Turkish Citizenship by Investment: Which Investment Should You Choose? 2026 — Property, Bank Deposit, Government Bonds, Real Estate and Venture Capital Funds, Private Pension, Fixed Capital and Employment: Comparing the Seven Routes (Regulation Art. 20)
08 October 2026

Turkish Citizenship by Investment: Which Investment Should You Choose? 2026 — Property, Bank Deposit, Government Bonds, Real Estate and Venture Capital Funds, Private Pension, Fixed Capital and Employment: Comparing the Seven Routes (Regulation Art. 20)

Türkçe sürüm: Yatırım Yoluyla Türk Vatandaşlığında Hangi Yatırım?

There is no single route to Turkish citizenship by investment. Article 20(2) of the Regulation on the Implementation of the Turkish Citizenship Law lists seven separate investment routes: a fixed capital investment of at least USD 500,000, real estate worth at least USD 400,000, employment of at least 50 people, a bank deposit of at least USD 500,000, government debt securities of at least USD 500,000, units in a real estate investment fund or venture capital investment fund of at least USD 500,000, and private pension contributions of at least USD 500,000. In the real estate, deposit, government debt, fund and private pension routes, the Regulation expressly requires the investment to be kept for three years; in the deposit, government debt and private pension routes, the foreign currency is first sold to a bank and then held in Turkish lira for three years. For an investor, therefore, the real question is not “can I get citizenship?” but “with which investment, taking which risk, and how will I get my money back after three years?” This guide compares the seven routes from the investor’s point of view, with the legal provisions, the implementing rules of the competent authorities and the developments of 2026.

Short answer: which investment should you choose for Turkish citizenship by investment?

1. All seven routes can lead to Turkish citizenship by Presidential decision; however, the decision is discretionary and requires that there be no obstacle in terms of national security and public order (Turkish Citizenship Law No. 5901, Arts. 12(1)(b) and 12(2); Regulation, Art. 20(2)). The differences lie in the minimum amount, in which currency and instrument the money is held for three years, in the return and in the exit.

2. The real estate route has the lowest threshold (USD 400,000), but since 12 December 2023 only independent units subject to condominium ownership or construction servitude (kat irtifakı) and plots with a building on them qualify; a three-year no-sale annotation is entered in the land register, and a valuation report and a foreign exchange purchase certificate are required.

3. In the deposit (Art. 20(2)(ç)), government debt (Art. 20(2)(d)) and private pension (Art. 20(2)(f)) routes, the foreign currency is sold to a bank operating in Turkey, and by that bank to the Central Bank, and the Turkish lira obtained is held for three years in a Turkish lira deposit, in Turkish lira government debt securities or in the designated pension funds (Art. 20(10)). In these routes the risk of the Turkish lira losing value lies with the investor.

4. In the fund route, only units in real estate investment funds (GYF) and venture capital investment funds (GSYF) qualify; shares in real estate investment trusts (REITs, GYO) are outside the scope of this route (Art. 20(2)(e)).

5. In every route, the competent authority determines whether the investment meets the conditions and issues a certificate of conformity (uygunluk belgesi); a short-term residence permit is then obtained under Law No. 6458, Art. 31(1)(j), and the citizenship application is filed. In 2026, the service fee for an application for exceptional citizenship is TRY 135.45 per person.

6. Losing the conditions, for example by disposing of the investment before the end of the period, can lead to the cancellation of the citizenship decision under Article 31 of the Citizenship Law. On 4 August 2026, the Ministry of Interior announced that the certificates of conformity of 1,150 investors found to have carried out sham or irregular transactions had been cancelled, and that the citizenship decisions of 5,391 people, including family members, had been cancelled.

Let us work out together which route to citizenship suits you

If you are planning the real estate, deposit, government bond, fund, private pension, capital or employment route, send us your investment amount, your family situation and your exit plan for after three years via WhatsApp, and we will structure the certificate of conformity, residence permit and citizenship application together. We can correspond in English. Hukukçular Evi Ankara: +90 554 648 37 15

📞 +90 554 648 37 15💬 WhatsApp

Legal framework: the seven routes at a glance

Article 12 of Turkish Citizenship Law No. 5901 provides that certain foreigners may acquire Turkish citizenship by Presidential decision, provided that they pose no obstacle in terms of national security and public order. Paragraph 1(b) of the article covers foreigners who have obtained a residence permit under Article 31(1)(j) of Law No. 6458 on Foreigners and International Protection and holders of the Turquoise Card, together with their foreign spouse and their own and their spouse’s minor or dependent foreign children. Article 31(1)(j) of Law No. 6458, in turn, provides for a short-term residence permit for foreigners who do not work in Turkey but will make an investment of the scope and amount determined by the President. The scope and amount of the investment are listed in Article 20(2) of the Regulation on the Implementation of the Turkish Citizenship Law, which states that a foreigner who meets any one of the following conditions may acquire Turkish citizenship by Presidential decision.

Regulation, Art. 20(2): the seven investment routes

Sub-paragraphInvestmentMinimum amount and periodDetermining authority
Art. 20(2)(a)Fixed capital investmentAt least USD 500,000 or the equivalent in foreign currencyMinistry of Industry and Technology
Art. 20(2)(b)Purchase of real estate or a notarized promise-to-sell contractAt least USD 400,000 or the equivalent in foreign currency; three-year no-sale annotation in the land register (for a promise to sell, an annotation that the contract will not be assigned or deleted from the register)Ministry of Environment, Urbanization and Climate Change (in practice, the General Directorate of Land Registry and Cadastre)
Art. 20(2)(c)Creating employmentEmployment of at least 50 peopleMinistry of Labour and Social Security
Art. 20(2)(ç)Bank depositAt least USD 500,000 or the equivalent in foreign currency; to be held for three yearsBanking Regulation and Supervision Agency (BDDK)
Art. 20(2)(d)Government debt securitiesAt least USD 500,000 or the equivalent in foreign currency; to be held for three yearsMinistry of Treasury and Finance
Art. 20(2)(e)Units in a real estate investment fund or venture capital investment fundAt least USD 500,000 or the equivalent in foreign currency; to be held for at least three yearsCapital Markets Board (SPK)
Art. 20(2)(f)Private pension system contributionsAt least USD 500,000 or the equivalent in foreign currency; held in designated funds and kept in the system for three yearsInsurance and Private Pension Regulation and Supervision Agency (SEDDK)

How did the amounts reach their current level? The investment routes first entered the Regulation through an amendment published in the Official Gazette of 12 January 2017; at that time USD 1,000,000 was required for real estate and USD 3,000,000 for a deposit. Presidential Decision No. 106, published in the Official Gazette of 19 September 2018, reduced the real estate threshold to USD 250,000, the fixed capital, deposit, government debt and fund thresholds to USD 500,000, and the employment requirement to 50 people. Decision No. 418, published in the Official Gazette of 7 December 2018, added the notarized promise-to-sell option; Decision No. 5072, published in the Official Gazette of 6 January 2022, introduced the rule that the foreign currency must be sold to a bank; and Decision No. 5554, published in the Official Gazette of 13 May 2022, raised the real estate threshold to USD 400,000 with effect from 13 June 2022 and added the private pension route. The latest change is Presidential Decision No. 7938, published in the Official Gazette of 12 December 2023, No. 32397, which restricted the type of real estate. Article 20 has not been amended since; the amounts and conditions remain the same in 2026.

For the other ways of acquiring citizenship and the general framework, see our guide (in Turkish) Türk Vatandaşlığı Nasıl Alınır? (how to acquire Turkish citizenship), and for the structure of the investment route in the Law and the Regulation, our articles (in Turkish) Türk Vatandaşlığına Yatırım Yoluyla Alınma (acquiring citizenship by investment) and Yatırım Yoluyla Türk Vatandaşlığı: İstisnai Kulvarın Tam Haritası (a full map of the exceptional route).

Rules common to all routes

Exchange rate. The monetary values listed in the Regulation are determined on the basis of the Central Bank of the Republic of Turkey’s effective selling rate and/or cross exchange rate on the date of determination (Art. 20(6)). Where the investment is made in a currency other than the US dollar or after conversion into Turkish lira, whether the threshold is met is calculated at this rate.

Selling the foreign currency to a bank. In the real estate, deposit, government debt, fund and private pension routes (Art. 20(2)(b), (ç), (d), (e) and (f)), the foreign currency amounts are sold, before the transaction, to a bank operating in Turkey, and by that bank to the Central Bank. The Turkish lira obtained is held for three years: in the deposit route in a Turkish lira deposit, in the government debt route in Turkish lira government debt securities, and in the private pension route in the funds designated by SEDDK; the Central Bank sets the implementing rules (Art. 20(10)). For the investor, this rule is the most important economic difference: for three years, the money stays in Turkish lira.

Switching between routes. The Regulation expressly provides that switching between the investment types listed in paragraph 2 is possible in order to complete the required period (Art. 20(8)). However, the authorities’ implementing rules regulate how a switch is made; for example, the Ministry of Treasury and Finance’s rules allow switching between investment types, but within the government debt route do not allow one government debt security to be exchanged for another, except where the Ministry redeems them early. If a switch is planned, confirmation should be obtained in advance from the authority of both the route being left and the route being entered.

Implementing rules. The procedures and principles for determining whether the investment conditions are met are set by the determining authority (Art. 20(9)). For this reason, the rules published by the relevant authority are explained separately below for each route.

Rules common to the seven routes

RuleContentLegal basis
Decision-makerCitizenship is granted by Presidential decision; there must be no obstacle in terms of national security and public orderCitizenship Law, Art. 12(1); Regulation, Art. 20(2)
Exchange rateCentral Bank effective selling rate and/or cross rate on the date of determinationRegulation, Art. 20(6)
Selling the foreign currency to a bankMandatory before the transaction in the real estate, deposit, government debt, fund and private pension routesRegulation, Art. 20(10)
Holding in Turkish liraThree years in the deposit, government debt and private pension routesRegulation, Art. 20(10)
Switching between routesPossible in order to complete the period; the procedure is set by the authorities’ rulesRegulation, Art. 20(8)
Determination of conformityThe procedures are set by the determining authorityRegulation, Art. 20(9)
Loss of the conditionsUnder the implementing rules of NVİ (the General Directorate of Population and Citizenship Affairs), the citizenship decision is cancelled under Article 31 of the LawNVİ Procedures and Principles, Art. 8(1); Citizenship Law, Art. 31

Real estate route: USD 400,000

Article 20(2)(b) of the Regulation provides two separate options. The first is buying real estate worth at least USD 400,000 or the equivalent in foreign currency that is subject to condominium ownership or construction servitude (kat irtifakı) or is a plot with a building on it, on condition that a three-year no-sale annotation is entered in the land register. The second is a notarized promise-to-sell contract for real estate subject to condominium ownership or construction servitude, for which at least USD 400,000 or the equivalent in foreign currency has been paid upfront in full and an undertaking not to assign the contract or have it deleted (terkin) from the land register for three years has been annotated in the register. In both options, the determination is made by the Ministry of Environment, Urbanization and Climate Change; in practice, the regional directorate of the General Directorate of Land Registry and Cadastre (TKGM) issues a “Real Estate Investment Determination Certificate” (Taşınmaz Yatırım Tespit Belgesi).

Which properties qualify? Presidential Decision No. 7938, published in the Official Gazette of 12 December 2023, No. 32397, restricted the type of property. Under the TKGM instruction of 13 December 2023, an independent unit must be registered as a separate independent unit under Condominium Law No. 634, and a plot must have a building on it with an occupancy permit (yapı kullanma izin belgesi); agricultural fields and vacant plots do not qualify for this route. The rule applies to acquisitions made from 12 December 2023 onwards.

Restrictions in the TKGM guide. The TKGM Guide on the Regulation, applicable from 1 February 2024, sets the following rules: a property may be used for citizenship only once; an application cannot be based on a share in a property; acquisitions in the name of a spouse, child or similar persons are not counted towards the required value; properties bought before 12 January 2017 and properties that were the subject of a promise-to-sell contract before 7 December 2018 are not counted. Under the guide’s conditions concerning the parties, the property must not be registered in the name of foreigners, of the buyer’s first-degree relatives who are Turkish citizens or of persons who acquired citizenship by investment, nor in the name of a company in which the buyer or the buyer’s first-degree relatives are a partner or manager. A second-hand property must not have been transferred to a Turkish citizen or company by the buyer or by the buyer’s first-degree relatives, whether or not they are Turkish citizens, nor within the last three years by any foreign natural person or by a person who acquired citizenship by investment; transfers arising from contracts for work (eser sözleşmesi), such as construction contracts, are outside this three-year rule. Property subject to a statutory mortgage cannot be used for citizenship; mortgaged or attached (seized, haciz) property may be sold, but its price is not counted in the investment determination. There is no limit on the number of properties acquired by sale. On the promise-to-sell route, the price must have been paid no later than the date of the contract, and applications based on more than one promise-to-sell contract are not considered. If the property is bought with a foreign currency loan, the remainder after deducting the loan amount from the sale price must reach USD 400,000. Because the guide’s rules are administrative practice, the current practice should be confirmed with the land registry office before buying.

Foreign exchange purchase certificate and payment. TKGM Circular No. 2022/1 provides that, for real estate bought in Turkey by persons who have no citizenship link with the Republic of Turkey, the foreign currency must, under the Central Bank’s Circular on Capital Movements, be sold before the land registry transaction to a bank, stating the reason, and by the bank to the Central Bank, and that the Turkish lira amount recorded in the foreign exchange purchase certificate (döviz alım belgesi) is declared to the land registry as the sale price. Under the guide, the bank sends the foreign exchange purchase certificate to the land registry office through KEP (registered electronic mail), and a certified bank receipt showing that the price was paid to the seller or a related party (ilgilisi) is submitted to the land registry office before the undertaking is registered. Payment in cash, or to third parties whose connection cannot be explained, therefore creates serious risk.

Valuation report. Whether the property reaches USD 400,000 is determined by a valuation report. Under the guide, valuation reports must be obtained through Web Tapu (via the TADEBİS system). Under TKGM Circular No. 2024/2, dated 1 March 2024 and in force from 4 March 2024, these reports were commissioned from a single firm, Gayrimenkul Değerleme AŞ (GEDAŞ), an affiliate of TOKİ (the Housing Development Administration); in its statement of August 2026, the Ministry of Interior also stated that since 2024 certificates of conformity had been issued on the basis of GEDAŞ reports. The circular was updated on 28 September 2026; by a Ministerial Approval dated 18 September 2026, it was decided that valuation reports used in determinations for citizenship purposes may be prepared by any valuation firm licensed by the Capital Markets Board. The guide provides that reports submitted with an application are valid for three months from their date; since the period of use for reports in land registry transactions was also revised by the 28 September 2026 update, the applicable period should be confirmed with the land registry office on the date of application.

The annotation and life after three years. An undertaking annotation stating that the property will not be sold within three years is entered in the land register; once the three-year period has ended, the annotation is deleted (terkin) at the owner’s request. The frequently asked questions page of NVİ states that Syrian nationals cannot apply through the real estate route.

Tax and costs. The title deed fee is 2% (twenty per thousand) each for the buyer and the seller (Fees Law No. 492, Tariff No. 4, I-20). On the first delivery of buildings constructed as residences or workplaces, deliveries to foreign individuals not resident in Turkey are exempt from VAT, provided the price is brought into Turkey in foreign currency; if the property is disposed of within three years, the person disposing of it must pay the tax not collected on time, together with deferral interest calculated under Article 48 of Law No. 6183, before the land registry transaction (VAT Law No. 3065, Art. 13(i)). For the tax and citizenship consequences of buying in your own name or through a company, see our guide Buying Property in Turkey: In Your Own Name or Through a Turkish Company?, and for the limits on property acquisition by foreigners, our article (in Turkish) Yabancılar Türkiye’de Taşınmaz Alabilir mi? (can foreigners buy property in Turkey?).

Real estate route checklist

CheckRuleLegal basis
Type of propertyIndependent unit subject to condominium ownership or construction servitude, or a plot with a building that has an occupancy permit; not agricultural fields or vacant plotsRegulation, Art. 20(2)(b) (Presidential Decision No. 7938); TKGM instruction of 13.12.2023
AmountAt least USD 400,000 or the equivalent in foreign currency; for purchases with a foreign currency loan, the loan amount is deductedRegulation, Art. 20(2)(b); TKGM Guide
OwnerIn the foreigner’s own name; acquisitions in the name of a spouse or child are not counted; no acquisition of a shareTKGM Guide
History of the propertyNot previously used for citizenship; not transferred to a Turkish citizen/company by the buyer or the buyer’s first-degree relatives, nor within the last three years by a foreigner or an investor-citizen; not subject to a statutory mortgageTKGM Guide
PaymentForeign currency first sold to a bank; foreign exchange purchase certificate and certified bank receipt showing payment to the seller submitted before the undertakingRegulation, Art. 20(10); TKGM Circular No. 2022/1
ValuationReport obtained through Web Tapu from a valuation firm licensed by the Capital Markets BoardTKGM Circular No. 2024/2 (update of 28.09.2026)
AnnotationThree-year no-sale annotation (for a promise to sell, no assignment or deletion from the register); deleted at the owner’s request when the period endsRegulation, Art. 20(2)(b); TKGM Guide

Bank deposit route: USD 500,000, three years in Turkish lira

Under Article 20(2)(ç) of the Regulation, a foreigner whom BDDK has determined to have deposited at least USD 500,000 or the equivalent in foreign currency with banks operating in Turkey, on condition of keeping it for three years, may apply for citizenship. Since 6 January 2022, the foreign currency is first sold to the bank, and by the bank to the Central Bank, and the Turkish lira obtained is held in a Turkish lira deposit for three years (Art. 20(10)). In practice, therefore, the deposit route today is not a foreign currency account but a three-year Turkish lira deposit.

Two consequences matter for the investor. First, the risk of the Turkish lira losing value over the three years lies with the investor; in return, Turkish lira deposit interest is earned. Second, withholding tax is deducted from the interest under Provisional Article 67 of the Income Tax Law: as of October 2026, the withholding rate on Turkish lira deposits is 17.5% for terms of up to six months, 15% for terms of up to one year and 10% for terms of more than one year, and these rates also apply to individuals not resident in Turkey. Because the rates are set by time-limited Presidential Decisions, they should be checked again on the investment date, and the effect of any double tax treaty should be assessed separately. Whether the money can be split between several banks, how maturities are rolled over and how the interest can be used should be confirmed in advance with the bank in line with BDDK’s current practice.

Government debt securities route: the Ministry of Treasury and Finance’s 2026 rules

Article 20(2)(d) of the Regulation covers a foreigner who buys government debt securities of at least USD 500,000 or the equivalent in foreign currency on condition of holding them for three years; the determination is made by the Ministry of Treasury and Finance. The “Procedures and Principles for the Application Processes of Foreigners Wishing to Acquire Turkish Citizenship Exceptionally by Purchasing Government Debt Securities”, published by the Ministry in 2026 and repealing the earlier rules of 14 February 2020, set the following rules:

  • Only Turkish lira domestic government debt securities issued by the Ministry and Turkish lira lease certificates (kira sertifikası) issued domestically by Hazine Müsteşarlığı Varlık Kiralama AŞ qualify (Art. 3(1)(b)).
  • The bank where the foreign currency is sold and the bank where the investment is made must be the same; transfers between banks are not allowed (Art. 4(2)).
  • As a rule, government debt securities with less than three years to maturity should not be used for a citizenship application; choosing a suitable instrument is the responsibility of the bank and the investor (Art. 4(4)).
  • The investor is free to use the interest or lease income of the instrument held in the account (Art. 4(5)).
  • A fall in value below the minimum amount due to a drop in the market price does not affect the citizenship application or acquisition; the minimum investment condition is not deemed lost (Art. 4(10)).
  • Except where the Ministry redeems the securities early, switching between government debt securities is not allowed (Art. 7(1)).

On the tax side, Presidential Decision No. 11444, published in the Official Gazette of 20 June 2026, No. 33286, extended until 31 December 2026 the withholding tax advantage applied to income from government bonds, Treasury bills and public lease certificates; the rate for 2027 and later should be monitored throughout the investment period.

GYF and GSYF fund route: SPK and the MKK blocking account

Under Article 20(2)(e) of the Regulation, a foreigner who buys units in a real estate investment fund or a venture capital investment fund of at least USD 500,000 or the equivalent in foreign currency, on condition of holding them for at least three years, may apply through this route; the determination is made by the Capital Markets Board (SPK). The scope is limited to units in these two types of fund; shares in real estate investment trusts (GYO) traded on Borsa Istanbul are not listed in this sub-paragraph.

According to SPK, the units are tracked in a “Citizenship Blocking Sub-Account” (Vatandaşlık Blokaj Alt Hesabı) at the Central Registry Agency (MKK); the blocking is optional. The investor must hold the units continuously for three years from the date on which the minimum amount is reached. MKK responds to SPK’s request within three business days, and once it is confirmed that the conditions are met, the certificate of conformity is issued within two business days. A fall in value below USD 500,000 due to exchange rate movements does not affect the application or the acquisition; nor is a fall in value caused by the fund’s own transactions outside the investor’s control, such as cash dividend distributions, redemption of units or liquidation, treated as a loss of the condition. On the tax side, under the rules shaped most recently by Presidential Decision No. 11107, published in the Official Gazette of 27 March 2026, No. 33206, within the framework of Provisional Article 67 of the Income Tax Law, the withholding rate on gains from units in venture capital investment funds and real estate investment funds held for more than two years is 0%. On the account-opening process for foreign investors in the capital markets, see our guide Can Foreign Investors Buy Shares on Borsa Istanbul?

Private pension route

Article 20(2)(f), added by Presidential Decision No. 5554 published in the Official Gazette of 13 May 2022, No. 31834, covers a foreigner who pays contributions of at least USD 500,000 or the equivalent in foreign currency into the private pension system, on condition of holding them in funds whose scope is determined by SEDDK and remaining in the system for three years; the determination is made by SEDDK. The foreign currency is first sold to a bank, and the Turkish lira obtained is held for three years in the funds designated by SEDDK (Art. 20(10)). Which funds are within the scope and how the contract is to be set up are determined by SEDDK’s procedures and principles (Art. 20(9)); these should be checked before a contract is signed with a pension company.

Comparison of the financial routes

IssueDeposit (Art. 20(2)(ç))Government debt (Art. 20(2)(d))GYF / GSYF (Art. 20(2)(e))Private pension (Art. 20(2)(f))
Determining authorityBDDKMinistry of Treasury and FinanceSPKSEDDK
Currency during the three yearsTurkish lira depositTurkish lira instrumentDepends on the assets the fund invests inFunds designated by SEDDK
ReturnDeposit interest; withholding of 10–17.5% depending on the termInterest or lease income freely usable; withholding tax advantage extended to 31.12.2026Fund performance; 0% withholding if held for more than two yearsFund performance
Fall in valueExchange rate risk lies with the investorA fall in the market price does not breach the conditionA fall due to exchange rate movements or to the fund’s distributions, redemptions or liquidation does not breach the conditionUnder SEDDK’s rules
Special ruleBank and maturity structure to be confirmed in advanceSame bank; instruments with less than three years to maturity should, as a rule, not be used; no switching between instrumentsMKK Citizenship Blocking Sub-Account; REIT (GYO) shares excludedRemaining in the system for three years

Fixed capital investment and employment routes

Fixed capital investment. Article 20(2)(a) of the Regulation covers a foreigner whom the Ministry of Industry and Technology has determined to have made a fixed capital investment of at least USD 500,000 or the equivalent in foreign currency. Like the employment route (Art. 20(2)(c)), this route is not among the sub-paragraphs listed in the rule on selling foreign currency to a bank (Art. 20(10)). The application is made to the Ministry of Industry and Technology. Whether the investment is to be made by a capital increase or by acquiring shares, and with which documents it is to be proven, depend on the Ministry’s implementing rules (Art. 20(9)); the Ministry’s current practice should be confirmed before the company structure is set up. On setting up a company, see our guide Company Formation in Turkey for Foreigners.

Employment. Article 20(2)(c) of the Regulation covers a foreigner whom the Ministry of Labour and Social Security has determined to have created employment for at least 50 people. According to the Ministry’s General Directorate of International Labour Force, a total of at least 50 Turkish citizens must be employed full time in one or more companies that the foreigner owns or is a partner in; the count is based on a current workplace employee list taken from the Social Security Institution (SGK) system, and continuity over the last six months is taken into account. The Ministry assesses whether the foreigner’s capital share and shareholding ratio are sufficient. The application must include a petition with a wet-ink signature, a notarized signature declaration, the Employment Information Form, the passport, trade registry records showing the partnership and capital shares together with a current trade registry certificate (ticaret sicil tasdiknamesi), the SGK employee list, letters showing the status of tax and SGK premium debts, and a declaration of whether any administrative fine was imposed in the last six months. Complete applications are concluded within seven business days; a thirty-day period is given to complete missing documents.

Real estate, deposit, bonds or funds: let us set up your file correctly from the start

Send us a summary of your file via WhatsApp if it concerns whether a property qualifies, the valuation report, the foreign exchange purchase certificate, a promise-to-sell contract, blocking a deposit or government bonds, GYF/GSYF fund units, or the company and employment structure. We can correspond in English. Hukukçular Evi Ankara: +90 554 648 37 15

📞 +90 554 648 37 15💬 WhatsApp

Comparison: which route for which investor?

The legal outcome of the seven routes is the same; the choice should be made according to which risk the investor is willing to carry for three years and how the investor will get the money back at the end of those three years. For an investor who plans to live in Turkey or earn rental income, the real estate route is the option with the lowest threshold; however, it is also the route that requires the most scrutiny of the property’s type, history and valuation, and the property cannot be sold for three years. For an investor who does not want a physical asset and accepts a Turkish lira interest return, the deposit and government debt routes offer a simpler structure; in these two routes the exchange rate risk lies with the investor for three years. The fund route suits those who want indirect exposure to real estate or venture capital assets; its advantages are that a fall in value caused by exchange rate movements or by the fund’s distributions, redemptions or liquidation does not breach the condition, and that the withholding rate on GYF and GSYF units held for more than two years is 0%, but the return depends on the fund’s performance. For an investor who will set up production or a business in Turkey, the fixed capital investment is the natural choice, and for an investor who already owns a large business, the employment route.

The seven routes from the investor’s point of view

RouteWho is it for?Main point to watch
Real estate (USD 400,000)Investors who want to live in Turkey, acquire a home or workplace, or earn rental incomeType and history of the property, valuation report, foreign exchange purchase certificate, three-year no-sale annotation
Bank deposit (USD 500,000)Investors who do not want a physical asset and prefer a fixed interest returnThree years in a Turkish lira deposit; exchange rate risk and withholding on interest
Government debt (USD 500,000)Investors who want interest or lease income on an instrument carrying sovereign riskTurkish lira instruments only; same bank; instruments with less than three years to maturity should, as a rule, not be used
GYF / GSYF (USD 500,000)Investors who want to invest in real estate or venture capital through a fundFund risk; MKK blocking; REIT (GYO) shares excluded
Private pension (USD 500,000)Investors planning long-term savingsFunds designated by SEDDK; three years in the system
Fixed capital (USD 500,000)Investors who will set up production, a plant or a business in TurkeyThe Ministry must determine the investment to be a fixed capital investment; the structure should be confirmed in advance
Employment (50 people)Investors who own or are partners in a large business in TurkeyAt least 50 Turkish citizens employed full time; continuity over the last six months

Application process and family

According to NVİ, the process consists of three main steps: meeting one of the investment conditions in Article 20 of the Regulation and obtaining a certificate of conformity from the competent authority, obtaining a short-term residence permit under Law No. 6458, Art. 31(1)(j), and filing the citizenship application. Under NVİ’s procedures and principles for investors, the application for the certificate of conformity may be made in person or through an agent appointed by a special power of attorney for this purpose; the certificate is sent to the applicant, to the General Directorate of Population and Citizenship Affairs and to the Presidency of Migration Management. The residence permit application is made to the Provincial Directorate of Migration Management or to the Special Joint Offices in Istanbul and Ankara; residence permits under Article 31(1)(j) may be granted for periods of up to five years at a time (Law No. 6458, Art. 31(5)). The citizenship file is prepared at the Special Joint Offices in Istanbul and Ankara, and in other provinces at the Provincial Directorate of Population and Citizenship Affairs. By contrast, NVİ’s frequently asked questions page states that foreigners must apply in person to obtain the certificate of conformity, apply for the short-term residence permit, collect the residence permit card and file the citizenship application; the TKGM guide also provides that the undertaking at the land registry can be given through an agent only if the power of attorney expressly authorizes it. Because of this difference, the steps for which an agent will be used should be confirmed in advance with the relevant authority.

According to the Ministry of Interior’s statement of August 2026, after the certificate of conformity is issued, the General Directorate of Security and the National Intelligence Organization carry out a security investigation and an archive search. The decision is made by the President and takes effect from the date of the decision (Citizenship Law, Art. 20(1)). For the documents required for the application, see our article (in Turkish) Vatandaşlık Başvurusu İçin Gerekli Belgeler (documents required for a citizenship application), for the security investigation Vatandaşlık Başvurusunda Güvenlik Soruşturması (the security investigation in a citizenship application), and for the steps after the decision Vatandaşlık Kararı Çıktıktan Sonra Ne Olur? (what happens after the citizenship decision).

The citizenship by investment process

StepWhere?Legal basis
1. Investment and certificate of conformityDepending on the route: TKGM, BDDK, the Ministry of Treasury and Finance, SPK, SEDDK, the Ministry of Industry and Technology or the Ministry of Labour and Social SecurityRegulation, Arts. 20(2) and 20(9)
2. Short-term residence permitProvincial Directorate of Migration Management or the Special Joint Offices in Istanbul and AnkaraLaw No. 6458, Arts. 31(1)(j) and 31(5)
3. Citizenship applicationSpecial Joint Offices in Istanbul and Ankara; in other provinces, the Provincial Directorate of Population and Citizenship AffairsCitizenship Law, Art. 12(1)(b); Regulation, Art. 20(3)
4. Service feeTRY 135.45 per person in the file for 2026Citizenship Law, Art. 45; Regulation, Art. 20(3)(f)
5. Security investigation and archive searchGeneral Directorate of Security and National Intelligence OrganizationCitizenship Law, Art. 12(1)
6. DecisionThe President; takes effect from the date of the decisionCitizenship Law, Arts. 12(1) and 20(1)

Family. Article 12(1)(b) of the Citizenship Law also covers the investor’s foreign spouse and the investor’s own and the spouse’s minor or dependent foreign children. The service fee is paid separately for each person in the file. As regards children, Article 20 of the Law provides that a child under the custody of the parent who acquires citizenship acquires citizenship with the consent of the other parent who does not acquire it, and that if consent is not given, the matter is handled according to the decision of a judge in the country of the parent’s habitual residence. It should also be remembered that, in the real estate route, acquisitions in the name of a spouse or child are not counted towards the required value. For details, see our articles (in Turkish) Çocukların Türk Vatandaşlığı (Turkish citizenship of children) and Aile İkamet İzni (family residence permits).

Previous citizenship, tax and military service. Article 12 of the Citizenship Law contains no requirement to renounce a previous citizenship; however, the law of the investor’s own country may not allow dual citizenship. For income tax, full tax liability depends, as a rule, not on citizenship but on being settled in Turkey (Income Tax Law No. 193, Arts. 3 and 4); for the tax position of an investor who continues to live abroad, see our article (in Turkish) Dar Mükellefiyet (limited tax liability). If there are sons in the family, the military service position of those who acquire citizenship later should be assessed separately; this is covered in our article (in Turkish) Sonradan Türk Vatandaşı Olanların Askerliği (military service for those who become Turkish citizens later).

Cancellation, refusal and 2026 developments

Refusal. Even if all the investment conditions are met, the decision is discretionary: Article 12(1) of the Citizenship Law provides that citizenship may be granted provided there is no obstacle in terms of national security and public order, and the applications of those who pose such an obstacle are refused by the Ministry (Art. 12(2)). An action for annulment of a refusal can be brought before the administrative courts. On these issues, see our articles (in Turkish) Yatırım Yoluyla Vatandaşlık Başvurusu Millî Güvenlik Gerekçesiyle Reddedildi (citizenship by investment refused on national security grounds), Vatandaşlık Reddine İptal Dava Dilekçesi Örneği (sample petition against a refusal) and Vatandaşlık Başvurum Yıllardır Sonuçlanmadı (when a citizenship application has been pending for years).

Cancellation and withdrawal. Under Article 31(1) of the Citizenship Law, a decision granting Turkish citizenship is cancelled by the authority that made it if it was obtained through the person’s false statements or concealment of material facts on which the acquisition was based. Article 40 of the Law provides that decisions on the acquisition of Turkish citizenship are withdrawn if it is later found that they were made without the legal conditions being met or more than once. The Law itself does not list the later loss of the investment conditions as a separate ground for cancellation; that link is made by NVİ’s implementing rules. Under NVİ’s procedures and principles for investors, the foreigner must continue to meet the conditions for the period specified in the Regulation; if the conditions are lost, the citizenship decision is cancelled under Article 31 of the Law, and the authority that finds that the conditions have been lost notifies NVİ and the Presidency of Migration Management (Art. 8). Selling the property before the annotation period ends, breaking a deposit or government bond holding early, or disposing of fund units before three years have passed therefore directly puts citizenship at risk.

Developments in 2026. In its statement of 4 August 2026, the Ministry of Interior announced that, in reviews of fake and irregular valuation reports, the certificates of conformity of 1,150 investors found to have carried out sham or irregular transactions had been cancelled and the citizenship decisions of 5,391 people, including family members, had been cancelled; and that the citizenship decisions of 743 people, comprising 263 investors found objectionable by the General Directorate of Security and the National Intelligence Organization and their family members, had been withdrawn on the ground that the legal conditions had not been met. The Ministry stated that these actions concerning a total of 6,134 people were taken under Articles 31 and 40 of Law No. 5901. In September 2026, TKGM then allowed valuation reports for citizenship purposes to be prepared by any valuation firm licensed by the Capital Markets Board. The message of these two developments for investors is clear: the valuation report, the foreign exchange purchase certificate, the bank receipt and the title deed price must be consistent with each other, and trying to reach the threshold with a price above market value can lead to the cancellation of citizenship even years later. On the loss and cancellation of citizenship, see our article (in Turkish) Türk Vatandaşlığının Kaybı (loss of Turkish citizenship), and on the MASAK (Turkey’s Financial Crimes Investigation Board) aspect of foreigners’ bank and real estate transactions, our article (in Turkish) Yabancı Uyrukluların Banka Hesabı ve Gayrimenkul İşlemlerinde MASAK (MASAK in foreigners’ bank and real estate transactions).

Main risks and safeguards

RiskConsequenceSafeguard
Property shown above its market valueCancellation of the certificate of conformity; cancellation or withdrawal of the citizenship decision (Citizenship Law, Arts. 31 and 40)Independent and consistent valuation; payment of the price through a bank
Disposing of the investment before the end of the periodLoss of the conditions and cancellation (NVİ Procedures and Principles, Art. 8)Tracking the three-year deadline in a calendar; legal assessment in advance if an early exit is needed
Unsuitable property (agricultural field, vacant plot, a share, in the spouse’s name)No certificate of conformity can be obtainedExamining the land register record and history before buying
National security or public order obstacleRefusal of the application (Citizenship Law, Art. 12(2))Documenting the source of funds and past records before applying
Turkish lira exchange rate riskIn the deposit, bond and private pension routes, a lower foreign currency equivalent after three yearsCalculating return and exchange rate scenarios before investing

Common mistakes

  • Buying a property without checking whether it has already been used for citizenship, whether it carries a statutory mortgage and whether it was transferred to a Turkish citizen by a foreigner within the last three years.
  • Buying a share in a property, or buying in the name of a spouse or child.
  • Planning a citizenship application with an agricultural field or a vacant plot bought after 12 December 2023.
  • Paying the price in cash or from third parties’ accounts, or not having a foreign exchange purchase certificate issued.
  • Relying on a price above market value in the valuation report.
  • Mistaking the deposit route for a foreign currency account and not taking into account that the money will be held in Turkish lira for three years.
  • In the government debt route, choosing an instrument with less than three years to maturity, or selling the foreign currency at one bank and making the investment at another.
  • Assuming that REIT (GYO) shares traded on the stock exchange fall within the fund route.
  • Breaking the investment before three years have passed.
  • Not planning the other parent’s consent for the children’s citizenship in advance.
  • Assuming that citizenship automatically creates full tax liability in Turkey, or that it has no tax consequences at all.

Frequently asked questions

What is the minimum investment for Turkish citizenship by investment?

At least USD 400,000 in the real estate route; at least USD 500,000 or the equivalent in foreign currency in the fixed capital, bank deposit, government debt, GYF/GSYF fund and private pension routes. In the employment route, the requirement is not an amount but employment of at least 50 people (Regulation, Art. 20(2)).

Did the investment amounts change in 2026?

No. The latest amendment to Article 20 of the Regulation is the restriction on the type of real estate made by Presidential Decision No. 7938, published in the Official Gazette of 12 December 2023. The real estate threshold has been USD 400,000 since 13 June 2022.

Which properties qualify for citizenship?

Independent units subject to condominium ownership or construction servitude (kat irtifakı) and plots with a building that has an occupancy permit qualify; agricultural fields and vacant plots do not. The property must not have been used for citizenship before, and must not be bought as a share or in the name of a spouse or child.

Can the USD 400,000 be reached with more than one property?

Yes. According to the TKGM guide, there is no limit on the number of properties acquired by sale. On the promise-to-sell route, several properties may also be promised under a single contract; however, applications based on more than one promise-to-sell contract are not considered. Each property must separately meet the type and history conditions.

Can the money be kept in US dollars in the deposit route?

No. Since 6 January 2022, the foreign currency is first sold to a bank, and by the bank to the Central Bank, and the Turkish lira obtained is held in a Turkish lira deposit for three years (Regulation, Art. 20(10)). The exchange rate risk lies with the investor.

Can Eurobonds be used in the government bond route?

No. Under the Ministry of Treasury and Finance’s 2026 procedures and principles, only Turkish lira domestic government debt securities issued by the Ministry and Turkish lira lease certificates issued domestically by Hazine Müsteşarlığı Varlık Kiralama AŞ qualify (Art. 3(1)(b)). The bank where the foreign currency is sold and the bank where the investment is made must be the same.

Can citizenship be obtained by buying REIT (GYO) shares?

No. Article 20(2)(e) of the Regulation lists only units in real estate investment funds and venture capital investment funds; shares in real estate investment trusts traded on Borsa Istanbul are outside this scope.

Is the right to citizenship lost if the fund’s value falls?

According to SPK, a fall in value below USD 500,000 due to exchange rate movements does not affect the application or the acquisition; nor is a fall caused by the fund’s own transactions outside the investor’s control, such as cash dividend distributions, redemption of units or liquidation, treated as a loss of the condition. For government debt securities, too, a drop in the market price does not breach the condition.

Can I switch from one investment route to another?

Article 20(8) of the Regulation provides that switching between investment types is possible in order to complete the required period. The procedure for switching is set by the authorities’ implementing rules; for example, within the government debt route, one government debt security cannot be exchanged for another except where the Ministry redeems them early. Confirmation should be obtained from the relevant authorities before switching.

Can my spouse and children also become citizens?

Yes. Article 12(1)(b) of the Citizenship Law also covers the investor’s foreign spouse and the investor’s own and the spouse’s minor or dependent foreign children. For children under the custody of the parent who acquires citizenship, the consent of the other parent who does not acquire it is required; if consent is not given, the matter is handled according to the decision of a judge in the country of the parent’s habitual residence (Citizenship Law, Art. 20(2)).

What happens if I sell the investment before three years?

Under NVİ’s procedures and principles for investors, the foreigner must continue to meet the conditions for the period specified in the Regulation; if the conditions are lost, the citizenship decision is cancelled under Article 31 of the Citizenship Law. Selling the property before the annotation period ends, or disposing of the deposit, bonds or fund units before three years have passed, creates this risk.

Where is the citizenship application filed?

After the certificate of conformity and the short-term residence permit, the citizenship file is prepared at the Special Joint Offices in Istanbul and Ankara, and in other provinces at the Provincial Directorate of Population and Citizenship Affairs. NVİ’s frequently asked questions page states that applications must be made in person, while NVİ’s procedures and principles allow an agent with a special power of attorney for the certificate of conformity application; the steps for which an agent will be used should be confirmed in advance.

How much is the application service fee?

According to NVİ’s 2026 tariff, the service fee for acquiring Turkish citizenship exceptionally is TRY 135.45 per person in the file, paid to the cash offices of the Ministry of Treasury and Finance.

Who prepares the valuation report?

TKGM Circular No. 2024/2 was updated on 28 September 2026, and by a Ministerial Approval dated 18 September 2026 it was decided that reports used in determinations for citizenship purposes may be prepared by any valuation firm licensed by the Capital Markets Board. From 4 March 2024 until this update, the reports were prepared by GEDAŞ. Reports are obtained through Web Tapu.

Will I pay tax in Turkey once I become a Turkish citizen?

For income tax, full tax liability depends, as a rule, not on citizenship but on being settled in Turkey (Income Tax Law, Arts. 3 and 4). An investor who continues to live abroad is, as a rule, taxed on income earned in Turkey; the tax consequences in the investor’s own country should be assessed separately.

Do I have to give up my previous citizenship?

Article 12 of the Citizenship Law contains no requirement to renounce a previous citizenship. However, the law of the investor’s own country may not allow dual citizenship; this should be checked under that country’s legislation.

How long does the process take?

There is no official overall time limit; the duration depends on obtaining the certificate of conformity, the residence permit procedures, and the security investigation and archive search. Some steps have institutional deadlines: in the employment route, complete applications are concluded within seven business days, and in the fund route SPK issues the certificate of conformity within two business days after MKK’s confirmation.

What can I do if my application is refused?

An action for annulment of the refusal can be brought before the administrative courts. Where the refusal is based on national security or public order, access to the contents of the file and the litigation strategy should be planned separately, and the investment should also be protected during this process.

Related guides

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Send us a summary of your file via WhatsApp if it concerns choosing the investment route, the certificate of conformity, the residence permit, applications for family members, a refusal, the risk of cancellation or your exit plan after three years. We can correspond in English. Hukukçular Evi Ankara: +90 554 648 37 15

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Important note: This article is for general information only; it is not investment or tax advice and does not constitute a legal opinion on any specific application. It is a translation of the Turkish version; in case of any discrepancy, the Turkish version prevails. Legislation relied on: Turkish Citizenship Law No. 5901, Arts. 12, 20, 31, 40 and 45; Regulation on the Implementation of the Turkish Citizenship Law, Art. 20 (as amended by Presidential Decisions No. 106, 418, 5072, 5554 and 7938); Law No. 6458 on Foreigners and International Protection, Art. 31; NVİ Procedures and Principles on the Exceptional Acquisition of Turkish Citizenship by Foreign Investors; TKGM Guide on the Regulation (01.02.2024), instruction of 13.12.2023 and Circulars No. 2022/1 and 2024/2; Ministry of Treasury and Finance Procedures and Principles on Government Debt Securities (2026); SPK and MKK rules on citizenship blocking; Ministry of Labour and Social Security rules on exceptional citizenship; Fees Law No. 492; VAT Law No. 3065, Art. 13(i); Law No. 6183, Art. 48; Income Tax Law No. 193, Arts. 3 and 4 and Provisional Art. 67, and Presidential Decisions No. 11107 and No. 11444. The authorities’ implementing rules and tax rates may change; the current text and practice on the application date should be relied on.

Post by Av. Fatma Öztürk