Turkish Citizenship by Investment Fund Shares: Real Estate and Venture Capital Funds

Turkish citizenship by investment fund shares means buying at least USD 500,000, or the equivalent in foreign currency, of real estate investment fund (GYF) or venture capital investment fund (GSYF) units and holding them, blocked at MKK, for at least three years. SPK issues the certificate of conformity; the President decides. Rules as of November 2026.

• Minimum: USD 500,000 or the equivalent in foreign currency.
• Eligible units: participation units of a real estate investment fund (gayrimenkul yatırım fonu, GYF) or a venture capital investment fund (girişim sermayesi yatırım fonu, GSYF).
• Holding period: at least 3 years, with the units blocked in the "Citizenship Blocking Sub-account" at MKK, the Central Registry Agency (Merkezi Kayıt Kuruluşu).
• Currency: the foreign currency is sold to a bank in Türkiye and by the bank to the Central Bank (CBRT) before the units are bought.
• Certificate issued by: SPK, the Capital Markets Board (Sermaye Piyasası Kurulu).
• Legal basis: Law No. 5901, art. 12(1)(b); the Citizenship Regulation, art. 20(2)(e); SPK's procedure and MKK's blocking principles.
• Family: your foreign spouse and your minor or dependent children can be included in the same file.
• Typical duration: often several months from the investment to the decision; there is no fixed legal deadline.

What Turkish citizenship by investment fund shares means

A real estate investment fund (GYF) is a fund for qualified investors that invests mainly in real estate and assets based on real estate. A venture capital investment fund (GSYF) is a fund for qualified investors that invests mainly in venture capital investments, that is, unlisted companies at start-up or growth stage; at least 80% of its total value must be in such investments. Both are set up under SPK communiqués (III-52.3 for GYF and III-52.4 for GSYF) and run by SPK-licensed portfolio management companies.

The fund route was added in 2017, reportedly at USD 1.5 million. Presidential Decision No. 106 reduced it to USD 500,000 in September 2018, and since January 2022 the foreign currency must be converted at the CBRT before the units are bought.

Buying GYF units is not buying property. The fund owns the real estate; you own units in the fund. The property route's rules (the USD 400,000 amount, the title deed annotation, the valuation and the seller checks) do not apply here, and fund units cannot be used on the real estate route. Shares of a listed real estate investment company (gayrimenkul yatırım ortaklığı, GYO) are also different: the regulation names only GYF and GSYF units.

The investment is a condition, not a purchase. Article 12 of the Turkish Citizenship Law says qualifying foreigners "may" acquire citizenship, and the President decides after a security review.

Who the fund route suits, and who it does not

The fund route may suit an investor who:

• wants indirect exposure to Turkish real estate or private companies through a regulated, professionally managed fund;
• meets the qualified investor criteria that SPK sets for these funds;
• accepts that these fund units are not redeemed on demand and may be held beyond three years;
• can document the source of the funds to a Turkish bank's standard.

It is usually a poor fit for someone who:

• needs the capital back on a fixed date;
• wants a predictable return or the capital kept in US dollars;
• does not want to read and assess a fund's legal documents and risk profile;
• has not checked whether their home country allows dual nationality (see dual citizenship in Türkiye).

The legal rules for citizenship through fund units

Law No. 5901, article 12(1)(b)

Under article 12(1) of the Turkish Citizenship Law No. 5901 (English text on the NVI site), listed foreigners may acquire Turkish citizenship on the proposal of the Ministry of Interior and by Presidential decision, if there is no obstacle on national security or public order grounds. Item (b) covers holders of a residence permit under Law No. 6458, art. 31(1)(j), the permit for people who invest without working in Türkiye, and their foreign spouse and minor or dependent children. There is no language test and no minimum residence period.

The Citizenship Regulation, article 20(2)(e)

Article 20(2)(e) of the Regulation on the Implementation of the Turkish Citizenship Law (Official Gazette 06.04.2010, No. 27544) covers a foreigner who buys GYF or GSYF participation units worth at least USD 500,000, or the equivalent in foreign currency, on condition of holding them for at least three years, as determined by SPK.

Conversion at the Central Bank

Article 20(10) of the regulation, added by Presidential Decision No. 5072 in January 2022, requires the foreign currency to be sold before the transaction to a bank operating in Türkiye and by that bank to the CBRT. The mechanics are in the CBRT's Implementation Instruction, some provisions of which were amended on 1 October 2026 on operational points. The lira proceeds then buy the units. Lira already held in Türkiye is not accepted.

SPK's procedure and the MKK block

SPK's page on exceptional citizenship through investment and MKK's principles for citizenship and long-term residence applications set the procedure:

• when the units are transferred to your account, they are blocked, at your request, in the MKK Citizenship Blocking Sub-account (Vatandaşlık Blokaj Alt Hesabı);
• you apply to SPK in writing with the investment details, proof of the block at MKK and a passport copy;
• SPK writes to MKK within two working days of a complete file; MKK is reported to answer in about three working days and SPK to issue the certificate about two working days later;
• the block is voluntary: SPK states that it does not take away your right to dispose of the units, and that by lifting it you can sell or transfer them and so cancel the citizenship process;
• MKK runs weekly checks on the blocked units, which pick up a removal of the block, a sale or transfer, or an attachment, injunction or other encumbrance;
• SPK states that a fall in the units' value below USD 500,000 because of exchange rate movements does not affect the application or the citizenship.

The fund rules: funds for qualified investors only

Under the SPK communiqués, GYF and GSYF units are sold only to qualified investors (nitelikli yatırımcı), and the distributor must obtain information and documents showing that you meet the criteria. Since amendments published in the Official Gazette on 17 July 2024 (GYF) and 21 September 2024 (GSYF), an issue contract containing minimum terms must be signed with the investor before units are sold. SPK has tightened the qualified investor criteria twice: a principle decision of 18 December 2025 raised the lira thresholds for being treated as a professional client on request but made an exception for buyers of GYF and GSYF units, and a decision of 26 October 2026 raised the thresholds again and removed that exception. Buyers of these units must now meet the general criteria. Depending on your other assets and experience, the citizenship investment alone may not be enough to qualify, so check the current test with the distributor before the transfer.

How the funds work

Each fund has an internal regulation (içtüzük) and an issue document (ihraç belgesi). Together they set the investment strategy, the fund's term, how and when units are valued, the fees and the conditions for leaving the fund. The portfolio management company runs the fund within these documents and SPK's rules.

Unlike an ordinary mutual fund, these funds do not buy back units on any business day. Exit depends on the fund's documents: some funds price and redeem units at set intervals, others pay out only at the end of their term, and a sale of the units to another qualified investor may be possible. A fund's term may run well beyond your three-year holding period. Read the exit clauses before you buy.

Some funds raise money through commitments that investors pay in over time. For citizenship, the units must actually be bought and blocked to the full qualifying amount, so confirm with the manager that the fund's structure allows this.

The value of the units follows the fund's assets: property valuations and rents for a GYF, the fortunes of unlisted companies for a GSYF. Both can fall, and a venture capital investment can be lost entirely. No one can promise a return.

After three years, the citizenship block can in principle be lifted at your request. What you can then do with the units depends on the fund's documents. Any tax on fund income or gains depends on the fund type and the holding period, so take tax advice in Türkiye and in your country of tax residence.

Step by step: the fund route and the lawyer's work at each stage

1. Eligibility and planning. The lawyer checks for anything that could raise a national security or public order question, confirms who in the family qualifies and maps the source-of-funds documents.
2. Choosing the fund. You choose a GYF or GSYF offered by an SPK-licensed portfolio management company. The lawyer reviews the internal regulation, the issue document and the issue contract for the legal points: fund type, term, exit, fees, transfer limits and how the citizenship block fits. The investment merits are your decision and your financial adviser's.
3. Tax number and accounts. You need a Turkish tax number, a bank account and an investment account with the distributor. The lawyer can obtain the tax number under a power of attorney and prepares the know-your-customer, qualified investor and source-of-funds documents; the bank may ask you to attend in person.
4. Transfer, conversion and purchase. You send the foreign currency to the account. The bank sells it to the CBRT, and the lira buys the units. The lawyer keeps the bank's conversion record (commonly a foreign exchange purchase certificate, döviz alım belgesi or DAB) and the purchase confirmation for the file.
5. Blocking at MKK. The units are blocked in the Citizenship Blocking Sub-account at your request. The lawyer checks the blocking statement against the amount and your identity details.
6. The SPK certificate. You, or the lawyer under a special power of attorney, apply to SPK in writing. After MKK confirms the block, SPK issues the certificate of conformity (uygunluk belgesi) and sends it to the Presidency of Migration Management and to the General Directorate of Civil Registration and Citizenship (Nüfus ve Vatandaşlık İşleri Genel Müdürlüğü, NVI). You receive it by e-mail.
7. Residence permit. You and your spouse apply for the art. 31(1)(j) permit at the Provincial Directorate of Migration Management, in current practice with biometrics in person and criminal record certificates for both. The lawyer prepares and files the application (see the residence permit page).
8. Citizenship application. Form VAT-4 is filed, usually in the joint offices of Migration and NVI, in person or by a lawyer with a special power of attorney. Postal applications are not accepted.
9. Security review and decision. The Ministry of Interior runs an archive and security investigation and makes a proposal; the President decides. The lawyer tracks the file and answers requests for documents.
10. Registration, ID card and passport. NVI registers you and your family, and the lawyer arranges the ID card and passport appointments.
11. The three years and after. Keep the units blocked. At the end, the lawyer can request the release of the block and review the exit options under the fund's documents.

Documents for the fund route

Lists vary by distributor and office; the usual set is:

• passports for you and each family member, and your Turkish tax number;
• source-of-funds evidence (salary, sale of assets, dividends, inheritance or loan records);
• qualified investor documents and the signed issue contract;
• the bank's conversion record, the purchase confirmation and the MKK blocking statement;
• the written application to SPK, the SPK certificate of conformity and the art. 31(1)(j) residence permit;
• form VAT-4 and biometric photos;
• birth certificate or civil registry extract, marriage certificate and children's birth certificates;
• criminal record certificates for you and your spouse;
• a special power of attorney if a lawyer acts for you (see power of attorney in Türkiye).

Foreign documents need an apostille or consular legalisation and a notarised Turkish translation. See the apostille guide.

How long the fund route takes

No stage has a statutory deadline. Practitioner estimates:

• accounts, qualified investor checks, conversion and purchase: usually days to a few weeks;
• SPK certificate: SPK's own step is two working days, and with MKK's answer the certificate is reported to follow within about seven working days of a complete file;
• residence permit: from the same day to about two weeks; the card often follows in about ten days;
• citizenship decision after filing: commonly about three to six months, with ranges of three to twelve months reported, because the security review sets the pace;
• ID card and passport after the decision: about one to three weeks.

The citizenship timeline guide covers each stage in more detail.

Costs, explained without prices

The amounts are set by law, by yearly tariff or by the provider, so check them when you start:

• bank charges for the incoming transfer and the conversion;
• fund fees and expenses set in the fund's documents, such as the management fee and any performance fee;
• intermediary and custody charges of the distributor;
• tax on fund income or gains, depending on the fund type and holding period;
• translations, notarisation and apostille of foreign documents and the power of attorney;
• residence permit fee and residence card fee, which vary by nationality and duration;
• ID card and passport fees.

Published sources show no separate citizenship application fee for this route; confirm it when you file. The cost of Turkish citizenship by investment page compares cost items across routes.

Risks and common mistakes on the fund route

• Buying the wrong product. Only GYF and GSYF units count; ordinary mutual funds and listed GYO shares do not.
• Not qualifying as an investor. If you do not meet the qualified investor criteria, which SPK raised again in October 2026, the distributor cannot sell you the units.
• Skipping the MKK block. Without the block in the Citizenship Blocking Sub-account, SPK cannot confirm the condition.
• Selling or moving units within three years. MKK's weekly checks detect a release, sale, transfer or attachment.
• Ignoring the exit terms. A fund that redeems only at set dates or at the end of its term may not let you out when the three years end.
• Trusting return promises. Treat any promise of a fixed or certain return on a citizenship fund with caution, and read the issue document.
• Weak source-of-funds evidence. Banks and distributors run anti-money-laundering checks before accepting the transfer.
• Misstatements in the file. A decision obtained by false declaration or concealment of material facts can be annulled under art. 31 of Law No. 5901, and family members who acquired citizenship through the investor can be affected. On 4 August 2026 the Ministry of Interior announced that the citizenship decisions of 6,134 people had been annulled or withdrawn under arts. 31 and 40 of Law No. 5901, most of them over sham or irregular transactions.
• Relying on old figures. Thresholds are set by Presidential decision and can change. As of November 2026 no decision raising the USD 500,000 amount has been found.

Most of these are prevented by checks before the transfer: the product and its documents, the qualified investor test, the block and the source-of-funds file.

Fund units compared with the other USD 500,000 routes

All four routes require at least USD 500,000 or the equivalent in foreign currency. The real estate route needs USD 400,000; the Turkish citizenship by investment overview compares all seven routes.

How we work on a fund route file

Av. Kaan Karanfiloğlu, the founder and owner of the firm, handles the file himself. The work is legal: checking eligibility, reviewing the fund's legal documents and the issue contract, checking the MKK block, preparing the source-of-funds file, applying to SPK, and filing the residence permit and citizenship applications under a power of attorney. The firm does not sell fund units or other financial products and is independent of portfolio managers, distributors and developers. The lawyer works in Turkish, English and French; clients who speak Russian or Chinese are served through native-speaking advisors at the office. The citizenship decision is the President's, and no lawyer can promise it.

Frequently asked questions

Which investment funds qualify for Turkish citizenship?

Only participation units of a real estate investment fund (GYF) or a venture capital investment fund (GSYF), worth at least USD 500,000 or the equivalent in foreign currency, under art. 20(2)(e) of the Citizenship Regulation, as of November 2026. Ordinary mutual funds and listed real estate company (GYO) shares do not count. The units must be held for at least three years.

Who manages these funds, and who supervises them?

GYF and GSYF funds are run by portfolio management companies licensed by SPK, the Capital Markets Board, under SPK's communiqués. SPK also issues the citizenship certificate of conformity. MKK, the Central Registry Agency, holds the records of the units and the citizenship block.

Do I need to be a qualified investor to buy GYF or GSYF units?

Yes. Under the SPK communiqués, these units are sold only to qualified investors, and the distributor must collect documents showing that you meet the criteria. Since an SPK decision of 26 October 2026, buyers of these units must meet the general qualified investor criteria, without the earlier exception for these funds. Check the current test with the distributor before you transfer money.

What is the MKK citizenship blocking sub-account?

It is a sub-account at MKK, the Central Registry Agency, in which your fund units are blocked at your request for the citizenship application. MKK confirms the block to SPK and checks the units weekly for any release, sale, transfer or attachment. The block is what proves the three-year holding.

What happens if the value of my fund units falls below USD 500,000?

Under SPK's procedure and MKK's principles, a fall in the units' value below USD 500,000 because of exchange rate movements does not affect the application or the citizenship. The financial loss remains yours. Losses from the fund's own performance are an investment risk you should assess before buying.

Can I sell my fund units after three years?

After three years the citizenship block can be lifted at your request. Whether you can then sell or redeem the units depends on the fund's term and the exit rules in its internal regulation and issue document. These funds generally do not buy back units on demand.

Is a real estate investment fund the same as buying property for citizenship?

No. With a GYF you own fund units, not a property; the amount is USD 500,000 rather than USD 400,000, the certificate comes from SPK rather than the land registry, and there is no title deed annotation. The two routes have separate rules, and as a rule amounts under different routes are not added together.

Related pages

• Turkish citizenship by investment: all routes and the lawyer's work
• Turkish citizenship by real estate investment
• Turkish citizenship by bank deposit
• Turkish citizenship by pension fund (BES)
• Turkish citizenship by government bonds
• Turkish citizenship by capital investment and employment
• Turkish citizenship due diligence
• Turkish citizenship for family members
• Opening a bank account in Türkiye
• Tax residency in Türkiye for foreigners

This page is general information as of November 2026 and not legal advice; the rules, amounts and practice can change, so check your own case with a lawyer before you invest.

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