
Turkish Citizenship by Investment Lawyer
Turkish Citizenship by Capital Investment and Employment: The USD 500,000 and 50-Job Routes
Turkish citizenship by capital investment means a fixed capital investment of at least USD 500,000, confirmed by the Ministry of Industry and Technology, whose procedure reportedly locks the shares for three years. Citizenship by creating jobs requires employing at least 50 Turkish citizens, confirmed by the Ministry of Labour and Social Security. As of November 2026, the President decides.
- Fixed capital amount: at least USD 500,000 or the equivalent in foreign currency, under art. 20(2)(a) of the implementing regulation; the figure was USD 2 million from January 2017 until September 2018.
- Employment threshold: at least 50 people under art. 20(2)(c); the Ministry counts Turkish-citizen employees and takes into account the continuity of full-time staff over the last six months.
- Certificate of conformity (uygunluk belgesi): issued by the Ministry of Industry and Technology for capital, and by the Ministry of Labour and Social Security for employment.
- Holding condition: for capital, the Ministry's procedure, as reported, bars share transfers for at least three years after the certificate of conformity; art. 20 itself sets no holding period for either route.
- Evidence: a special-purpose report by a sworn financial advisor (YMM) for capital; trade registry and social security (SGK) records for employment.
- Legal basis: Law No. 5901 art. 12(1)(b), Regulation art. 20, and a residence permit under Law No. 6458 art. 31(1)(j).
- Family: the foreign spouse and minor or dependent children may apply with the investor.
- Timing: the investment itself sets the pace; after filing, a citizenship decision often takes several months, with no fixed legal deadline.
Who these routes suit, and who they do not
The two business routes suit people who are building, or already run, a real business in Türkiye:
- a manufacturer, hotel operator, logistics, energy or agricultural business putting land, buildings, machinery or equipment into a Turkish company;
- a foreign group that already owns or co-owns Turkish companies with a large workforce;
- an investor who wants the money to stay at work in an operating company rather than sit in a blocked deposit or a property.
They are usually the wrong choice if:
- you want a passive investment with a clear exit: the bank deposit, government bonds or real estate routes are simpler to evidence;
- your plan is only to buy an office, a warehouse or vehicles, which does not count as fixed capital;
- you intend to fund the investment with a loan, because the capital is expected to be paid in without borrowing;
- you want to buy into an existing company and count what it already owns, which the published summaries of the Ministry's procedure say does not count (see below).
The legal basis: Law No. 5901 and Regulation art. 20
Article 12(1) of the Turkish Citizenship Law No. 5901 lets certain foreigners acquire citizenship on the proposal of the Ministry of Interior and by Presidential decision, provided there is no obstacle on national security or public order grounds. Item (b) of article 12(1), added by the International Labour Force Law No. 6735 in 2016, covers foreigners holding a residence permit under art. 31(1)(j) of the Law on Foreigners and International Protection No. 6458, together with their foreign spouse and minor or dependent children. The wording is "may acquire": meeting the investment condition makes you eligible to apply, but the decision is the President's.
The routes and amounts are set by art. 20(2) of the Regulation on the Implementation of the Turkish Citizenship Law. Item (a) covers a fixed capital investment of at least USD 500,000 or the equivalent in foreign currency, determined by the Ministry of Industry and Technology (Sanayi ve Teknoloji Bakanlığı). Item (c) covers foreigners whom the Ministry of Labour and Social Security (Çalışma ve Sosyal Güvenlik Bakanlığı) determines to have created employment for at least 50 people. Both routes were introduced on 12 January 2017 (Council of Ministers Decision No. 2016/9601) at USD 2 million and 100 jobs; Presidential Decision No. 106 (Official Gazette of 19 September 2018) lowered them to the current figures. Presidential Decision No. 5072 (Official Gazette of 6 January 2022) rewrote item (a) without changing the amount and, as reported, removed its earlier reference to a Turkish lira equivalent. No later change has been found, but thresholds can change by Presidential decision.
Turkish citizenship by fixed capital investment: the rules
The Ministry of Industry and Technology, through its General Directorate of Incentive Implementation and Foreign Investment, applies its own implementation procedures and principles. The points below follow that procedure as published in practitioner summaries; where they conflict, this page says so, and the Ministry's position should be confirmed in writing before you invest.
What counts as fixed capital
Fixed capital means land, buildings, machinery and equipment used to produce goods or services. Spending on real property or vehicles counts when it is directly tied to that productive investment, but buying only real property, only vehicles, or both, does not qualify. Cash in the company, or total assets above USD 500,000, is not enough on its own.
Investing through a Turkish company
The investment is normally made through a Turkish company in which the investor is a shareholder, and what counts is the investor's share of it. Where an investor adds to an existing investment, the summaries describe the test as the increase in fixed investment multiplied by the investor's shareholding ratio, which must reach USD 500,000. The paid-in capital is expected to be proportionate to the investment and contributed without borrowing, and a capital increase that is turned into fixed assets has to be traceable in the company's records.
Buying shares in an existing company
Turkish practitioner summaries of the Ministry's procedure say that the investor may buy a non-listed company or join it as a partner, but only fixed capital investment made after that date counts; the company's earlier investments, and an existing investment taken over, do not. Some English-language guides describe a qualifying share purchase of at least USD 500,000 backed by a valuation report, which the Turkish summaries do not mention. Unless the Ministry confirms otherwise in writing, assume the price paid for shares does not count.
Timing and the look-back period
Fixed capital investments made before 12 January 2017 do not count. For later applications, only expenditure from the three years before the application is taken into account, so plan the spending and the filing together.
Currency
The rule in art. 20(10) that requires foreign currency to be sold to a bank in Türkiye and on to the Central Bank of the Republic of Türkiye (CBRT) lists the property, deposit, bond, fund and pension routes, not the fixed capital route. Since the January 2022 amendment, item (a) refers only to USD 500,000 or the equivalent in foreign currency, although older guides still quote a Turkish lira equivalent. Where the spending is in lira, confirm with the Ministry which exchange rate and date it will use before the money is spent.
Evidence, inspection and the three-year share lock
The investment is evidenced by an investment information form and a special-purpose report certified by a sworn financial advisor (yeminli mali müşavir, YMM), following the model annexed to the Ministry's procedure. According to the published summaries, the Ministry may inspect on site after the application and, without notice, after the certificate. According to the same summaries, once the certificate of conformity is issued, the investor may not transfer the shares to another person for at least three years; some summaries add that the capital should not be reduced, or the fixed assets counted sold, in that period. Confirm the scope with the Ministry and keep to the stricter reading.
Turkish citizenship by creating jobs: the employment route
The Ministry of Labour and Social Security handles it through its General Directorate of International Labour Force (Uluslararası İşgücü Genel Müdürlüğü, UİGM), under its procedures for foreigners who create employment for at least 50 people in workplaces they own or are a partner in. Older guides name the Ministry of Family, Labour and Social Services, which was split in 2021.
According to the Ministry's own page:
- the employees must be Turkish citizens, and the company or companies concerned must together employ at least 50 of them;
- the Ministry takes into account the continuity of full-time Turkish-citizen employees over the last six months;
- the Ministry assesses whether the foreigner's capital share and shareholding ratio in the company or companies is sufficient;
- the application is made in writing, with trade registry gazette records showing the shareholding and capital of the companies, a current trade registry certificate, and records from the SGK and tax systems;
- a complete application is decided within seven working days; missing documents must be supplied within 30 days or the application is refused.
Article 20(2)(c) states no holding period. The Ministry's page sets no minimum shareholding ratio, so a minority stake in a large employer is assessed case by case, and it does not say whether the workforce must be kept after the certificate. Ask before you file and keep the payroll stable in the meantime. Part-time staff, foreign employees and workers registered under a subcontractor should not be relied on to reach the 50.
The residence permit and the citizenship application
The certificate of conformity goes to the Presidency of Migration Management (Göç İdaresi Başkanlığı) and to the General Directorate of Civil Registration and Citizenship (Nüfus ve Vatandaşlık İşleri Genel Müdürlüğü, NVI). The investor then needs a short-term residence permit under art. 31(1)(j) of Law No. 6458, the permit for foreigners who invest without working in Türkiye; Law No. 6458 allows a permit on this ground for up to five years at a time. In current practice the investor and spouse attend biometrics in person, and criminal record certificates are asked for both.
The citizenship application is filed with the VAT-4 form, in practice at a joint office of the migration and civil registry authorities, in person or through a lawyer holding a special power of attorney. After the Ministry of Interior's security review, the file goes to the President. If you will also work in the company yourself, for example as a managing shareholder, note that the art. 31(1)(j) permit is for investors who do not work in Türkiye; how a work permit under the International Labour Force Law fits with a citizenship file built on that permit is not settled in the published guidance, so settle it with the lawyer before the residence filing.
The process, step by step
- Structure review. Before any money is committed, the lawyer reviews the company structure, the shareholding ratio, the timing rules and the funding of the capital, and puts open points to the Ministry in writing.
- Tax number, bank account and company. The investor obtains a Turkish tax number and a bank account, and either sets up a company or increases the capital of an existing one. The lawyer prepares the corporate documents and filings, and can act under a power of attorney.
- Making the investment or building the workforce. The company buys land, buildings, machinery and equipment, or employs its staff and registers them with SGK. The lawyer reviews the contracts so that what is bought matches what the Ministry will count.
- Evidence file. For capital, a YMM prepares the special-purpose report; for employment, the company obtains the SGK employee list and the tax and premium debt letters. The lawyer checks that the report, the trade registry records, the bank records and the invoices tell the same story.
- Certificate of conformity. The written application goes to the competent Ministry, in person or through a proxy with a special power of attorney. The lawyer files it, answers the Ministry's questions and prepares the company for any on-site inspection.
- Residence permit. The family applies for the art. 31(1)(j) permit and attends biometrics, with the file prepared by the lawyer.
- Citizenship application. The VAT-4 file is lodged with the family documents. The lawyer follows the security review and answers any request for further documents.
- Decision and passport. After the Presidential decision, NVI registers the family and ID cards and passports are issued. The lawyer diarises the three-year share restriction.
Documents
The Ministries publish and update their own lists, so treat this as a typical set:
- a written application to the competent Ministry and, for capital, the investment information form;
- for capital: the YMM special-purpose report, trade registry records showing the company's shareholding and capital, and the invoices, title deeds, asset records, bank records of the capital payments and shareholder resolutions behind the report;
- for employment: trade registry gazette records showing the shareholding and capital of the companies, a current trade registry certificate, a current SGK employee list, and letters from the Revenue Administration (Gelir İdaresi Başkanlığı) and SGK systems showing the tax and premium debt position;
- the investor's passport and birth certificate, and the marriage and children's birth certificates for family members;
- criminal record certificates for the investor and spouse, and biometric photographs;
- a special power of attorney if the lawyer is to act for you;
- apostille or consular legalisation of foreign documents, with a Turkish translation by a sworn translator, certified by a notary.
How long it takes
- The investment itself is usually the longest part: building a plant or installing equipment can take months or years, and the employment route needs at least six months of stable payroll, since the Ministry looks at the last six months.
- The certificate: the Ministry of Labour states seven working days for a complete file; no published deadline was found for the Ministry of Industry and Technology, and an inspection can add time.
- Residence permit: from the same day to about two weeks.
- Citizenship decision: often several months; practitioners report commonly about three to six months after filing, sometimes longer, and there is no fixed legal deadline.
Costs, explained without prices
These routes have no fee schedule of their own. The cost items are:
- notary, trade registry and registration costs of setting up the company or increasing its capital, under official tariffs updated each year;
- the YMM's fee for the special-purpose report, and the company's ongoing accounting;
- for the employment route, salaries, SGK premiums and payroll taxes, which are the real cost of the route;
- sworn translation, notarisation and apostille of personal documents and the power of attorney;
- the residence permit and card fees, and the ID card and passport fees, set by law and updated each year.
No separate citizenship application fee for these routes has been confirmed.
Risks and common mistakes
- Counting the wrong spending. An office or vehicles with no productive investment behind them will not reach the threshold. Review the plan before buying.
- Borrowed capital. An investment financed by loans rather than paid-in capital can fail the test. Fund the company with your own capital and document each transfer.
- Assuming an acquired company's assets count. According to the published summaries, fixed investments made before you became a partner are not counted. Get the Ministry's view before you sign a share purchase.
- Inconsistent records. A YMM report that does not match the trade registry, the bank statements or the invoices leads to questions or refusal. The lawyer and the YMM reconcile them before filing.
- Payroll gaps. A dip below 50 full-time Turkish-citizen employees during the six months, or unpaid SGK premiums, weakens an employment file. Check the payroll monthly.
- Transferring shares too early. A transfer within three years breaches the Ministry's condition, and a capital reduction or a sale of the assets counted may also be caught. Diarise the date and check any group restructuring against it.
- Working without a work permit. Working in Türkiye without a required work permit is a separate breach, and the art. 31(1)(j) permit is for investors who do not work here. Settle the position before you take a role in the company.
- Overstated figures. A decision obtained by false declaration or concealment can be annulled under art. 31 of Law No. 5901. On 4 August 2026, the Ministry of Interior announced that the citizenship decisions of 6,134 people, 1,413 investors and their family members, had been annulled or withdrawn under articles 31 and 40 of Law No. 5901, most of them over sham or irregular transactions, chiefly inflated valuation reports.
The business routes compared with the passive routes
| Route | Minimum | Certificate issued by | Holding condition | Main evidence |
|---|---|---|---|---|
| Fixed capital investment | USD 500,000 or equivalent | Ministry of Industry and Technology | Shares not transferred for 3 years (Ministry procedure, as reported) | YMM special-purpose report |
| Employment | At least 50 people | Ministry of Labour and Social Security | None stated in art. 20; continuity over the last 6 months assessed | Trade registry and SGK records |
| Real estate | USD 400,000 or equivalent in foreign currency | Land registry (TKGM) in practice | 3-year no-sale annotation on the title | Title deed, valuation, DAB |
| Bank deposit | USD 500,000 or equivalent in foreign currency | BDDK | Held as a Turkish lira deposit for 3 years | Bank and CBRT conversion records |
Only the business routes keep the money at work in your own company, but they carry business risk and need more evidence. The Turkish citizenship by investment overview compares all seven routes.
How the lawyer works on a business-route file
Av. Kaan Karanfiloğlu, founder of Karanfiloglu Law Firm in Istanbul, handles these files personally. The work is legal: structuring the company and the investment, drafting corporate documents, reviewing contracts, raising open questions with the Ministry, and filing the certificate, residence and citizenship applications. The YMM report is prepared and signed by the client's sworn financial advisor under that advisor's own responsibility; the lawyer reviews it against the legal requirements. The lawyer works in Turkish, English and French, and Russian and Chinese speaking clients are served through native-speaking advisors at the office. The firm does not sell property or financial products, does not act as an agent and takes no commission from sellers, developers or agents. To discuss a file, use the contact page.
Frequently asked questions
What counts as a fixed capital investment for Turkish citizenship?
Land, buildings, machinery and equipment used to produce goods or services, worth at least USD 500,000 or the equivalent. Real property and vehicles count only when directly tied to that productive investment; buying only an office or vehicles does not qualify.
Can I buy shares in an existing Turkish company to get citizenship?
Buying shares can be the way into a company, but Turkish summaries of the Ministry of Industry and Technology's procedure count only the fixed capital investment made after you become a partner, not what the company already owns. Some English-language guides say otherwise, so get the Ministry's position on your structure in writing before you sign.
Can I sell my shares after getting Turkish citizenship by capital investment?
Not straight away. Under the Ministry's procedure, as reported, the shares may not be transferred to another person for at least three years after the certificate of conformity is issued. Some summaries also restrict capital reductions and sales of the fixed assets counted in that period, so check with the Ministry before any sale or restructuring.
Do the 50 employees have to be Turkish citizens?
Yes. The Ministry of Labour and Social Security looks for at least 50 Turkish-citizen employees in the company or companies you own or are a partner in. It takes into account the continuity of full-time Turkish-citizen employees over the last six months, using SGK records.
How long does the Ministry of Labour take to issue the certificate?
The Ministry's page states that a complete application is decided within seven working days. Missing documents must be supplied within 30 days or the application is refused. The citizenship decision that follows often takes several months, with no fixed legal deadline.
Can my spouse and children get citizenship through my business investment?
Yes. Your foreign spouse and your or your spouse's minor (as a rule, under 18) or dependent children may apply with you under art. 12(1)(b) of Law No. 5901 and the last paragraph of Regulation art. 20. In practice your spouse needs a residence permit in their own name and attends biometrics in person. Parents are not included.
Does a certificate of conformity mean I will get Turkish citizenship?
No. The certificate confirms that the investment condition is met, which allows you to apply. The Ministry of Interior then runs a security review, and the President decides whether to grant citizenship.
Related pages
- Turkish citizenship by investment: all routes
- Citizenship by real estate investment
- Citizenship by bank deposit
- Citizenship by government bonds
- Citizenship by investment fund shares
- Citizenship by private pension (BES)
- Citizenship due diligence
- Company formation in Turkey for foreigners
- Work permits and company formation
- Foreign direct investment in Turkey
- Family members in a citizenship application
- Turkish citizenship by investment timeline
- Power of attorney in Turkey for foreigners
This page is general information as of November 2026 and not legal advice; thresholds and ministry procedures change, and the decision on citizenship rests with the President of the Republic of Türkiye.
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