
Turkish Citizenship by Investment Lawyer
Turkish Citizenship by Pension Fund: the Private Pension System (BES) Route
Turkish citizenship by pension fund means paying at least USD 500,000, or the equivalent in foreign currency, into a dedicated private pension (BES) contract with a licensed Turkish pension company and staying in the system for three years. SEDDK issues the certificate of conformity, and the President decides on citizenship. These are the rules as of November 2026.
- Minimum: USD 500,000 or the equivalent in foreign currency, paid as a contribution to the private pension system.
- Condition: the money stays in funds within the scope SEDDK sets, and you commit to stay in the system for 3 years.
- Currency: the foreign currency is sold to a bank in Türkiye and by the bank to the Central Bank (CBRT); the pension account is credited in Turkish lira.
- Certificate issued by: SEDDK, the Insurance and Private Pension Regulation and Supervision Agency (Sigortacılık ve Özel Emeklilik Düzenleme ve Denetleme Kurumu).
- Legal basis: Law No. 5901, art. 12(1)(b); the Citizenship Regulation, art. 20(2)(f), added by Presidential Decision No. 5554 (Official Gazette 13.05.2022); SEDDK's rules, first set in 2022 and now in its BES Circular 2026/1.
- Family: your foreign spouse and your minor or dependent children can be included in the same file.
- State contribution: not paid on this contribution.
- Typical duration: often several months from the contribution to the citizenship decision; there is no fixed legal deadline.
What Turkish citizenship by pension fund means
The private pension system (Bireysel Emeklilik Sistemi, BES) is Türkiye's voluntary, funded pension scheme under Law No. 4632 on the Individual Pension Savings and Investment System. A participant signs a contract with a licensed pension company, pays contributions, and the money is invested in pension investment funds. The savings are recorded in the participant's own individual pension account.
Since 13 May 2022, a foreigner can use a BES contribution of at least USD 500,000 as the qualifying investment for exceptional Turkish citizenship. It is the newest of the seven investment routes. It shares the amount and the three-year period with the bank deposit, government bonds and investment fund shares routes, but the money sits in a pension account with its own rules on funds, fees and exit. The investment is a condition, not a purchase: meeting it does not by itself guarantee citizenship.
Who the private pension route suits, and who it does not
The pension route may suit an investor who:
- prefers a financial asset to property and does not want to run title, valuation and seller checks;
- accepts that the money is in Turkish lira and in market-priced funds for at least three years;
- has a clear, documented source for the funds that a Turkish bank will accept;
- wants the investment in an account in their own name with a regulated company.
It is usually a poor fit for someone who:
- may need the money back within three years;
- wants the capital kept in US dollars, or an asset they can live in or let;
- expects the state contribution that Turkish participants receive;
- comes from a country that does not allow dual nationality and has not checked the consequences (see dual citizenship in Türkiye).
The legal rules for citizenship through the private pension system
Law No. 5901, article 12(1)(b)
Article 12(1) of the Turkish Citizenship Law No. 5901 (English text on the NVI site) lets listed foreigners acquire Turkish 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), added by Law No. 6735 in 2016, covers foreigners who hold a residence permit under Law No. 6458, art. 31(1)(j), the short-term permit for people who invest without working in Türkiye. It also covers their foreign spouse and their own or their spouse's minor or dependent foreign children. There is no language test and no minimum period of residence on this route.
The Citizenship Regulation, article 20(2)(f)
The investment routes are set in article 20(2) of the Regulation on the Implementation of the Turkish Citizenship Law (Official Gazette 06.04.2010, No. 27544). Item (f) covers a foreigner who pays at least USD 500,000, or the equivalent in foreign currency, into the private pension system, keeps it in funds whose scope SEDDK determines, and undertakes to stay in the system for three years. Presidential Decision No. 5554 added item (f) with effect from 13 May 2022. SEDDK's own explanatory note on the BES route summarises the condition.
The foreign currency sale to the Central Bank
Article 20(10) of the regulation requires the foreign currency for the property, deposit, bond, fund and pension routes to be sold, before the transaction, to a bank operating in Türkiye and by that bank to the CBRT. The rule was introduced by Presidential Decision No. 5072 (January 2022) and has applied to the pension route since that route was added on 13 May 2022; lira already held in Türkiye is not accepted. The mechanics are in the CBRT's Implementation Instruction, some provisions of which were amended on 1 October 2026 (operational points such as transfer costs). For BES, the lira proceeds are credited to the pension company as your contribution. Once the currency sale is done, the transaction cannot be cancelled.
SEDDK's rules on the citizenship contract
SEDDK Circular 2022/21 of 8 August 2022, which amended the then general BES Circular 2016/39, and the procedures and principles SEDDK adopted the same month, set these conditions:
- a new contract in a citizenship pension plan (a plan with "vatandaşlık", citizenship, in its title); an existing BES account cannot be used;
- the qualifying amount must sit in one contract; it cannot be split across several contracts;
- funds with "foreign" (yabancı) or "external debt instruments" (dış borçlanma araçları) in their titles are excluded, including such funds offered through BEFAS, the platform through which pension funds of other companies can be chosen;
- for the first three years from the contract's effective date, no plan change, no merging of this account with other pension accounts and no transfer to another pension company;
- a later fall of the account's US dollar value below USD 500,000 because of exchange rate movements does not affect the application or the citizenship.
SEDDK has since replaced the 2016 circular with a new BES Circular 2026/1 (dated 28 January 2026, in force since 1 July 2026). Its Section K governs the citizenship plan and keeps citizenship plan contracts out of transfers to another company. Check the current conditions under Section K with the pension company before signing.
How the pension contract and the funds work
A BES contract is linked to a pension plan, which is the company's menu of funds, fees and terms approved under the BES rules. You choose how your contribution is spread across the plan's funds. Each fund is a pension investment fund with its own investment strategy, for example money market instruments, Turkish lira government debt, equities or participation (interest-free) assets. Your contribution buys units in those funds, and the value of your account is the number of units multiplied by their daily prices.
Under SEDDK's procedure, the pension company files the request for the certificate of conformity, with its documents, in the system of the Pension Monitoring Centre (Emeklilik Gözetim Merkezi, EGM), which holds the central BES records, within five working days of the contract's effective date. EGM checks the file, reportedly within five working days, and forwards eligible applications to SEDDK. EGM also monitors the three-year restrictions.
The citizenship contract has a narrower fund menu because of the SEDDK exclusions. Under the general BES rules, as EGM publishes them, the allocation between funds may be changed up to 12 times a year; the citizenship plan may set narrower terms, so ask the company to state them in writing. Because the SEDDK exclusion expressly reaches funds offered through BEFAS, eligible funds of other companies appear to remain available there, although the contract itself cannot move; confirm this for your plan.
The account is priced in lira and moves with the funds. A fall in dollar value caused by exchange rates does not cost you the citizenship, but it is a real loss. No one promises fund returns.
After the three years, the citizenship restrictions end. The general BES rules then apply. Under those rules, retirement within the system generally requires 10 years in the system and age 56. You may leave earlier, but returns on the account are then taxed by withholding at rates that depend on how long you stayed and whether you met the retirement conditions, and the company's own terms on exit apply. Take tax advice in Türkiye and in your country of tax residence before you plan an exit.
Step by step: the pension route and the lawyer's work at each stage
- 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.
- Tax number and bank account. You need a Turkish tax number and an account at a bank in Türkiye. The lawyer can obtain the tax number under a power of attorney and prepares the bank's know-your-customer file; the bank may ask you to attend in person.
- Choosing the pension company and the plan. Only SEDDK-licensed companies that offer the citizenship contract can be used. The lawyer reviews the contract, the eligible funds, the deductions and the three-year restrictions.
- Transfer and conversion. You send the foreign currency to your Turkish account; the bank sells it to the CBRT and the lira amount is credited to the new contract. The lawyer confirms the amounts and the sequence before this irreversible step, then keeps the bank's conversion record (commonly a foreign exchange purchase certificate, döviz alım belgesi or DAB) for the file.
- Application and the SEDDK certificate. The pension company, not you, files the request for the certificate in the EGM system within five working days of the contract's effective date. After EGM's check, SEDDK issues the certificate of conformity (uygunluk belgesi) and sends it to the Presidency of Migration Management and NVI; you receive it by e-mail.
- 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).
- Citizenship application. Form VAT-4 is filed, usually in the joint offices of Migration and the General Directorate of Civil Registration and Citizenship (Nüfus ve Vatandaşlık İşleri Genel Müdürlüğü, NVI), in person or by a lawyer with a special power of attorney. Postal applications are not accepted.
- 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.
- Registration, ID card and passport. NVI registers you and your family, and the lawyer arranges the ID card and passport appointments.
- The three years. Keep the contract in place. At the end, the lawyer can review the exit or continuation options against the contract and the tax position.
Documents for the pension route
Lists vary by office and company; 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);
- the citizenship BES contract, the plan documents, the bank's conversion record and the contribution receipt;
- the SEDDK 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. The apostille guide explains the process.
How long the BES route takes
No stage has a statutory deadline. Practitioner estimates:
- tax number, bank account, contract and conversion: usually days to a few weeks, mostly driven by the bank's checks;
- SEDDK certificate: commonly one to three weeks;
- 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 expenses, reflected in the fund prices; under the 2022 SEDDK rules citizenship plans charge no entry fee and no management expense deduction, but ask for the plan's fee schedule in writing;
- withholding tax on returns when you leave the system, at rates that depend on time in the system;
- 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 BES route
- Treating the conversion as reversible. Once the currency is sold to the CBRT, the transaction cannot be cancelled. Check every document before the transfer.
- Breaking a SEDDK rule. An existing account, a split across contracts, an excluded fund or a plan change or transfer within three years can each put the condition at risk.
- Expecting currency protection. The account is in lira and in market-priced funds. The value can fall in dollar terms.
- Expecting the state contribution. It is not paid, because it is reserved for Turkish citizens and persons with status under art. 28 of Law No. 5901 (Turkish citizens by birth who gave up citizenship with permission, and their descendants, known as Blue Card holders).
- Ignoring exit costs. Leaving before the retirement conditions means withholding tax on returns and the company's exit terms.
- Weak source-of-funds evidence. Banks 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, chiefly inflated valuation reports.
- 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 legal checks before the transfer: the contract and fund review, the source-of-funds file and the family and residence permit plan.
Pension route compared with the other USD 500,000 routes
| Route | Minimum | Held for | Certificate issued by | Where the money sits |
|---|---|---|---|---|
| Private pension (BES) | USD 500,000 or equivalent in foreign currency | 3 years in the system | SEDDK | Lira pension funds, value moves with the market |
| Bank deposit | USD 500,000 or equivalent in foreign currency | 3 years | BDDK (banking regulator) | Lira time deposit at a Turkish bank |
| Government debt instruments | USD 500,000 or equivalent in foreign currency | 3 years | Ministry of Treasury and Finance | Lira government bonds or lease certificates, blocked at the bank |
| Real estate or venture capital fund units | USD 500,000 or equivalent in foreign currency | At least 3 years | SPK (Capital Markets Board) | Fund units blocked at MKK |
| Real estate | USD 400,000 or equivalent in foreign currency | 3-year no-sale annotation | Land Registry (TKGM) in practice | Property in your name, which you may use or let |
The Turkish citizenship by investment overview compares all seven routes, including fixed capital investment and employment.
How we work on a pension route file
Av. Kaan Karanfiloğlu, the founder and owner of the firm, handles the file himself. The work is legal: checking eligibility, reviewing the pension contract and the fund choices against the SEDDK rules, preparing the source-of-funds file, coordinating with the bank and the pension company, and filing the residence permit and citizenship applications under a power of attorney. The firm does not sell pension, bond or fund products and is independent of banks, pension companies and portfolio managers. 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
What is the minimum pension contribution for Turkish citizenship?
The minimum is USD 500,000 or the equivalent in another foreign currency, under art. 20(2)(f) of the Citizenship Regulation, as of November 2026. The currency is sold to the Central Bank through a bank in Türkiye and credited to the pension account in lira. Lira already held in Türkiye is not accepted.
Which pension companies offer the citizenship pension plan?
Any pension company licensed in Türkiye and supervised by SEDDK may offer the dedicated citizenship contract, but not every company does. No official list of participating companies was found, so ask each company whether it offers the product and request its plan documents. The contract must be new and in your own name.
Will I receive the state contribution on my BES account?
No. The state contribution in the private pension system is limited to Turkish citizens and persons with status under art. 28 of Law No. 5901. The citizenship contribution therefore earns only the return of the funds you choose, after fund expenses.
Can I switch funds or move to another pension company during the three years?
For the first three years from the contract's effective date, you cannot change the plan, merge the account with other pension accounts or transfer the contract to another company. Any change of allocation must stay within the eligible funds, and funds with "foreign" or "external debt instruments" in their titles are excluded. The general BES rules allow up to 12 allocation changes a year; ask the company to confirm in writing what the plan allows.
What happens if the USD value of my pension account falls below USD 500,000?
Under SEDDK's rules, a later fall in the account's US dollar value caused by exchange rate movements does not affect the application or the citizenship. The condition is tested on the contribution made; ask the company to confirm how it treats a fall in fund prices. The loss in value is still yours to bear.
Can I withdraw my money after three years, and what deductions apply?
After three years, the citizenship restrictions end and the ordinary BES rules apply. Retirement within the system generally requires 10 years in the system and age 56, and leaving earlier means withholding tax on returns at rates that depend on time in the system, plus the company's own exit terms. Get tax advice before you plan an exit.
Can my spouse and children get citizenship through my pension investment?
Yes. Your foreign spouse and your own or your spouse's minor or dependent children can apply together with you on the same investment, under art. 12(1)(b) of Law No. 5901 and the last paragraph of art. 20 of the regulation. In practice your spouse needs a residence permit in their own name and attends biometrics in person. Parents are not included. See citizenship for family members.
Related pages
- Turkish citizenship by investment: all routes and the lawyer's work
- Turkish citizenship by bank deposit
- Turkish citizenship by government bonds
- Turkish citizenship by investment fund shares
- Turkish citizenship by real estate investment
- Turkish citizenship by capital investment and employment
- Turkish citizenship due diligence
- Turkish citizenship for family members
- Turkish citizenship by investment timeline
- 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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Other practice areas
- Turkish Citizenship by Investment Lawyer
- Turkish Citizenship by Property
- Turkish Citizenship by Bank Deposit
- Citizenship by Government Bonds
- Citizenship by Investment Fund Shares
- Citizenship by Capital or Employment
- Citizenship Due Diligence
- Real Estate Due Diligence
- Turkish Residence Permit Lawyer
- Work Permits and Company Formation
- Entry Ban and Deportation
- Foreign Divorce Recognition
