Aviation law in Turkey is the body of legislation, regulation, and international convention that governs the operation of aircraft, the licensing of aviation entities, and the resolution of disputes arising from commercial aviation activity within Turkish airspace and territory. At its centre stands Law No. 2920, the Turkish Civil Aviation Act, enacted in 1983 and substantially reformed by Law No. 7519, whose changes entered full force in January 2026. The reform aligned Turkey’s regulatory architecture more closely with ICAO standards and the Chicago Convention than any version of the Act had done in a generation.

For foreign operators, that alignment matters more than any single clause in the new text. What changed in January 2026 was not simply a legislative update. It was a structural signal: Turkey’s civil aviation market, already one of the busiest in Europe by passenger throughput, now operates under a framework of aviation law in Turkey that international counterparts can read, anticipate, and work within. The Directorate General of Civil Aviation, SHGM, modernised its oversight framework, and new secondary regulations followed in the spring of 2026. The gap between what the market was and what the legal framework required began, at last, to close.

This page sets out what foreign airlines, lessors, financiers, ground handling companies, cargo operators, and their counsel need to understand about aviation law in Turkey in its current form: the regulatory architecture, the recent legislative changes, the operational risks that are easy to overlook, and the legal instruments available when disputes arise. Foreign operators who need counsel on these matters, rather than a legal overview, will find our separate page on instructing an aviation law firm in Turkey the more direct starting point.

⚖️ What Is the Legal Architecture Governing Aviation in Turkey?

Aviation law in Turkey rests on four interlocking layers. Each functions independently, but the risks foreign operators face almost always arise at the points where the layers intersect rather than within any single layer in isolation.

The first layer is statutory. Law No. 2920, the Turkish Civil Aviation Act, is the foundational instrument of aviation law in Turkey. It establishes the competence of SHGM, defines the rights and obligations of aircraft operators, sets the framework for licensing, and governs liability in air accidents. Its reform under Law No. 7519, fully effective from January 2026, introduced substantive changes to SHGM’s supervisory powers and aligned key provisions with the Chicago Convention’s annexes. The reform was not cosmetic. Several provisions that had remained unchanged for decades were rewritten, and the domestic regulatory environment that emerged is materially different from what existed before.

The second layer is regulatory. Secondary legislation issued by SHGM gives the statutory framework its operational content. This layer has been particularly active in recent months. The SHY-22 Ground Handling Services Regulation was amended in May 2026, revising the licensing and operational standards applicable to ground handling companies and airport operators. The SHY-GÜVENLİK Civil Aviation Security Regulation, published in Official Gazette No. 33261 on 22 May 2026, introduced cybersecurity compliance obligations alongside traditional physical security requirements, binding airlines, airports, ground handlers, and cargo operators alike. Two further instruments were in draft at SHGM during 2026: SHT-İHA, governing unmanned aircraft systems, and SHT-66, addressing maintenance personnel licensing.

The third layer is international convention law. Turkey is a contracting state to the Chicago Convention and a member of ICAO. The January 2026 reform incorporated ICAO standards into domestic aviation law in Turkey with greater clarity than earlier versions of Law No. 2920 had achieved. Turkey is also a party to the Montreal Convention of 1999 on passenger and cargo liability, which it ratified in 2009 and which entered into force for Turkey on 26 March 2011, and to the Cape Town Convention on International Interests in Mobile Equipment together with its Aircraft Protocol, both ratified by Turkey in 2011. These conventions are central to how liability and aircraft finance security interests are treated under aviation law in Turkey, and they are examined in detail below.

The fourth layer is private law. Aircraft leasing and financing transactions, ground handling agreements, maintenance contracts, and codeshare arrangements are governed by Turkish private international law under Law No. 5718, the Turkish Code of Obligations, and the Turkish Commercial Code. Parties to international commercial aviation contracts may choose foreign governing law. That choice is valid and enforceable under Turkish private international law, subject to mandatory provisions of Turkish law that apply regardless of the governing law clause. Understanding which Turkish provisions are mandatory and which are default rules is a legal question that shapes how every cross-border aviation contract involving Turkish parties or Turkish-registered aircraft should be structured.

⚖️ Why Does the January 2026 Reform Matter for Foreign Operators?

Foreign operators entering the Turkish market frequently carry a version of this assumption: compliance is the Turkish entity’s problem. The licence, the registration, the SHGM relationship belong to the local airline, the local ground handler, the local counterpart. The foreign lessor, the foreign financier, the foreign carrier using Turkish airports as a transit hub, operates at a layer of commercial distance that insulates it from regulatory exposure.

The January 2026 reform changed that assumption’s validity.

One practical effect of the reform, and of the secondary regulations that followed it, is that the conduct of foreign operators within Turkish territory is increasingly assessed against the standards of aviation law in Turkey, not only against the standards of the operator’s home jurisdiction. The May 2026 SHY-GÜVENLİK security regulation, for example, applies by its own terms to both domestic and foreign operators. The point is not that every foreign operator now needs a new Turkish licence. It is that regulatory scrutiny increasingly attaches to operational conduct within Turkish territory regardless of where the entity is domiciled.

What this means in practice varies by operator type. For a foreign airline, it means that ground handling arrangements, slot coordination practices, and safety compliance standards are assessed against aviation law in Turkey, not only against the standards of the operator’s home jurisdiction. For a foreign lessor, it means that repossession and enforcement procedures for Turkish-registered aircraft are subject to SHGM involvement, and the speed and outcome of those procedures depend on how the financing transaction was structured at the outset. For a foreign ground handling company seeking entry into the Turkish market, it means that the SHY-22 framework applies in full from the date of operational commencement, and the May 2026 amendment introduced requirements that earlier licence applications were not structured to satisfy.

None of this makes the Turkish aviation market inaccessible. Turkey’s strategic geography, the volume of its air traffic, and the commercial depth of its aviation sector make it a market that most serious international operators cannot afford to avoid. What the reform requires is that entry and operation be structured with an accurate understanding of aviation law in Turkey rather than assumptions formed before January 2026.

⚖️ The Regulatory Risks That Foreign Operators Consistently Underestimate

Every foreign operator that has encountered difficulty in the Turkish aviation market has, on reflection, identified a version of the same problem: the risk was visible in the documentation, but its practical consequence was not understood until it materialised. The following are the categories of risk that recur most frequently under aviation law in Turkey, and the ones that legal structuring can most effectively address before they become operational problems.

Licensing and Certification Gaps

Turkey operates a comprehensive licensing framework under SHGM authority. Airlines require an Air Operator Certificate. Ground handlers require an SHY-22 licence. Maintenance organisations require SHGM approval under the continuing airworthiness framework. The January 2026 reform and the spring 2026 secondary regulations updated the conditions for each of these authorisations. Operators whose licences were granted under the prior framework should verify that their existing authorisations satisfy the updated requirements. Licences issued before January 2026 are not automatically invalidated, but compliance assessments against the current standards of aviation law in Turkey are an operational prudence measure, not a formality.

Ground Handling Agreement Exposure

The May 2026 SHY-22 amendment introduced revised operational and safety standards for ground handling services. Airlines that contract with Turkish ground handlers typically operate under framework agreements that reference the regulatory standards in force at the time of signing. An agreement executed before the amendment may not incorporate the updated SHY-22 requirements by reference. This creates a potential gap between the contractual standard the airline believes applies and the regulatory standard that SHGM will assess the ground handler against. If an incident occurs in that gap, the allocation of liability between the airline and the ground handler depends on contract language that was drafted before the current regulatory baseline of aviation law in Turkey existed.

Cybersecurity Compliance

The SHY-GÜVENLİK regulation of May 2026 was the first Turkish aviation regulation to include explicit cybersecurity obligations. It applies to airlines, airports, ground handling companies, and cargo operators. The obligations are not aspirational. They establish minimum standards for cyber threat identification, incident response, and reporting. For foreign operators whose Turkish operations are managed from headquarters systems located outside Turkey, the question of how those systems interact with Turkish regulatory reporting requirements is a compliance issue that did not exist before 22 May 2026.

Repossession and Enforcement Uncertainty

Aircraft leasing and financing transactions involving Turkish-registered aircraft are subject to aviation law in Turkey for purposes of enforcement, even where the lease or loan agreement is governed by foreign law. Turkey’s status as a contracting state to the Cape Town Convention and its Aircraft Protocol provides a framework for international interests and deregistration, but the practical speed and outcome of enforcement still depend on how the transaction was structured at the outset, including the choice of registry, the drafting of deregistration authorisation provisions, and the selection of dispute resolution forum. The interaction between the Convention’s mechanisms and Turkish administrative practice should be confirmed for each specific transaction.

Dispute Resolution Misalignment

Commercial aviation contracts routinely include arbitration clauses. The choice of arbitral institution, seat, and governing law in those clauses has material consequences if a dispute proceeds. Turkish courts will enforce foreign arbitral awards under the New York Convention, to which Turkey is a party. However, the interaction between the arbitral award and any SHGM regulatory dimension of the underlying dispute requires careful analysis. A lessor that has obtained an arbitral award establishing its right to repossess an aircraft still needs to navigate aviation law in Turkey to give practical effect to that right.

⚖️ Aircraft Registration in Turkey: What the Framework Requires

Aircraft operating under Turkish registration are entered on the Turkish Civil Aircraft Registry, maintained by SHGM. The registration framework distinguishes between Turkish-owned aircraft and aircraft owned by foreign entities but registered in Turkey under a financial lease or similar arrangement.

For a foreign lessor placing an aircraft on the Turkish register under a lease to a Turkish airline, the key questions under aviation law in Turkey are: the conditions under which SHGM will consent to registration; the deregistration procedure if the lease terminates or defaults; and the documents required to support repossession. Turkey’s status as a contracting state to the Cape Town Aircraft Protocol is relevant to how deregistration and creditor remedies are approached, but the procedure that applies to a given aircraft, and the supporting documents SHGM will require, depend on the transaction and should be confirmed at the outset. These steps are best anticipated in the original transaction documents rather than addressed once a default has occurred.

Aircraft registered in Turkey are also subject to SHGM’s airworthiness oversight. The continuing airworthiness management framework sets out the obligations of operators and approved maintenance organisations with respect to aircraft in Turkish service. For lessors, this framework creates a practical monitoring requirement: the lessor needs visibility into the lessee’s maintenance compliance status, not only because a poorly maintained asset is a commercial risk, but because aircraft that do not meet continuing airworthiness standards can face operational consequences under SHGM oversight.

⚖️ Aircraft Leasing, Finance, and the Cape Town Convention

Turkey does not have a standalone aircraft leasing and finance statute. Leasing and financing transactions are governed by a combination of Law No. 2920, the Turkish Commercial Code, private international law rules under Law No. 5718, and SHGM regulatory requirements, read together with the Cape Town Convention framework. This combination defines the operative landscape of aviation law in Turkey for lessors and financiers.

Turkey ratified both the Cape Town Convention on International Interests in Mobile Equipment and the Protocol on Matters Specific to Aircraft Equipment in 2011, and made arrangements to harmonise its domestic law with both instruments. For lessors and financiers, this is significant. It means that an international interest in a Turkish-registered airframe, engine, or helicopter can be registered on the International Registry maintained under the Convention. How the Convention’s priority and remedy provisions operate in a specific case depends on the declarations Turkey made on ratification and on local procedure, which is a matter to assess at the structuring stage.

What this does not remove is the need for careful structuring. The declarations a contracting state makes on ratification determine which remedies are available and on what conditions, and the interaction between the Convention’s self-help and deregistration remedies and Turkish administrative and court practice is where transactions succeed or stall. A creditor relying on the Convention’s remedies should confirm, at the structuring stage, how those remedies are given effect in practice before SHGM and the Turkish courts under the current framework of aviation law in Turkey, rather than assuming the position is identical to other contracting states.

⚖️ Passenger and Cargo Liability: The Montreal Convention in Turkey

Liability for international carriage of passengers, baggage, and cargo by air is governed in Turkey by the Montreal Convention of 1999. Turkey ratified the Convention through its parliament in 2009, and it entered into force for Turkey on 26 March 2011. Under Article 90 of the Turkish Constitution, a ratified international convention has the force of national law, so the Montreal Convention applies directly to international carriage as defined within it, without separate implementing legislation.

For carriers, this establishes a familiar and predictable liability regime within the broader framework of aviation law in Turkey. The Convention applies a two-tier system for passenger death and injury, strict liability up to a defined threshold and a fault-based regime above it, and sets limits for baggage and cargo expressed in Special Drawing Rights. Before the Montreal Convention entered into force, Turkey applied the older Warsaw Convention system as amended. For carriage that falls outside the Montreal Convention’s scope, including purely domestic carriage, liability is governed by the Turkish Civil Aviation Act.

For foreign airlines operating to and from Turkey, the practical consequence is that liability exposure for international carriage is assessed under the same Montreal framework that applies across most of the world’s major aviation markets. The areas that require local legal attention are the points where the Convention interacts with Turkish procedural law: jurisdiction, the calculation of limits in Turkish proceedings, and the handling of claims that mix international and domestic carriage segments.

⚖️ Ground Handling and Airport Operations: The Post-SHY-22 Landscape

Ground handling services at Turkish airports are regulated under SHY-22, one of the most actively amended instruments in aviation law in Turkey in 2026. The regulation governs the licensing of ground handling companies, the scope of services each licensee may provide, the operational safety standards applicable to ramp activities, and the relationship between ground handlers and airport operators.

The May 2026 amendment updated several of these provisions. The principal changes affect licensing conditions, safety management system requirements, and the obligations of airport operators with respect to ground handler supervision. Ground handling companies operating in Turkey before the amendment entered into force should have conducted a compliance gap analysis against the updated SHY-22 text. Airlines that hold master ground handling agreements with Turkish service providers should verify that those agreements have been updated to reflect the current regulatory baseline.

Turkey’s airport infrastructure includes Istanbul Airport, one of the highest-capacity airports in Europe by design, and Sabiha Gokcen Airport on the Asian side of Istanbul, as well as major airports in Ankara, Izmir, Antalya, and a network of regional airports. Ground handling market access at each airport is governed by the applicable SHGM licence, the slot coordination framework, and the airport operating agreement. The structure of market access, and the legal protections available to a ground handler if access is restricted or terminated, depend on the specific contractual and regulatory instruments in place.

⚖️ Aviation Security and Cybersecurity Compliance

The SHY-GÜVENLİK regulation, published in Official Gazette No. 33261 on 22 May 2026, is Turkey’s primary civil aviation security instrument and one of the most significant recent developments in aviation law in Turkey. It consolidates and updates the security requirements applicable to the full range of aviation stakeholders: airlines, airport operators, ground handling companies, cargo and mail operators, and other designated entities in the aviation supply chain. By its own terms, it applies to both domestic and foreign operators active in Turkish civil aviation.

The regulation follows the ICAO security framework and the national civil aviation security programme. It establishes requirements across physical security of aircraft and facilities, personnel security and background verification, cargo and mail security, passenger and baggage processing, and, introduced explicitly for the first time in Turkish aviation security law, cybersecurity.

The cybersecurity provisions require designated entities to implement a cyber risk management framework, maintain incident detection and response capabilities, and report significant cyber incidents to the competent authority. The scope of designated entities is broad. Foreign operators with Turkish operations that use centralised IT systems should assess whether those systems and the data flows they support satisfy the new requirements.

Compliance is not optional for entities within scope. SHGM has audit authority to inspect security compliance and to impose operational restrictions on entities found to be non-compliant. The interaction between the regulation’s cybersecurity requirements and data protection obligations under Turkish personal data protection law, Law No. 6698, adds a further layer of compliance analysis for operators processing passenger or employee data within Turkish systems.

⚖️ Upcoming Regulatory Changes: What to Monitor

Two regulatory instruments were in draft at SHGM during 2026, and both carry material implications for specific categories of foreign operator under aviation law in Turkey.

SHT-İHA (Unmanned Aircraft Systems Regulation): a draft addressing the operation of drones and unmanned aerial systems in Turkish airspace, including registration requirements, operational restrictions, and licensing for commercial UAS operators. Foreign companies operating or planning to operate drone services in Turkey, whether for logistics, inspection, or media production, should monitor the publication of the final text and assess their operational models against the new framework before commencing activities.

SHT-66 (Maintenance Personnel Licensing): a draft addressing the licensing of aircraft maintenance engineers and technicians, including the recognition of foreign licences. Approved maintenance organisations operating in Turkey, and foreign organisations seeking Turkish approval, should assess the implications of the SHT-66 framework for their workforce licensing structure before the final text enters into force.

In both cases, the gap between draft publication and final entry into force provides a limited window for legal review and operational preparation. The January 2026 reform of Law No. 2920 demonstrated that SHGM is capable of moving quickly from legislative instruction to regulatory implementation. Treating draft publications as distant signals rather than proximate compliance obligations is a risk management error in any area of aviation law in Turkey.

⚖️ Aviation Dispute Resolution in Turkey

Disputes arising from aviation transactions and operations in Turkey are resolved through one of three principal mechanisms: Turkish courts, domestic arbitration, and international arbitration. The appropriate mechanism depends on the nature of the dispute, the governing law and jurisdiction clauses in the relevant contract, and the practical enforceability considerations that apply to each option.

Turkish courts have jurisdiction over disputes where Turkey is the seat of the aviation operation, where a Turkish-registered aircraft is involved, or where a Turkish party is the defendant. The commercial courts in Istanbul handle aviation disputes with reasonable familiarity, particularly in relation to cargo claims, passenger rights, and insurance disputes. For high-value commercial disputes between sophisticated parties, however, the standard market practice is international arbitration.

International arbitration clauses in Turkish aviation contracts typically designate institutions such as the London Court of International Arbitration, the International Chamber of Commerce, or the Istanbul Arbitration Centre. Turkish law, under Law No. 4686 on International Arbitration, supports international arbitration and its enforcement. Turkey is a party to the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, and foreign arbitral awards are recognised and enforced in Turkey where the formal requirements of the Convention are satisfied.

The practical consideration that parties sometimes underestimate is the interaction between an arbitral award and the regulatory dimension of the underlying dispute. An arbitral tribunal has authority over the contractual rights and obligations of the parties. It does not have authority over SHGM’s regulatory decisions. A lessor with an arbitral award establishing its right to terminate a lease and repossess an aircraft still needs to engage with the SHGM deregistration and repossession framework under aviation law in Turkey to give practical effect to that right. This interaction should be anticipated in the dispute resolution clause and the enforcement strategy before a dispute arises, not after.

⚖️ How Aviation Law Intersects with Turkish Investment and Corporate Law

Foreign aviation operators entering the Turkish market must make a structural choice that has legal consequences well beyond the aviation regulatory framework: whether to operate through a Turkish legal entity, through a branch, or on a purely transactional basis without local establishment.

The choice has implications across at least four legal domains. First, the SHGM licensing framework: certain SHGM licences may require the applicant to be a Turkish legal entity. Foreign operators wishing to hold an SHGM licence directly, rather than through a Turkish partner, should confirm the entity requirements for the specific licence, which may mean establishing a Turkish company or at minimum a Turkish branch with the appropriate corporate capacity.

Second, the tax treatment of aviation income: Turkey’s corporate tax framework applies to Turkish-resident entities and to permanent establishments of foreign entities in Turkey. Aviation income that passes through a Turkish entity is subject to Turkish corporate taxation, the current standard rate being 25 per cent, unless a tax treaty between Turkey and the operator’s home jurisdiction provides for reduced or eliminated withholding on specific income categories such as aircraft lease payments.

Third, employment law: aviation personnel employed in Turkey, whether flight crew based at Turkish airports or ground-based operations staff, are subject to Turkish labour law. The Turkish Labour Act, Law No. 4857, establishes mandatory employment protections that apply regardless of the governing law clause in any individual employment contract.

Fourth, corporate governance: Turkish limited liability companies and joint stock companies are governed by the Turkish Commercial Code, Law No. 6102. Foreign-owned Turkish entities must comply with Turkish corporate governance requirements, including annual general meeting obligations, financial reporting standards, and beneficial ownership disclosure requirements connected to anti-money laundering legislation.

The interaction between these domains means that entry into the Turkish aviation market is not a single legal transaction. It is a structured programme that typically involves corporate establishment, SHGM licensing, employment contracting, tax planning, and ongoing compliance with aviation law in Turkey across multiple frameworks simultaneously.

⚖️ What to Look for When Selecting Legal Counsel for Turkish Aviation Matters

The selection of legal counsel for Turkish aviation matters is itself a legal risk management decision. The Turkish legal market includes generalist firms, aviation-specialist firms, and international firms with Turkish desks. Each has a different capacity profile for the work that aviation clients actually need.

The most important distinction is not between large and small firms. It is between counsel who understand aviation law in Turkey and counsel who understand aviation law in Turkey and have advised on its application in transactions and disputes. Turkish aviation law is not a static body of text that can be read and applied without contextual knowledge. Law No. 2920 has been reformed. SHGM’s administrative practice evolves. The secondary regulatory framework is actively developing. Counsel who have not worked on Turkish aviation matters in the post-January 2026 environment may be applying an understanding of the framework that is structurally accurate but operationally outdated.

A second practical consideration is language. Turkish aviation regulatory proceedings, SHGM correspondence, Turkish court proceedings, and Turkish arbitration are conducted in Turkish. Foreign operators working through counsel who do not have Turkish-language fluency at regulatory and technical level are dependent on intermediary translations that can create delay, misunderstanding, and, in contentious proceedings, material procedural risk.

A third consideration is the relationship between aviation law expertise and complementary practice areas. The issues that arise in Turkish aviation transactions almost always involve a combination of aviation law in Turkey, corporate law, tax law, and potentially arbitration or litigation. Counsel who can provide integrated advice across these areas, without requiring the client to coordinate multiple specialist firms, reduce both cost and the risk of gaps in the advice received.

⚖️ Why Foreign Aviation Clients Work with Oznur & Partners

Oznur & Partners is a Turkish law firm based in Istanbul, listed in Legal 500 EMEA, with a practice that advises international corporate clients across investment, regulatory, and dispute resolution matters. The firm’s aviation practice advises foreign airlines, lessors, financiers, ground handling companies, and cargo operators on the full range of legal issues arising from aviation law in Turkey.

The firm’s engagement model is designed for international clients. Initial consultations and ongoing advisory work are conducted remotely where the client prefers. Document review, contract drafting, and regulatory correspondence are managed digitally. Where Turkish notarisation, apostille, or in-person representation before SHGM or Turkish courts is required, the firm handles those procedures directly without requiring the client to be present in Turkey.

The firm advises on regulatory compliance under the reformed Law No. 2920 framework, SHGM licensing and approval procedures, aircraft registration and deregistration, ground handling agreement structuring and review, cybersecurity compliance under SHY-GÜVENLİK, aviation contract drafting under Turkish and international law, and dispute resolution including international arbitration involving Turkish aviation parties.

Legal advice on aviation law in Turkey is provided in English and Turkish. Clients whose transactions involve Russian-speaking parties or Chinese-speaking counterparts can also be accommodated through the firm’s multilingual advisory capacity.

❓ Frequently Asked Questions: Aviation Law in Turkey

✅ What is the primary legislation governing aviation law in Turkey?

Aviation law in Turkey is primarily governed by the Turkish Civil Aviation Act, Law No. 2920, enacted in 1983. The Act was substantially amended by Law No. 7519, whose changes entered into full force in January 2026, aligning Turkey’s regulatory framework more closely with ICAO standards and the Chicago Convention.

✅ Which authority regulates civil aviation in Turkey?

The Directorate General of Civil Aviation, known by its Turkish abbreviation SHGM (Sivil Havacılık Genel Müdürlüğü), is the primary regulatory authority for civil aviation in Turkey. Following the 2026 reform of Law No. 2920, SHGM’s supervisory framework was updated and its oversight role clarified. SHGM regulates operators active in Turkish civil aviation, and foreign operators should assess how the reformed framework applies to their specific activities.

✅ Do foreign airlines and operators need to comply with Turkish aviation regulations?

Yes. Foreign airlines, ground handlers, cargo operators, and lessors operating in Turkey or using Turkish airspace are subject to SHGM oversight in respect of their activities in Turkey. Operators should assess how the reformed Law No. 2920 framework and the 2026 secondary regulations apply to their specific operations.

✅ Is Turkey a signatory to the Chicago Convention?

Yes. Turkey is a contracting state to the Convention on International Civil Aviation (Chicago Convention) and a member of ICAO. The January 2026 reform of Law No. 2920 aligned domestic aviation legislation more closely with ICAO standards, making Turkey’s regulatory environment more predictable for international operators.

✅ Is Turkey a party to the Montreal Convention on air carrier liability?

Yes. Turkey ratified the 1999 Montreal Convention for the Unification of Certain Rules for International Carriage by Air in 2009, and it entered into force for Turkey on 26 March 2011. Under Article 90 of the Turkish Constitution, the Convention has the force of national law and applies directly to international carriage of passengers, baggage, and cargo.

✅ Does the Cape Town Convention apply to aircraft registered in Turkey?

Yes. Turkey ratified the Cape Town Convention on International Interests in Mobile Equipment and its Aircraft Protocol in 2011. International interests in Turkish-registered aircraft objects can therefore be registered on the International Registry, and the Convention’s priority and remedy provisions apply, subject to the declarations Turkey made on ratification. The practical application of specific remedies before SHGM and the Turkish courts should be confirmed for each transaction.

✅ What are the main legal risks for foreign operators entering the Turkish aviation market?

Key legal risks include non-compliance with SHGM licensing requirements, failure to adapt operational structures to the reformed Law No. 2920 framework, exposure to expanded regulatory enforcement powers, gaps in ground handling agreements following the May 2026 SHY-22 amendment, and cybersecurity compliance obligations introduced by the SHY-GÜVENLİK regulation of May 2026.

✅ How are aviation disputes resolved in Turkey?

Aviation disputes in Turkey may be resolved through Turkish courts, domestic arbitration, or international arbitration. Commercial aviation contracts frequently include arbitration clauses referencing institutions such as the LCIA, ICC, or ISTAC. Turkish law permits parties to choose foreign governing law for international commercial contracts, subject to mandatory provisions of Turkish law.

✅ What is the SHY-22 regulation and who does it affect?

SHY-22 is Turkey’s Ground Handling Services Regulation. An amendment in May 2026 updated the licensing, operational, and safety requirements applicable to ground handling companies and airport operators. Any entity providing or procuring ground handling services at Turkish airports must review its agreements and compliance procedures against the updated SHY-22 framework.

✅ What does the SHY-GÜVENLİK regulation require from aviation stakeholders?

The SHY-GÜVENLİK Civil Aviation Security Regulation, published on 22 May 2026 in Official Gazette No. 33261, establishes security and cybersecurity compliance obligations for airlines, airports, ground handlers, and cargo operators. It introduced explicit requirements for cyber threat management alongside traditional physical security obligations, and applies to both domestic and foreign operators.

✅ Can aviation contracts in Turkey be governed by foreign law?

Yes. Turkish private international law, under Law No. 5718, permits parties to choose foreign governing law for international commercial contracts, including aircraft leasing and financing agreements. However, certain mandatory provisions of Turkish law apply regardless of the chosen governing law, and the practical enforcement of contractual rights in Turkey requires familiarity with SHGM procedures and Turkish court processes.

✅ What upcoming aviation regulations should foreign operators monitor in Turkey?

Two regulatory instruments were in draft at SHGM during 2026: SHT-İHA, which will govern unmanned aircraft systems, and SHT-66, addressing maintenance personnel licensing. Foreign operators involved in drone operations or aircraft maintenance should monitor the publication of the final texts and assess their operational models against the new frameworks.

✅ Does Turkey have specific regulations for aircraft leasing and finance?

Turkey does not have a standalone aircraft leasing and finance statute. Leasing and financing transactions are governed by a combination of Law No. 2920, the Turkish Commercial Code, private international law rules under Law No. 5718, SHGM regulatory requirements, and the Cape Town Convention framework, to which Turkey has been a contracting state since 2011.

✅ How can Oznur & Partners assist foreign aviation clients?

Oznur & Partners advises foreign airlines, lessors, financiers, ground handling companies, and cargo operators on regulatory compliance with Turkish aviation law, SHGM licensing requirements, contract structuring under Turkish and international law, and dispute resolution including international arbitration. The firm is listed in Legal 500 EMEA and operates from Istanbul with a remote-capable engagement model for international clients.

Turkey’s civil aviation market sits at one of the most consequential intersections in global air transport: between Europe and Asia, between established carriers and fast-growing regional networks, between a rapidly modernising regulatory environment and the operational realities of an airport system that handles among the highest passenger volumes on the continent. For foreign operators, that intersection is an opportunity and a legal landscape simultaneously. The January 2026 reform of Law No. 2920 did not make that landscape more complex. It made it more transparent, more aligned with international standards, and, for operators who understand the current framework, more navigable than it has ever been.