Cancellation and Withdrawal of Turkish Citizenship in 2026: New Valuations, Investment Shortfalls, Families, Children, Military Service and Construction Company Investigations

Last updated: 28 September 2026

For foreign nationals who acquired Turkish citizenship through real estate investment, 2026 has brought significant developments concerning the renewed examination of historical citizenship files, the cancellation of Certificates of Conformity, fresh scrutiny of earlier property valuation reports and the relationship between criminal investigations and citizenship law.

Following the investigations announced by the İstanbul Cumhuriyet Başsavcılığı in August and September 2026, several questions have acquired immediate importance for investors and their families: Can the authorities revisit a valuation report used years ago? Can a new expert valuation be obtained? Can an investment shortfall be made up today? What if the investor genuinely paid the required amount but the valuation report was defective? What happens to a spouse or child? Does military service protect citizenship? Which companies were publicly named, and which projects have actually been confirmed as part of the investigations?

This article examines those questions by considering Law No. 5901 on Turkish Citizenship, the Regulation on the Implementation of the Turkish Citizenship Law, guidance issued by the Tapu ve Kadastro Genel Müdürlüğü (TKGM), judgments of the Danıştay, guidance issued by the Millî Savunma Bakanlığı, academic literature and information made public up to 28 September 2026.

Our Earlier Publications — In Chronological Order

The present analysis develops the issues addressed in our earlier publications. The following links are arranged by publication date; English articles are identified expressly, while the related Turkish and Arabic versions are included where available.

1. 14 September 2026 — English: Military Service After Acquiring Turkish Citizenship: The 22-Year Rule, Exemption and Deferment.
2. 19 September 2026 — Turkish: Yatırım Yoluyla Kazanılan Türk Vatandaşlığının İptali ve Geri Alınması: Sahte Ekspertiz, Muvazaalı İşlemler, İyi Niyetli Yatırımcı ve Yargısal Koruma.
3. 19 September 2026 — English: Cancellation and Withdrawal of Turkish Citizenship Acquired by Investment: False Valuation Reports, Sham Transactions, Good-Faith Investors and Judicial Remedies.
4. 21 September 2026 — English, related family-law analysis: Divorce in Turkey for Foreigners: Foreign Spouses, Dual Citizens, Spouses Living Abroad and Consular Procedures.
5. 26 September 2026 — Turkish: 1.070 Kişiyi İlgilendiren Türk Vatandaşlığı İptali Süreci.
6. 26 September 2026 — English: 1,070 People Facing Turkish Citizenship Cancellation Proceedings in 2026: A Comprehensive Legal Guide for Real Estate Investors.
7. 26 September 2026 — Arabic: إلغاء الجنسية التركية لـ 1,070 شخصاً في 2026 | دليل قانوني للمستثمرين العقاريين.
8. 28 September 2026 — Turkish: Türk Vatandaşlığı İptali ve Geri Alınması 2026: En Çok Sorulan Sorular, Ceza Soruşturması, Dava ve Dosya İnceleme.
9. 28 September 2026 — English: Revocation and Withdrawal of Turkish Citizenship in 2026: Frequently Asked Questions, Criminal Investigations, Litigation and File Review.

These publications should be read together. The 19 September analysis explains the fundamental distinction between iptal and geri alma; the 26 September articles focus on the investigation concerning 1,070 persons; and the 28 September question-and-answer articles examine individual status checks, criminal investigations and access to files. The present article adds a detailed analysis of new valuations, investment shortfalls, family members, military service and the companies and portfolios discussed publicly.

1. What Is the Most Recent Development in 2026?

On 21 September 2026, a second-phase operation conducted in İstanbul and other provinces considerably expanded the publicly known investigation into Turkish citizenship acquired through real estate investment.

According to statements of the İstanbul Cumhuriyet Başsavcılığı reported by Anadolu Ajansı and other news organisations, land registry records, expert reports, MASAK analyses and additional documents were examined together. Investigators allege that, in some transactions, the foreign currency required for citizenship did not genuinely enter Türkiye; apparent payments were created using the financial resources of sellers or intermediary companies; and property valuation reports overstated actual values. [H1] [H2] [H3] [H4] [H5]

These remain allegations within criminal proceedings. Investigation measures concerning a person or company do not amount to a final criminal conviction. The presumption of innocence applies.

Second-phase information made public	Reported figure
Sales to foreign purchasers examined	734
Sales alleged to have been sham transactions	274
Total persons stated to have acquired citizenship	1,070
Principal investors	263
Family members	807
Persons who acquired citizenship at the date of the original decision	1,015
Children said to have acquired citizenship after that decision	55
Amount attributed to the transactions	USD 72,250,000 / more than TRY 3.5 billion as reported
Suspects subject to apprehension measures	88
Suspects remanded in custody by 25 September	33
Suspects subject to a house-arrest measure	20
Suspects subject to other judicial-control measures	21
Properties reported to have been seized	2,011
Joint-stock companies reported to have been placed under trusteeship	30

Sources: Public statements reported by Anadolu Ajansı, TRT Haber and other news organisations. [H1]–[H8]

2. How Many Citizenship Decisions Have Been Cancelled or Withdrawn So Far?

Information attributed to the İçişleri Bakanlığı and reported on 21 September 2026 concerned a considerably broader set of investment-related citizenship files:

Reported measure	Relevant investors or files	Persons including family members
Cancellation of citizenship acquisition decisions	Various investment files	5,391
Withdrawal of citizenship decisions	263 investors and their families	743
Reported total	1,413 investors	6,134
Investors whose Certificates of Conformity were cancelled after 11 February 2026	458 investors	1,393

These figures have been reported as information supplied by the Ministry. [H1] [H3] [H6] A crucial terminological qualification is necessary: public statements may use the word iptal broadly to describe the termination of citizenship. Under Law No. 5901, however, iptal and geri alma are distinct legal mechanisms with different requirements and effects.

3. What Is the Difference Between Cancellation (İptal) and Withdrawal (Geri Alma)?

This is not merely an academic distinction. It affects the temporal operation of the decision, the status of spouses and children, acts performed during the period of citizenship and the appropriate litigation strategy.

Issue	Cancellation — iptal	Withdrawal — geri alma
Statutory basis	Articles 31–32 of Law No. 5901	Article 40 of Law No. 5901
Central ground	A false statement by the person concerned or concealment of a material matter forming the basis of citizenship	A citizenship decision issued without the legal requirements having been satisfied or issued repetitively; the Regulation also addresses a decision issued by mistake
Effect in time	Effective from the date of the cancellation decision	Under Article 66 of the Regulation, the withdrawn decision is ineffective from the date of the original decision
Spouse and children	Article 32 addresses those who acquired citizenship dependent on the person concerned, subject to the regulatory exceptions	The consequences for each dependent decision require separate examination in light of the retrospective effect
Acts performed while a citizen	Protected from the effect of cancellation under Article 58 of the Regulation	May raise more complex questions because withdrawal operates retrospectively

Article 31 concerns acquisition resulting from the false statement or material concealment of the person concerned. Article 40 asks whether the legal conditions objectively existed when the decision was issued. The two mechanisms should not be obscured by using the single English word “revocation” without identifying the Turkish-law basis. [M1] [M2] [M3] [M4]

For a fuller examination of this distinction, see our 19 September English legal analysis and our 28 September English questions and answers.

4. Can Citizenship Be Withdrawn Even If the Investor Committed No Fraud?

This question is particularly important where an investor says that the purchase price was genuinely paid but the valuation company or seller may have made an error or acted improperly.

For cancellation under Article 31, the statutory wording concerns a false statement or concealment attributable to the person concerned. Misconduct by a third party is not automatically the investor’s own false statement or concealment.

Withdrawal under Article 40 raises a different question: were the legal conditions for citizenship genuinely present when the decision was issued? Accordingly, even without personal fraud by the investor, the administration may raise an Article 40 issue if it alleges that an objective investment condition never existed.

That power is not unlimited. In its judgment of 26 June 2025, E.2022/7637, K.2025/3313, the Danıştay 10th Chamber emphasised the importance of whether the obstructing factual or legal circumstance existed at or before the date of the citizenship decision. A new circumstance arising only after acquisition, with no demonstrated connection to that earlier period, cannot by itself prove that the original legal conditions were absent. The judgment did not itself concern the 2026 valuation investigations, but its temporal analysis is important when old investment files are reviewed today. [Y1]

5. Can the Authorities Request a New Property Valuation Years Later?

Yes. In the course of renewed investigation, a new valuation or expert examination may be obtained. The legally decisive question, however, is what the new report actually establishes.

Article 38 of Law No. 5901 concerns the provision of information and documents for citizenship investigations. Article 57 of the Regulation addresses investigation where a false statement or concealment connected with acquisition is learned of. Current public statements likewise indicate that investigators have considered land registry records, expert reports, MASAK analyses and banking information together. [M2] [M4] [H1]

Two questions must not be confused:

First: Can an authority obtain a new expert opinion in 2026? Yes.

Second: Does a lower present-day value automatically prove that a property failed to satisfy the investment threshold in 2019, 2020 or 2021? No.

The relevant inquiry is the property’s genuine value at the legally relevant historical transaction date and whether the conditions then in force were satisfied. A retrospective report must therefore engage with historical evidence rather than simply substitute today’s market price for an earlier one. [Y1]

6. If the Original Valuation and New Expert Report Conflict, Which One Prevails?

There is no general rule that a newer report automatically invalidates an earlier report. Its valuation date, methodology, comparable sales and underlying assumptions must be examined alongside the original report.

Other relevant evidence includes the official deed price; sale agreement; bank and SWIFT records; foreign-exchange purchase document; the amount actually received by the seller; any direct or indirect return of funds; independent sales in the same project during the relevant period; tax and land registry records; the Certificate of Conformity; and the investor’s own knowledge and conduct.

The Danıştay 10th Chamber’s judgment of 12 December 2024, E.2020/5861, K.2024/6304, concerned issues surrounding the valuation report and the price stated in an official real estate transaction used for citizenship purposes. It did not decide the 2026 investigations, but illustrates why the valuation and official sale price must be analysed as distinct elements. [Y2]

7. What If the Investor Paid the Required Amount but the Valuation Report Was Problematic?

That situation is not identical to a case in which the qualifying amount was never genuinely paid.

For example, assume that the applicable threshold was USD 250,000, that the investor paid USD 300,000 from personal funds through the banking system, that the seller received the payment, and that the property genuinely had a historical value of USD 300,000. If a procedural or evidential problem is later identified in the valuation report, it remains necessary to determine whether the substantive investment condition was in fact met.

By contrast, if a property genuinely worth USD 100,000 was presented on paper as worth USD 250,000 or USD 400,000, or if an apparent payment was financed by the seller or intermediary and subsequently returned, the legal analysis may be substantially different. These are among the kinds of issues raised in the 2026 investigation statements. [H1] [H2] [H8]

8. What Property Investment Threshold Applied at Different Dates?

It would be incorrect to apply today’s USD 400,000 threshold to every historical file. Each investment must be tested against the legislation and transitional rules applicable to its transaction.

Period	Real estate investment threshold
12 January 2017 – 18 September 2018	USD 1,000,000
Relevant period beginning 19 September 2018	USD 250,000
From 13 June 2022	USD 400,000

TKGM’s instructions dated 1 June 2022 contain transitional rules concerning certain applications made before the change took effect. The dates of the transaction, application and relevant undertaking must therefore be examined rather than selecting the threshold from the date of a later review. [T1] [T2]

9. Can an Omission Be Completed Later?

Possibly, but a missing document and a missing investment must be distinguished.

Article 39 of Law No. 5901 addresses correction or completion of material errors or omissions in a decision in accordance with its basis. Article 65 of the Regulation also addresses correction and completion, particularly in relation to information in citizenship decisions. Neither should be treated as a general rule allowing an investor to pay a previously missing USD 100,000 years later and thereby make an earlier citizenship decision lawful retrospectively. [M5] [M6]

Type of issue	Possibility of addressing it later	Legal significance
A receipt for a payment actually made at the relevant time is missing from the file	Potentially possible	A newly produced record may prove an earlier payment.
A formal identity, authority or application document is incomplete	Depends on the applicable rule	Different from an absent substantive investment.
The required amount was genuinely paid but the chain of payment was insufficiently documented	Primarily an evidential question	Contemporary bank and seller records may establish the historical fact.
The property genuinely lacked the required value at the relevant date	A later document does not retrospectively create that value	The original legal conditions may need to be examined under Article 40.
The required sum was never genuinely paid	A new payment is a new event	It does not automatically create a payment at the earlier date.

10. Has TKGM Previously Allowed Deficiencies to Be Completed?

Yes, in particular circumstances. TKGM’s 1 June 2022 transitional instructions illustrate the distinction. They addressed certain pending transactions in which the former USD 250,000 condition and the required undertaking had been satisfied, while other deficiencies could be completed after 13 June 2022 under the stated conditions. The same instructions treated documents bearing on the investment value separately. [T2]

That transitional practice cannot be converted into a general authority to create a previously nonexistent substantive investment. Current TKGM and Your Key Türkiye guidance also addresses restrictions on completing an investment shortfall through a later sale-promise arrangement. [T3] [T4]

11. Can an Investment Shortfall Paid Today Save an Old Citizenship Decision?

As a general proposition, a payment first made today does not establish that an investment condition existed years ago when citizenship was granted. The relevant historical facts and applicable dates must be established.

Scenario A: The funds were genuinely paid at the relevant time, but records establishing the payment were missing or incorrectly filed. New evidence may prove the earlier fact.

Scenario B: The funds were not genuinely paid at that time, or the property did not have the required historical value. A later payment does not automatically transport the missing fact into the past.

This distinction is consistent with the temporal analysis of Article 40 in the Danıştay judgment E.2022/7637, K.2025/3313. [Y1]

12. What Is the TTB and Why Does It Matter?

The current TKGM framework uses the Taşınmaz Edinim Sureti ile Vatandaşlık Kazanımına Esas Tutar Tespit Belgesi (TTB) in determining the amount of real estate investment eligible for citizenship.

Under the 2024/4 circular and its guidance, the price declared in the official instrument or sale-promise agreement, together with relevant transfers and payments, is examined against the applicable threshold and the amount confirmed through the TTB process. These are distinct elements of the current assessment. [T3] [T5]

The current procedure does not mean that every older citizenship file may simply be reconstructed using rules first introduced after its transaction. Historical files must be examined under the substantive rules applicable at the relevant time.

13. Can Citizenship Be Cancelled After the Person Has Completed Military Service?

Yes. Completion of military service, paid military service or a military exemption does not by itself create statutory immunity against cancellation or withdrawal of a citizenship decision.

The consequences for military records require separate examination. Article 31 cancellation operates prospectively, and Article 58 of the Regulation protects acts performed during the period of citizenship from the effect of cancellation. Withdrawal under Article 40, together with Article 66 of the Regulation, raises different questions because of its retrospective effect. Guidance of the Millî Savunma Bakanlığı concerning loss and reacquisition of citizenship should be considered as appropriate. [M1] [M3] [M4] [A1] [A2]

For the rules governing military service immediately after acquisition of Turkish citizenship—including the 22-year rule—see our earlier English military-service article dated 14 September 2026.

14. What Happens to the Investor’s Spouse?

Article 32 of Law No. 5901 provides that an Article 31 cancellation decision also applies to a spouse who acquired Turkish citizenship dependent on the person concerned. The legal basis of the spouse’s citizenship is therefore decisive. [M1]

Article 58(2) of the Regulation addresses an important exception: a spouse who later acquired Turkish citizenship independently through marriage is not affected by the principal person’s cancellation in the same manner. It would therefore be inaccurate to say that the citizenship of every spouse necessarily ends together with the investor’s.

The dates and legal bases of both citizenship decisions must be checked. Where a family also has cross-border marital-status issues, those are distinct questions; see our 21 September English article on foreign spouses and dual citizens.

15. What Happens to the Children?

Children who acquired Turkish citizenship dependent on the investor generally fall within Article 32 when the principal person’s acquisition decision is cancelled under Article 31. Their records nevertheless require individual examination.

Article 58(2) of the Regulation contains an important exception concerning a child born after the parent acquired Turkish citizenship. In the stated cancellation context, the parent’s cancellation decision does not affect that child in the manner described by the provision. The child’s date of birth, date and basis of citizenship acquisition, and the legal basis of the measure against the parent must therefore be established. [M1] [M4]

16. Why Are the “55 Children” Mentioned in the 2026 Investigation Particularly Important?

The publicly reported information states that 1,015 persons acquired citizenship at the time of the original decision and that 55 children acquired citizenship after that decision. [H1] [H3] [H6]

There is an important distinction between acquiring citizenship after the decision and being born after the parent acquired citizenship. The express exception in Article 58(2) concerns the latter situation. The public figures alone therefore establish neither that all 55 children fall within that exception nor that all 55 will lose citizenship.

Each child’s birth date, citizenship acquisition date, legal basis of acquisition and relationship to an Article 31 cancellation or Article 40 withdrawal decision must be reviewed separately.

17. Does Potential Statelessness Change the Answer for a Child?

Preventing statelessness is an important consideration in nationality law. It does not justify an automatic answer without examining the precise statutory measure, the child’s other nationality status, the manner in which Turkish citizenship was acquired and the applicable constitutional and international-law arguments.

Academic writing continues to examine cancellation, withdrawal, legal certainty, proportionality and the prevention of statelessness. In particular, Çiçek Özgür’s 2026 study analyses the distinction between Articles 31 and 40 in the investment-citizenship context. The work of Mesut Aygün and Gülser Banu Uslu Yiğit considers wider difficulties in the investment-citizenship regime. [D1] [D2]

18. If a Construction Company Is Investigated, Is Every Purchaser’s Citizenship Cancelled?

No. An investigation concerning a company, manager, intermediary or valuation expert is not equivalent to a finding that every individual citizenship file connected with that company was unlawful.

For each investor, the following questions matter: Was the specific property one of the sales under examination? Did it genuinely meet the historical value threshold? Did the purchaser pay the required amount from genuine funds? Did the seller receive it? Was any amount returned? Was the valuation accurate? Did the purchaser know of or participate in an alleged irregularity? What is the individual reason for any measure concerning the Certificate of Conformity?

Company-level suspicion must be distinguished from investor-specific proof. This is also a central theme of our 19 September English analysis.

19. The First Phase in 2026: The Investigation Described as Babacan İnşaat-Related

On 4 August 2026, the Adalet Bakanlığı announced an investigation involving allegations that lower-value properties had been presented at higher values through false valuation reports and sham sales. It stated that legal proceedings had been initiated concerning the citizenship of 687 persons. [H9]

Reports concerning the first phase also referred to an alleged failure of approximately TRY 2.5 billion in qualifying funds to enter Türkiye, measures affecting properties and companies, and subsequent detention and judicial-control decisions concerning suspects. The second-phase reporting described the earlier phase as connected with Babacan İnşaat transactions. These are reported investigation matters, not findings concerning every buyer from the group. [H10] [H11] [H12]

20. Which Babacan-Related Companies Were Publicly Named in a Trusteeship Announcement?

Babacan GYO published a corporate announcement identifying the following 12 companies and stating that TMSF had been appointed as trustee under the relevant decision of the İstanbul 11. Sulh Ceza Hâkimliği. The announcement refers to the İstanbul Cumhuriyet Başsavcılığı investigation numbered 2026/132798 and later TMSF board decisions. [K1]

No.	Company stated in the Babacan GYO corporate announcement
1	B Grup Yapı Sanayi ve Ticaret AŞ
2	Babacan Grup Yatırım İnşaat Sanayi ve Ticaret AŞ
3	Babacan Gayrimenkul Enerji ve Turizm Sanayi Ticaret AŞ
4	Babacan Girişim Lojistik Hizmetleri Sanayi ve Ticaret AŞ
5	BBC Enerji Sanayi ve Ticaret AŞ
6	Investment Global Zenith Gayrimenkul Sanayi Ticaret AŞ
7	Batures Yönetim Turizm İşletme Sanayi ve Ticaret AŞ
8	Metares Bilişim ve Dijital Ticaret AŞ*
9	EFCE Lojistik Hizmetleri Ticaret AŞ
10	BBCN Yapı Gayrimenkul Geliştirme AŞ
11	Babacan Gayrimenkul Yatırım Ortaklığı AŞ
12	BCN Global Gayrimenkul Ticaret AŞ

*The corporate announcement appears to contain a spelling variation in this company name. The trade registry record should be checked before stating its exact registered trade name in a formal document.

21. Which Companies Were Expressly Named in the Second Phase?

Reports of the public statements concerning the 21 September second phase expressly identified the following structures in connection with the sales being examined:

Company or structure	Position in publicly reported statements
Gül İnşaat AŞ	Named in reporting concerning sales examined in the second phase.
Beyaz İnşaat	Named in reporting concerning sales examined in the second phase; the precise seller’s registered trade name must be checked in an individual file.
LİV İnşaat / LİV Yapı	Named in reporting concerning sales examined in the second phase; the precise legal entity must be verified.

Being named in an investigation is not a conviction. Nor does it establish that every project or every sale undertaken by a named company is under investigation. [H1] [H2] [H7]

22. What Other Company Names Appeared in a Press-Published Suspect List?

A list which the news organisation Takvim stated that it had obtained included the following company names or descriptions. This is press reporting, not a complete or authenticated official prosecutor’s list of companies. Similar names must not be used to attribute allegations to a different legal entity. [H13] [H14]

Name appearing in press reporting	Source qualification
Gül İnşaat Proje AŞ	Press-published list
Gül İnşaat AŞ	Also identified in reporting of public statements
Gül Yapı İnşaat Turizm Petrol Ürünleri ve Dış Ticaret AŞ	Press-published list
Gül İnşaat Turizm ve Ticaret AŞ	Press-published list
LİV Yapı Gayrimenkul Yatırım	Press-published list; exact registered name requires verification
Beyaz İnşaat Petrol Ürünleri Turizm Sanayi ve Ticaret AŞ	Press-published list; avoid confusing similarly named companies
2K Yapı İnşaat Sanayi ve Ticaret AŞ	Press-published list

23. Is There a Complete Official List of Projects Under Investigation?

As of 28 September 2026, no complete, publicly verified official project-and-unit list had been published showing precisely how the 274 sales were distributed among projects or independent units.

This is an essential limitation. Project names circulate on websites, social media and messaging groups. A project appearing in a company’s portfolio does not establish that it contains one of the 274 sales discussed in the investigation. The precise property, registered seller and transaction must be matched against official records. [H14]

24. How Should Project Names Circulating Publicly Be Read?

The following is not a “list of projects under investigation.” It lists examples appearing in publicly accessible company portfolios. It is provided to distinguish portfolio information from officially identified sales and to avoid attributing wrongdoing to an unverified project.

Company or group	Examples in publicly accessible portfolios	Meaning for the investigation
Gül İnşaat	Otoport, Metroport, Avangart, Eyüppark, Avcılar Park, Gül Express, Gülpark Yaşam, Güneşli Park Gardenya, Rose Marine Butik, Gül Parkyuvam, Güneşli Park, İş Batı, Rose Marine, Skyport, Kavaklı Konakları, Loca, Yedimavi, Gülpark 59, Terrace Garden, Eyüp Palas, Tempoint	Portfolio information only. A complete official list has not established that any particular one of these projects contains one of the 274 sales.
LİV Yapı	Yedi Mavi, Avangart İstanbul, LİV Büyükçekmece, LİV Marmara, LİV Marine Villa, Otoport, Kalekent, LİV Bahçeşehir, Rose Marine	Portfolio information, not identification of an investigated project.
Beyaz İnşaat	Beyaz Residence, Beyaz Kent, Beyaz City, White Corner, BeyCity, White Court, Beyaz Konaklar, Bakırköy Konakları, Beyaz Center Residence, Beyaz Tower, White Home, Şehr-i Bahar 2, Beyaz Vadi Residence, Beyaz Vadi Konakları	Public portfolio examples. Inclusion in this table does not establish inclusion in the investigation.
Babacan-related portfolio	Babacan Central, Babacan Lagoon, Babacan Port Royal, Vista Life, Babacan Atakent Halkalı, Babacan GOP Residence/AVM/Ofis, Babacan Botanist Başakşehir	Portfolio information. The public statements do not allocate the 687 citizenship files project by project.

Portfolio sources: Corporate publications of Gül İnşaat, LİV Yapı, Beyaz İnşaat and Babacan GYO. [K1]–[K4]

25. What Does the Appearance of a Project in This Table Establish?

By itself, nothing about an individual investigation or citizenship decision. These are examples taken from public portfolios. Purchasing a unit in Rose Marine, Kalekent, Yedi Mavi, Skyport, Otoport, Beyaz Residence or Babacan Port Royal does not establish that the unit formed part of the 274 or 687 transactions discussed publicly.

For that determination, the block, parcel and independent unit; date of sale; seller’s exact legal identity; valuation company and report; Certificate of Conformity; and complete payment chain must be compared with the individual administrative and, where lawfully accessible, criminal records.

26. Has the Full List of the 30 Companies Under Trusteeship Been Published?

Public statements concerning the second phase referred to seizure and trustee measures involving 30 joint-stock companies. [H1] [H8]

As of 28 September 2026, the public official statements examined for this article did not set out a complete list of the registered trade names of all 30 companies. Lists circulating on social media must therefore not be published as “the official list of 30 companies” without verification against the relevant prosecutor’s statement or judicial decision.

27. What Criminal Offences Have Been Mentioned in the Citizenship Investigation?

Reporting of the prosecutor’s statements of 21 and 25 September referred, in relation to various suspects, to allegations involving the establishment, management or membership of an organisation for criminal purposes; migrant smuggling; fraud to the detriment of public institutions; forgery of official documents; forgery of private documents; and false statements in the preparation of an official document. [H1] [H8]

It would be incorrect to infer that every offence is alleged against every investor or every company employee. Criminal liability is personal; the elements of an offence and the evidence concerning the particular suspect must be assessed individually.

28. Does a Criminal Investigation Mean Citizenship Has Already Been Cancelled?

No. A criminal investigation and an administrative act terminating citizenship are distinct legal processes.

For a person living abroad who has received no notification, an investigation involving the same property, project or transaction chain may nevertheless indicate that the citizenship file could also be subject to administrative examination. It does not prove that an individual cancellation or withdrawal decision has already been issued.

Determining the actual position may require separate checks concerning the criminal investigation, Certificate of Conformity, TKGM records, individual citizenship decision and records held by the Nüfus ve Vatandaşlık İşleri Genel Müdürlüğü. The practical distinctions are addressed in our 26 September English article and 28 September English FAQ.

29. Can a Cancellation or Withdrawal Decision Be Challenged in Court?

Yes. Article 66 of the Constitution establishes that citizenship is acquired under the conditions laid down by law and lost only in the cases specified by law; judicial review of relevant citizenship decisions cannot be closed off. [M7]

The issuing authority must be identified before selecting the competent court. Article 24 of Law No. 2575 provides for the Danıştay to hear actions against decisions of the President of the Republic as a court of first instance. [M8]

Under Article 7 of Law No. 2577, the general time limit before the Danıştay and administrative courts is 60 days unless a special period applies. Its starting date and calculation depend on the particular act and notification. A prior administrative application under Article 11 may affect the running of the period if the statutory requirements are met; its usefulness must be assessed in the individual case. [M9] [M10]

30. Does Filing a Lawsuit Automatically Suspend Cancellation?

No. Bringing an administrative action does not automatically suspend the challenged measure.

Under Article 27 of Law No. 2577, a stay of execution generally requires both that the administrative act be clearly unlawful and that its implementation cause harm difficult or impossible to remedy. The application should address the individual consequences for passports, travel, residence, work, family status, business activity and other legally relevant interests. [M11]

31. What Happens to the Investor’s Property If Citizenship Is Cancelled?

Termination of citizenship does not mean that the property automatically and immediately passes to the Treasury.

Article 33 of Law No. 5901 addresses the liquidation of assets where liquidation is considered necessary and specified in the cancellation decision. It also provides for liquidation procedures to be left until the end of litigation if the cancellation decision is challenged. [M1]

Whether the individual can continue to own a specific property as a foreign national is a separate question requiring examination of the former nationality, the location of the property, the Tapu Kanunu and the applicable rules on acquisition of real estate by foreigners.

32. Is It Enough to Say, “I Really Paid USD 400,000”?

No—but it is an important starting point. The current investigations concern not only the figure written in an official deed but also the genuine economic movement of funds.

Where possible, the investor should be able to demonstrate the source of the funds, the entire transfer chain, receipt by the seller and the absence of a direct or indirect return of money to the investor or connected persons. SWIFT records, complete bank statements, foreign-exchange purchase documents, seller account records and contemporary comparable sales may become decisive evidence.

33. What Documents Should an Investor Facing a Potential Risk Preserve?

The initial review should bring together the title deeds and official sale instruments for every property used in the citizenship application; purchase and sale-promise agreements; original valuation reports; Certificates of Conformity; foreign-exchange purchase documents; bank receipts; SWIFT records; payment instructions; invoices; records showing the source of the investor’s funds; citizenship application documents; and the citizenship decision.

Where there is a related criminal investigation, the investor-specific portions of expert reports, MASAK assessments, property lists and witness or suspect statements should be considered to the extent they can lawfully be accessed. Documents showing the actual seller, historical market value and absence of a refund may be especially important.

34. What Are the Most Important Legal Distinctions in a Defence?

No single defence applies to every investor. The following questions should nevertheless be answered in order:

1. Is the measure an Article 31 iptal decision or an Article 40 geri alma decision?
2. Does the administration allege the investor’s own false statement or concealment, or the absence of an objective investment condition?
3. Does a new expert report assess historical value at the relevant date, or improperly infer a historic value from current prices?
4. Was the investment genuinely deficient, or is the problem an evidential gap in proving an investment that actually occurred?
5. Did the investor genuinely pay the required amount from the investor’s own resources?
6. Did the property actually meet the legally applicable value threshold at the relevant historical date?
7. Does newly discovered evidence prove a fact already existing when citizenship was granted, or relate only to a subsequent event?
8. Did the spouse or child acquire citizenship dependent on the principal investor or through an independent legal basis?

35. Why Is the Danıştay’s 2025 Judgment So Important?

The Danıştay 10th Chamber’s judgment of 26 June 2025, E.2022/7637, K.2025/3313, arose from a withdrawal dispute involving a family who had acquired Turkish citizenship. Its significance lies in the temporal interpretation of the Article 40 concept of a decision issued without the legal conditions having been satisfied.

The factual or legal impediment relied on to justify withdrawal must be connected to the time when citizenship was granted or an earlier time. A later event with no established link to that original position cannot by itself prove that the original conditions were absent. [Y1]

This does not prevent the use of a newly prepared expert report. It means that the report must establish a relevant historical fact. The judgment should not be presented as though it had itself decided the merits of the 2026 valuation investigations.

36. Conclusion: Not Every Investigation File Is the Same

The 2026 operations demonstrate a period of substantial administrative and criminal scrutiny of Turkish citizenship acquired through investment. They do not justify identical conclusions for every investor who bought from the same company, acquired a property in the same project or used a valuation company whose work is now being examined.

The legally decisive facts are the investor’s own sale, payment chain, property’s genuine historical value, Certificate of Conformity, citizenship decision and any investor-specific connection to the criminal evidence.

An investor who genuinely paid the qualifying amount through the banking system, satisfied the substantive conditions at the relevant time and did not know of alleged misconduct by third parties must be distinguished from a person alleged to have participated knowingly in a merely apparent investment and circular movement of funds.

Equally, a formal or evidential deficiency in proving an investment must be distinguished from a substantive investment condition that never existed. Our earlier 19 September analysis, 26 September investigation analysis and 28 September FAQ address those different stages in chronological order.

37. Frequently Asked Questions

Can the authorities request another valuation?

Yes. A new expert or valuation examination can be undertaken during a renewed review. The relevant historical investment condition must, however, be assessed by reference to the appropriate earlier date rather than automatically substituting the property’s current market value.

Does the new valuation automatically invalidate the old one?

No. Both reports’ dates, methods, comparable transactions and assumptions must be considered together with deed and payment evidence.

Can an investment shortfall be completed later?

A later document may prove an investment genuinely made in the past. A payment first made years later does not automatically create a past substantive investment condition.

Does “completion” under Article 39 of Law No. 5901 mean paying a missing USD 100,000?

No general conclusion of that kind follows from Article 39. The provision concerns correction or completion of material errors or omissions in a decision in accordance with its basis, not a general right to validate an earlier citizenship decision by retrospectively making a previously absent investment.

Can the citizenship of a person who completed military service be cancelled?

Yes. Military service does not itself prevent an Article 31 cancellation or Article 40 withdrawal. The effects on the person’s military record require a separate assessment of the precise citizenship measure.

Does the spouse also lose citizenship?

The answer depends on whether the spouse acquired citizenship dependent on the investor or through a separate legal basis. Article 58(2) of the Regulation provides an exception concerning a spouse who subsequently acquired citizenship through marriage.

What about a child born after the parent acquired Turkish citizenship?

Article 58(2) of the Regulation states that, in the specified Article 31 cancellation context, the cancellation does not affect a child born after the parent acquired Turkish citizenship. The child’s individual records must still be examined.

Are the 55 children mentioned in September automatically protected?

No conclusion can be drawn from the public figure alone. The announcement says they acquired citizenship after the original decision; it does not establish that all were born after that decision. Birth and acquisition dates must be checked separately.

Does an investigation into a company place all of its purchasers in the same position?

No. An individual transaction may be reviewed, but a company investigation alone cannot establish that every purchaser failed to meet the citizenship conditions.

Which Gül, LİV and Beyaz projects are officially confirmed as part of the 274 sales?

As of 28 September 2026, no complete, publicly verified official list had assigned those sales to specific projects and independent units. Company portfolio lists must not be represented as investigation lists.

What is the time limit to challenge a citizenship decision?

Where no special period applies, the general period under Article 7 of Law No. 2577 is 60 days. The individual decision, method and date of notification, and any relevant administrative application must be reviewed to calculate the deadline correctly.

Does filing a case automatically stop the citizenship measure?

No. A stay of execution must be requested and supported under Article 27 of Law No. 2577.

38. Sources and Legal References

Legislation and Official Materials

[M1] Law No. 5901 on Turkish Citizenship, Articles 31, 32 and 33: https://www.mevzuat.gov.tr/mevzuatmetin/1.5.5901.pdf

[M2] Law No. 5901 on Turkish Citizenship, Articles 38, 39 and 40: https://www.mevzuat.gov.tr/mevzuatmetin/1.5.5901.pdf

[M3] Regulation on the Implementation of the Turkish Citizenship Law, Article 66: withdrawal and the effect from the original decision date. Official legislation portal: https://www.mevzuat.gov.tr/

[M4] Regulation on the Implementation of the Turkish Citizenship Law, Articles 57–58: investigation of cancellation grounds, effect on family members and specified exceptions. Official legislation portal: https://www.mevzuat.gov.tr/

[M5] Law No. 5901, Article 39: correction of material errors and completion: https://www.mevzuat.gov.tr/mevzuatmetin/1.5.5901.pdf

[M6] Regulation on the Implementation of the Turkish Citizenship Law, Article 65: correction and completion. Official legislation portal: https://www.mevzuat.gov.tr/

[M7] Constitution of the Republic of Türkiye, Article 66: https://www.mevzuat.gov.tr/mevzuatmetin/1.5.2709.pdf

[M8] Law No. 2575 on the Danıştay, Article 24: https://www.mevzuat.gov.tr/mevzuatmetin/1.5.2575.pdf

[M9] Law No. 2577 on Administrative Procedure, Article 7: https://www.mevzuat.gov.tr/mevzuatmetin/1.5.2577.pdf

[M10] Law No. 2577, Article 11: administrative application and its effect on the filing period: https://www.mevzuat.gov.tr/mevzuatmetin/1.5.2577.pdf

[M11] Law No. 2577, Article 27: stay of execution: https://www.mevzuat.gov.tr/mevzuatmetin/1.5.2577.pdf

TKGM and Real Estate Investment Sources

[T1] Your Key Türkiye / TKGM, information concerning the historical USD 250,000 and USD 400,000 thresholds: https://www.yourkeyturkiye.gov.tr/vatandaslik-kazanimi

[T2] TKGM Yabancı İşler Dairesi Başkanlığı, instructions dated 1 June 2022 concerning the amendment and transition: https://www.tkgm.gov.tr/sites/default/files/2022-06/Turk_vatandasligi_kanunu_uygulanmas%C4%B1_hk.01.06.2022.pdf

[T3] TKGM, 2024/4 circular and accompanying guidance, available in the official TKGM document collection: https://www.tkgm.gov.tr/yabanci-isler-dairesi-baskanligi/dokumanlar

[T4] Your Key Türkiye, “Vatandaşlık Kazanımı,” including the explanation concerning completion of an investment shortfall through a sale-promise agreement: https://www.yourkeyturkiye.gov.tr/vatandaslik-kazanimi

[T5] TKGM / Your Key Türkiye, guidance concerning the TTB and the amount eligible for citizenship: https://www.yourkeyturkiye.gov.tr/tasinmaz-edinim-rehberi

Danıştay Judgments

[Y1] Danıştay 10th Chamber, 26 June 2025, E.2022/7637, K.2025/3313: the time at which the conditions for an Article 40 decision must be assessed. Judgment citation: Danıştay 10. Daire, E.2022/7637, K.2025/3313.

[Y2] Danıştay 10th Chamber, 12 December 2024, E.2020/5861, K.2024/6304: valuation and the amount stated in the official property transaction used for citizenship purposes.

[Y3] Danıştay 10th Chamber, 23 June 2025, E.2021/279, K.2025/3174: grounds and evidential basis relevant to withdrawal of a citizenship decision.

Military Service Sources

[A1] Millî Savunma Bakanlığı, Askeralma Genel Müdürlüğü, “Vatandaşlık İşlemleri”: https://www.msb.gov.tr/Askeralma/icerik/vatandaslik-islemleri

[A2] Millî Savunma Bakanlığı, military-service questions and answers: https://www.msb.gov.tr/Genel/icerik/sikca-sorulan-sorular

Academic Sources

[D1] Çiçek Özgür, “Yatırım Yoluyla Kazanılan Türk Vatandaşlığının İptali ve Geri Alınması,” Ankara Üniversitesi Hukuk Fakültesi Dergisi, Vol. 75, No. 1, 2026, pp. 741–779: https://dergipark.org.tr/tr/pub/auhfd/article/1710185

[D2] Mesut Aygün / Gülser Banu Uslu Yiğit, “Yabancıların Yatırım Yoluyla Türk Vatandaşlığı Kazanmalarının Hukuki Yönden Değerlendirilmesi ve Yeni Model Önerisi,” Selçuk Üniversitesi Hukuk Fakültesi Dergisi, Vol. 34, No. 1, 2026: https://dergipark.org.tr/tr/pub/suhfd/article/1705055

[D3] Cemil Güner, “Türk Vatandaşlığının Kazanılması ve Kaybı Kararlarının Geri Alınması,” Milletlerarası Hukuk ve Milletlerarası Özel Hukuk Bülteni, Vol. 37, No. 2.

[D4] Hümeyra Zeynep Erden, “Türk Vatandaşlığına Alınma Kararının İptalinde Süre,” Milletlerarası Hukuk ve Milletlerarası Özel Hukuk Bülteni, Vol. 36, No. 1.

Official Announcements and Investigation Reporting

[H1] Anadolu Ajansı, 21 September 2026, report of the İstanbul-centred investigation: https://www.aa.com.tr/tr/gundem/istanbul-merkezli-usulsuz-vatandaslik-operasyonunda-73-zanli-yakalandi/4062988

[H2] TRT Haber, 21 September 2026, report of the second phase and company names: https://www.trthaber.com/haber/gundem/usulsuz-yollarla-turk-vatandasligi-kazandiran-sebekeye-operasyon-72-gozalti-957506.html

[H3] İçişleri Bakanlığı information concerning the 6,134 persons, principal investors, family members and 55 children, as reported in the 21 September 2026 news coverage. See the Anadolu Ajansı report at [H1].

[H4] Reporting dated 21 September 2026 concerning the second-phase investigation and the trustee measures affecting companies. See the public prosecutor information reported at [H1] and [H2].

[H5] Reporting dated 21 September 2026 concerning the amount exceeding TRY 3.5 billion attributed to second-phase transactions. See [H1] and [H2] for the publicly reported investigation context.

[H6] Reporting of İçişleri Bakanlığı data concerning 5,391 cancellations, 743 withdrawals and 6,134 persons in total. See the information reported at [H1].

[H7] Anadolu Ajansı, 21 September 2026, further details of the second-phase operation: https://www.aa.com.tr/tr/gundem/istanbul-merkezli-usulsuz-vatandaslik-operasyonunda-73-zanli-yakalandi/4062988

[H8] Anadolu Ajansı, 25 September 2026, report concerning 33 remand decisions and other judicial-control measures: https://www.aa.com.tr/tr/gundem/istanbul-merkezli-usulsuz-vatandaslik-operasyonunda-yakalanan-33-supheli-tutuklandi/4068739

[H9] Adalet Bakanlığı, 4 August 2026, announcement concerning legal proceedings relating to 687 persons: https://basin.adalet.gov.tr/bakan-gurlek-687-kisinin-vatandasliginin-iptali-icin-yasal-surec-baslatildi

[H10] Anadolu Ajansı, August 2026, subsequent report concerning judicial measures in the first phase: https://www.aa.com.tr/tr/gundem/-haksiz-yollarla-turk-vatandasligi-kazandirdigi-belirlenen-suc-orgutu-operasyonunda-32-zanli-tutuklandi/4021485

[H11] Public reporting concerning allegedly false valuations and approximately TRY 2.5 billion in the first phase; see the Adalet Bakanlığı announcement at [H9].

[H12] August 2026 reporting concerning detention measures and the 687-person citizenship process; see [H9] and [H10].

[H13] Takvim, 21 September 2026, press-published list described by the outlet as having been obtained by it. The list is not adopted here as an authenticated or complete official list.

[H14] Patronlar Dünyası, reporting dated 21–22 September 2026 concerning corporate relationships and the absence of a publicly announced allocation of the 274 sales by project.

Company Portfolio Sources

[K1] Babacan GYO, corporate announcement identifying 12 companies and public project portfolio: https://babacangyo.com/

[K2] Gül İnşaat, completed projects and corporate information: https://gul-insaat.com.tr/tamamlanan-projeler/

[K3] LİV Yapı, corporate project portfolio: https://www.livyapi.com/index.php

[K4] Beyaz İnşaat, corporate information and portfolio: https://beyaz-insaat.com/Kurumsal/

Legal Information and the Presumption of Innocence

This article has been prepared on the basis of publicly accessible legislation, judicial decisions, official announcements, academic publications, corporate portfolio material and news reporting available as of 28 September 2026.

An investigation, detention decision, asset measure or trusteeship measure concerning a company or individual is not a final criminal conviction. Persons and entities remain entitled to the presumption of innocence. Equally, the involvement of a company in an investigation does not establish that every project, unit or sale associated with it was irregular.

Social-media lists of investors, companies or projects are not official proof that a particular person is among the 1,070, that a particular unit forms part of the 274 sales, or that an individual citizenship cancellation or withdrawal decision has been issued.

A reliable assessment requires the individual citizenship file, the applicable law at the transaction date, property and title records, historical valuation evidence, the Certificate of Conformity, complete banking records and any evidence specifically attributable to the investor. This article provides general legal information and is not an individual legal opinion or a guarantee of outcome.

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TD Law Firm | TD Hukuk ve Danışmanlık

Av. Murat Can Dolğun
İstanbul Barosu — Registration No. 75860
TD Law Firm — İstanbul
Telephone: +90 212 299 44 22
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Website: https://td-lawfirm.com

An assessment concerning cancellation or withdrawal of Turkish citizenship, renewed examination of a real estate investment or a related criminal investigation should consider the citizenship file together with the property, valuation and payment records. Each investor and each family member requires an individual legal analysis.