Summary

The acquisition of Turkish citizenship by investment is one of the exceptional methods of acquiring citizenship regulated under Article 12 of Turkish Citizenship Law No. 5901 (“TCL”) and Article 20 of the Regulation on the Implementation of the Turkish Citizenship Law (“Regulation”).

In particular, where citizenship is sought through the acquisition of real estate, the investment must satisfy the amount and other conditions prescribed by the legislation, the competent administrative authorities must determine that the relevant investment requirements have been fulfilled, and the competent authority must ultimately issue a decision granting Turkish citizenship.

Criminal investigations and administrative reviews that became public in 2025 and 2026 have resulted in renewed scrutiny of the legal status of a significant number of persons who previously acquired Turkish citizenship by investment. These investigations have primarily concerned allegations that low-value properties were presented as having substantially higher values through false or fraudulent valuation reports, that sham property transactions were conducted, that the legally required investment amount was presented as having been satisfied when it had not actually been paid, and that apparent financial transfers were subsequently reversed.

On 4 August 2026, the Turkish Ministry of Justice announced that, within an investigation concerning allegations that low-value properties had been presented as high-value properties through fraudulent valuation reports and sham sales transactions, legal proceedings had been initiated with a view to cancelling the citizenship of 687 persons stated to have acquired Turkish citizenship through this method.

Republic of Türkiye Ministry of Justice:
https://basin.adalet.gov.tr/bakan-gurlek-687-kisinin-vatandasliginin-iptali-icin-yasal-surec-baslatildi

Anadolu Agency:
https://www.aa.com.tr/tr/gundem/haksiz-turk-vatandasligi-kazandirdigi-tespit-edilen-suc-orgutune-operasyon-/4017632

However, the existence of a criminal investigation against a property developer, real estate company, intermediary or valuation expert and the conclusion that an investor dealing with that person or entity unlawfully acquired Turkish citizenship are distinct legal questions.

For each investor, it is necessary to examine separately the legislation in force at the date of the investment, the true economic substance of the investment, the historical value of the property, the movement of funds, whether the investor knew of any alleged irregularities committed by third parties, and the statutory basis upon which the citizenship decision is subsequently terminated.

In this context, a fundamental distinction must be drawn between cancellation of a citizenship acquisition decision under Article 31 TCL and withdrawal of a citizenship decision under Article 40 TCL.

I. LEGAL NATURE OF TURKISH CITIZENSHIP BY INVESTMENT

Citizenship by investment is not a form of citizenship that can be “sold” by private persons.

A developer or real estate company may sell property, and an intermediary or consultancy company may provide services in relation to the investment and application process. The authority to grant Turkish citizenship, however, belongs to the Turkish State.

Article 12 TCL regulates circumstances in which Turkish citizenship may be acquired exceptionally. The types and amounts of qualifying investments are principally regulated under Article 20(2) of the Regulation.

Under the current framework, the real estate route generally requires the acquisition of property with a value of at least USD 400,000 or its equivalent in foreign currency, together with the legally prescribed restriction preventing disposal for three years.

The current USD 400,000 threshold, however, cannot be applied indiscriminately to investments completed under earlier versions of the legislation. Investment thresholds and procedural requirements have changed over time.

Accordingly, a historical citizenship file must be examined by reference to the legal regime applicable when the relevant investment was made.

The legality of an earlier investment cannot therefore be assessed solely by reference to the investment requirements presently in force.

II. LEGAL SIGNIFICANCE OF VALUATION REPORTS AND THE CERTIFICATE OF CONFORMITY

In citizenship applications based on real estate investment, purchasing property alone is insufficient. The Turkish system includes an administrative process for determining whether the relevant property and investment satisfy the requirements prescribed by citizenship legislation.

Valuation reports, title deed records, determination of the qualifying investment amount and the Certificate of Conformity therefore assume considerable legal significance.

A Certificate of Conformity is not a document created merely by the investor’s unilateral declaration or by the seller’s representation. The competent public authority conducts an assessment as to whether the investment satisfies the applicable requirements.

Consequently, where a previously granted citizenship decision is subsequently reviewed, the analysis should not be confined to the investor’s relationship with the developer or other private parties. The administrative examination that preceded the citizenship decision must also be taken into account.

Nevertheless, the fact that a Certificate of Conformity was issued does not mean that the citizenship decision can never subsequently be withdrawn. Article 40 TCL expressly regulates the withdrawal of citizenship decisions where it is later established that the legal requirements had not been satisfied.

Two extreme approaches should therefore be avoided.

The prior issuance of a Certificate of Conformity does not place a citizenship decision entirely beyond subsequent legal review.

Conversely, an investigation concerning a valuation company or property developer does not, of itself, establish that every investor who dealt with that person or entity unlawfully acquired Turkish citizenship.

Each case must be examined on its own facts and legal circumstances.

III. THE 2025 INVESTIGATION INTO ALLEGED SHAM PROPERTY TRANSACTIONS

Large-scale investigations concerning citizenship by investment did not begin in 2026.

On 24 September 2025, an Istanbul-based investigation extending across 19 provinces became public. It concerned allegations that foreign investors had obtained Turkish citizenship through sham real estate transactions.

According to information released in connection with the investigation, it was alleged that 451 foreign investors, together with their family members, had acquired citizenship through the scheme; that the foreign capital required for citizenship had not genuinely entered Türkiye; that fictitious financial movements had been created; and that properties had been presented at values exceeding their true values.

Anadolu Agency:
https://www.aa.com.tr/tr/gundem/muvazaali-gayrimenkul-satisiyla-vatandaslik-saglayan-suc-orgutu-cokertildi/3697125

Subsequent reports concerning the investigation also contained allegations that arrangements had been made enabling certain properties to be returned to previous owners or related persons after completion of the citizenship process.

Anadolu Agency:
https://www.aa.com.tr/tr/gundem/yabancilara-usulsuz-vatandaslik-kazandiran-suc-orgutune-yonelik-operasyonda-yakalanan-113-supheli-adliyede/3699547

If substantiated, such allegations may demonstrate a significant discrepancy between the actual economic substance of the transactions and their formal legal appearance.

It must nevertheless be emphasised that allegations made during a criminal investigation do not constitute final criminal convictions.

IV. THE 2026 INVESTIGATION CONCERNING 687 PERSONS

On 4 August 2026, the Ministry of Justice published details of a large-scale investigation coordinated by the Organised Crime Investigation Bureau of the Istanbul Chief Public Prosecutor’s Office.

The official announcement referred to allegations involving:

“low-value properties being presented as high-value properties through fraudulent valuation reports and Turkish citizenship being obtained through sham sales transactions.”

Republic of Türkiye Ministry of Justice:
https://basin.adalet.gov.tr/bakan-gurlek-687-kisinin-vatandasliginin-iptali-icin-yasal-surec-baslatildi

According to the announcement, approximately TRY 2.5 billion which should have entered Türkiye in connection with citizenship acquisitions allegedly did not enter the country, and fictitious money transfers were allegedly used instead.

The authorities further announced measures concerning seven companies and 1,045 properties and stated that legal proceedings had been initiated with a view to cancelling the citizenship of 687 persons said to have obtained citizenship through the method under investigation.

The investigation was also reported by Anadolu Agency:

At a later stage, it was reported that 32 of 80 detained suspects had been remanded in custody:

Descriptions such as “fraudulent valuation” and “sham transaction” in this context refer to allegations made within the investigation. An investigation, detention or remand order does not constitute a final conviction. The presumption of innocence continues to apply unless and until a final conviction is entered.

V. ARTICLE 31 TCL: CANCELLATION FOR FALSE STATEMENTS OR CONCEALMENT OF MATERIAL MATTERS

Article 31 of Turkish Citizenship Law No. 5901 provides:

“Where a decision on the acquisition of Turkish citizenship has resulted from a false statement by the person concerned or from the concealment of material matters constituting the basis for the acquisition of citizenship, the decision shall be cancelled by the authority which issued it.”

Turkish Citizenship Law No. 5901:
https://www.mevzuat.gov.tr/mevzuatmetin/1.5.5901.pdf

The wording of the provision is significant.

The Law does not provide that every irregularity discovered in the citizenship acquisition process is, in itself, sufficient for cancellation under Article 31.

For Article 31 to apply, the acquisition of citizenship must have resulted from a “false statement by the person concerned” or from that person’s concealment of a material matter forming the basis of the acquisition of citizenship.

Accordingly, where an administrative decision is based on Article 31, it must be identified which statement made by the investor was false or which material matter was concealed.

There must also be a causal relationship between the false statement or concealment and the acquisition of citizenship. In other words, it is necessary to consider whether citizenship would have been granted had the true circumstances been known to the administration.

Article 31 should therefore not be treated as a general statutory mechanism for correcting every possible irregularity associated with an earlier citizenship decision.

VI. ACTS OF THIRD PARTIES CANNOT, OF THEMSELVES, BE ATTRIBUTED TO THE INVESTOR

One of the central legal issues in the current disputes is the extent to which acts allegedly committed by developers, real estate companies, intermediaries or valuation experts can produce consequences for individual investors.

Article 31 refers specifically to a false statement or concealment by “the person concerned”.

Accordingly, the fact that a valuation expert prepared a false report does not, without more, establish that the investor knew that the report was false.

Similarly, an allegation that a developer carried out sham transactions in certain sales is not, by itself, sufficient to establish that every investor who purchased property from that developer knowingly participated in those transactions.

An individualised examination is therefore necessary.

In particular, it may be necessary to determine:

whether the investor knew that the valuation report was inaccurate;

whether the investor gave any instruction or otherwise participated in increasing the stated value;

whether the investor knew that part of the purchase price would later be returned;

whether any part of the purchase price was in fact returned;

whether the investor made any false statement during the citizenship application; and

whether the investor knowingly concealed any matter material to the acquisition of citizenship.

Particularly in light of the express wording of Article 31, the conduct of a third party should not simply be equated with the conduct of the investor.

VII. ARTICLE 40 TCL: WITHDRAWAL WHERE THE LEGAL REQUIREMENTS WERE NOT SATISFIED

Article 40 TCL provides:

“Decisions concerning the acquisition or loss of Turkish citizenship shall be withdrawn where it is subsequently understood that they were issued without the legal requirements having been satisfied or were issued repetitively.”

Turkish Citizenship Law No. 5901:
https://www.mevzuat.gov.tr/mevzuatmetin/1.5.5901.pdf

Article 40 addresses a different legal issue from Article 31.

Article 31 focuses upon the false statement or concealment of the person concerned. Article 40 concerns whether the legal requirements for the citizenship decision objectively existed when the decision was made.

It is therefore possible, in principle, for an investor to have engaged in no fraudulent conduct whatsoever while one of the objective statutory conditions required for citizenship was nevertheless absent from the outset.

For example, an investor may have relied in good faith on the accuracy of a valuation report and may not have made any misleading statement. It might nevertheless subsequently be established through reliable evidence that the true value of the property at the relevant time was below the investment threshold prescribed by the legislation then in force.

In such circumstances, the question of false statement or concealment under Article 31 and the question of whether the objective legal requirements existed under Article 40 must be analysed separately.

VIII. WHY THE DISTINCTION BETWEEN ARTICLES 31 AND 40 IS CRITICAL

Articles 31 and 40 do not merely regulate the same legal consequence using different terminology.

The central question under Article 31 is:

Was citizenship acquired as a result of a false statement by the person concerned or the concealment of a material matter?

The central question under Article 40 is:

Did the legal requirements necessary for the acquisition of citizenship actually exist when the citizenship decision was issued?

The distinction is not merely theoretical or terminological.

It directly affects the statutory basis of the administrative measure, its factual grounds, the matters that the administration must establish and the legal arguments available to the person concerned.

An investor’s false representation and an erroneous administrative determination that the investment requirements had been fulfilled are not the same legal circumstance.

IX. ADMINISTRATIVE ERROR, LEGAL CERTAINTY AND WITHDRAWAL

A decision granting citizenship is an administrative act. The withdrawal of unlawful administrative acts is closely connected with the principles of legal certainty and administrative stability under Turkish administrative law.

Where the alleged illegality results not from fraud by the person concerned but from an error in the administration’s own examination or assessment, the limits applicable to the later withdrawal of an act conferring legal status become particularly significant.

The absence of an express time limit in Article 40 does not eliminate questions concerning legal certainty.

Citizenship is a fundamental component of an individual’s legal status and social identity. A person may have relied upon that status over a period of years when organising family life, economic activity, professional relationships and residence in Türkiye.

Depending on the circumstances of the individual case, these matters may therefore become relevant to legal certainty, administrative stability and proportionality.

At the same time, deliberate deception by an applicant and an error made by the administration in its own examination cannot simply be treated as legally identical situations.

X. THE PRINCIPLE OF LEGALITY IN MATTERS OF CITIZENSHIP

Article 66(3) of the Constitution of the Republic of Türkiye provides:

“Citizenship shall be acquired under the conditions stipulated by law and shall be lost only in the cases specified by law.”

Constitution of the Republic of Türkiye:
https://www.mevzuat.gov.tr/mevzuatmetin/1.5.2709.pdf

This constitutional provision establishes the principle of legality in relation both to the acquisition and loss of citizenship.

The statutory basis for terminating citizenship status must therefore be identified, and the circumstances of the individual case must fall within the elements of the ground for loss prescribed by law.

Accordingly, subordinate regulations, administrative circulars or administrative procedural rules cannot be interpreted in a manner that expands the statutory scope of Articles 31 and 40 TCL.

Where an administrative measure has the serious consequence of terminating citizenship status, the administration should identify both the statutory basis for its decision and the factual circumstances that make that provision applicable.

XI. THE LEGISLATION IN FORCE AT THE DATE OF THE INVESTMENT MUST BE CONSIDERED

The current USD 400,000 threshold for the real estate route cannot be used as the sole benchmark for every historical investment.

The required investment amounts and other conditions have changed over time.

A historical file should therefore be examined by reference to, among other matters:

the date of the investment;

the investment threshold in force on that date;

the date on which the acquisition of the property was completed;

the date of the Certificate of Conformity;

the date of the citizenship application; and

the date of the citizenship decision.

The current investment threshold cannot simply be applied retrospectively when assessing the legality of an investment completed under an earlier legal regime.

XII. WHERE A FALSE VALUATION IS ALLEGED, THE HISTORICAL VALUE OF THE PROPERTY REMAINS CRITICAL

An allegation that a valuation report was fraudulent or inaccurate does not eliminate the separate question of what the property was actually worth.

On the contrary, one of the central factual questions becomes the true market value of the property at the date of the investment.

Assume, for example, that the applicable citizenship threshold was USD 250,000 and that the property was valued in the original report at USD 400,000.

If years later it is alleged that the valuation report was inaccurate, it remains necessary to establish whether the property’s true historical value was USD 150,000, USD 280,000 or approximately USD 400,000.

A retrospective independent valuation may therefore become important.

Comparable transactions from the relevant period, independent sales within the same development, bank valuation reports, title deed records, historical project price lists, the physical characteristics and location of the property, and contemporary market conditions may all be relevant.

If objective historical evidence establishes that the property itself already exceeded the statutory threshold applicable at the date of investment, alleged misconduct by the person who prepared the valuation report in other transactions does not, by itself, establish that the individual investor failed to satisfy the objective investment requirement.

XIII. THE ENTIRE FLOW OF FUNDS SHOULD BE EXAMINED

Another major issue emerging from the current investigations is whether the qualifying investment amount was genuinely paid in economic terms.

Examining a single bank receipt may therefore be insufficient.

The entire financial chain should be analysed.

Relevant questions may include the source of the investor’s funds, how and when the money entered Türkiye, the account to which it was transferred, whether the seller actually received the purchase price, and whether any part of the funds was subsequently returned directly or indirectly to the investor or a related person.

An investor who apparently transferred USD 400,000 but, pursuant to a prior arrangement, later received a substantial portion of that sum back presents a materially different case from an investor who genuinely paid the required investment amount and received no refund.

The financial substance of the transaction is therefore a central evidential issue.

XIV. LEGAL CONSEQUENCES OF AN INVESTIGATION AGAINST A DEVELOPER OR VALUATION COMPANY

The existence of a criminal investigation against a real estate company, developer, intermediary or valuation expert does not, of itself, establish that all investors who dealt with that person or entity unlawfully acquired Turkish citizenship.

A company may have sold hundreds of properties.

Some properties may have been overvalued, whereas the genuine market values of others may already have exceeded the relevant citizenship threshold.

Some investors may have received part of the purchase price back, whereas others may have received no refund whatsoever.

Some investors may be alleged to have known of an unlawful arrangement, while others may have invested in reliance upon official valuation documentation, title deed procedures and a Certificate of Conformity.

Citizenship status should therefore be examined through an individualised assessment of each file rather than through a generalised conclusion based solely upon the identity of the developer or valuation company.

XV. THE LEGAL POSITION OF A GOOD-FAITH INVESTOR

The concept of a “good-faith investor” must be used carefully in citizenship disputes.

Good faith does not, of itself, guarantee that citizenship status will be preserved in every circumstance.

It is, however, particularly important in an assessment under Article 31.

An investor may have:

genuinely paid the required investment amount;

received no refund;

acquired the property through an official title deed transaction;

relied upon a valuation report produced within the authorised system;

obtained a Certificate of Conformity;

complied with the applicable restriction on disposal;

submitted no false document;

made no false statement; and

had no knowledge of unlawful conduct allegedly committed by third parties.

Such an investor is not in the same legal position as a person who knowingly participated in a sham investment arrangement.

Nevertheless, even where the investor engaged in no fraudulent conduct, it may subsequently be alleged that an objective statutory investment requirement did not actually exist when citizenship was granted.

In such a case, the existence of a false statement or concealment attributable to the investor under Article 31 and the existence of the objective legal conditions under Article 40 must be examined separately.

XVI. AN INVESTOR WHO RELIED UPON THE ADMINISTRATION’S OWN SYSTEM

The citizenship-by-investment procedure involves several stages of administrative examination.

An investor may have completed an official title deed transaction, relied upon a valuation report produced through the authorised system, obtained a Certificate of Conformity and completed the citizenship application before the competent public authorities.

The existence of these steps does not absolutely prevent the application of Article 40.

However, an investor’s reliance upon a system established and supervised by the administration may, depending upon the individual circumstances, be relevant to the principles of legal certainty, administrative stability, legitimate expectations and proportionality.

These considerations may become particularly significant where the alleged illegality resulted not from deception by the investor but from errors in the examination or assessment undertaken by the competent authorities.

XVII. COUNCIL OF STATE, 10TH CHAMBER, E.2022/7637, K.2025/3313, 26 JUNE 2025

The judgment of the 10th Chamber of the Council of State in Case E.2022/7637, K.2025/3313, dated 26 June 2025, did not concern a fraudulent property valuation or real estate investment dispute.

It is nevertheless important in relation to the application of Article 40 TCL and judicial review of the withdrawal of citizenship decisions.

The judgment emphasises the importance of establishing factual grounds capable of demonstrating whether the relevant legal requirements actually existed at the time citizenship was acquired.

An adverse fact emerging at a later date and the absence of a legal requirement at the time the citizenship decision was issued are not the same thing.

This distinction is relevant to citizenship-by-investment disputes.

For example, the fact that an investigation is commenced against a developer or valuation company in 2026 does not, by itself, establish that an individual investor dealing with that company in an earlier year failed to satisfy the legal requirements applicable at the time citizenship was acquired.

The later information must be capable of demonstrating that a legal requirement was in fact absent at the relevant historical date.

Council of State, 10th Chamber, E.2022/7637, K.2025/3313:
https://hukas.com.tr/ictihat/danistay/10-daire-2022-7637-esas-2025-3313-karar/aa20d570-25fb-4ee9-a4ec-f174f89cdce8

XVIII. COUNCIL OF STATE, 10TH CHAMBER, E.2021/279, K.2025/3174, 23 JUNE 2025

The judgment of the 10th Chamber of the Council of State in Case E.2021/279, K.2025/3174, dated 23 June 2025, is also significant in relation to Article 40 TCL.

The judgment requires the circumstances relied upon to justify withdrawal of citizenship to be supported by “concrete, sufficient and serious information”.

In terms of the factual grounds of an administrative act, the administration is required to base its decision upon genuine and legally valid grounds.

Applied to citizenship-by-investment disputes, this approach indicates that the existence of an investigation into a particular company or valuation entity cannot, by itself, be treated as a general ground for withdrawing the citizenship of every investor who previously dealt with that entity.

The administration must establish, in relation to the individual investor, which legal requirement was absent when citizenship was acquired.

Council of State, 10th Chamber, E.2021/279, K.2025/3174:
https://mevzuat.adalet.gov.tr/ictihat/1170303600

XIX. CRIMINAL INVESTIGATIONS AND JUDICIAL REVIEW OF CITIZENSHIP DECISIONS MUST BE DISTINGUISHED

A criminal investigation and administrative review of the legality of a citizenship decision are separate legal processes.

Bank records, valuation documents, communications, money transfers and other evidence obtained in a criminal investigation may be highly relevant to a citizenship dispute.

However, the fact that a developer, company director, intermediary or valuation expert is a suspect in a criminal investigation does not, of itself, establish that an investor made a false statement or concealed a material fact within the meaning of Article 31 TCL.

Conversely, the fact that an investor is not a suspect in the criminal investigation does not, of itself, establish that all objective statutory requirements for citizenship were satisfied.

Criminal liability and the validity of a citizenship decision under administrative law are governed by different legal tests.

Evidence obtained in criminal proceedings may be used in the administrative dispute, but the legality of a cancellation or withdrawal decision must still be assessed separately by reference to the elements of the applicable provision of Law No. 5901.

XX. JUDICIAL PROTECTION AGAINST CANCELLATION OR WITHDRAWAL OF CITIZENSHIP

Cancellation or withdrawal of a citizenship decision constitutes an administrative act and is subject to judicial review.

The competent court must be determined by reference to the authority that issued the challenged measure.

Under Article 24 of Law No. 2575 on the Council of State, actions challenging decisions of the President of the Republic are heard by the Council of State as the court of first instance.

Law No. 2575 on the Council of State:
https://www.mevzuat.gov.tr/mevzuatmetin/1.5.2575.pdf

A citizenship-by-investment file may, however, involve more than one administrative act.

Cancellation of the Certificate of Conformity and cancellation or withdrawal of the citizenship decision may constitute separate administrative measures.

It is therefore necessary to examine separately:

the authority issuing each measure;

the legal character of the measure;

its statutory basis;

the date of notification;

any earlier decision concerning the Certificate of Conformity; and

the final measure directly affecting citizenship status.

XXI. TIME LIMIT FOR BRINGING AN ADMINISTRATIVE ACTION

Article 7(1) of the Administrative Procedure Law No. 2577 provides, in substance, that unless a special statutory period applies, the general time limit for bringing an action before the Council of State and administrative courts is sixty days.

Administrative Procedure Law No. 2577:
https://www.mevzuat.gov.tr/mevzuatmetin/1.5.2577.pdf

The precise commencement and calculation of the time limit must nevertheless be determined by reference to the individual case, including the date and manner of notification, the nature of the administrative measure and any relevant administrative application.

A cancellation or withdrawal decision should therefore be reviewed without delay following notification.

XXII. STAY OF EXECUTION

Bringing an action for annulment does not, of itself, suspend the operation of the challenged administrative measure.

Under Article 27 of Law No. 2577, a stay of execution may be granted where the implementation of the administrative act would cause damage that is difficult or impossible to remedy and the act is clearly unlawful. Both conditions must be satisfied.

Administrative Procedure Law No. 2577:
https://www.mevzuat.gov.tr/mevzuatmetin/1.5.2577.pdf

Termination of citizenship status may have consequences extending considerably beyond identity documents and passports.

Depending upon the individual circumstances, it may affect residence and employment status, travel, corporate activities, banking relationships, family life and the private life established by the individual in Türkiye.

An application for a stay of execution should therefore address not only the alleged unlawfulness of the measure but also the specific and individual harm likely to arise from its implementation.

XXIII. PRIVATE-LAW CLAIMS AGAINST DEVELOPERS, SELLERS AND INTERMEDIARIES

Administrative proceedings concerning citizenship and private-law claims against a developer, seller, intermediary or other private party are distinct legal avenues.

A property may have been expressly marketed as an investment satisfying the conditions for Turkish citizenship, and the investor may have purchased the property in reliance upon that representation.

If the property did not in fact possess the characteristics promised or did not satisfy the investment conditions represented by the seller or intermediary, contractual liability may arise.

Article 112 of the Turkish Code of Obligations No. 6098 provides for liability for damage resulting from non-performance or improper performance of an obligation, subject to the applicable statutory conditions.

Turkish Code of Obligations No. 6098:
https://www.mevzuat.gov.tr/mevzuatmetin/1.5.6098.pdf

Depending upon the facts, the provisions concerning tort and unjust enrichment may also require consideration.

Sales contracts should therefore be preserved together with advertisements, brochures, project presentations, emails, WhatsApp communications and other representations that the property qualified for Turkish citizenship.

XXIV. PROVISIONAL ATTACHMENT AND INTERIM INJUNCTIONS

In high-value investment disputes, it may also be necessary to consider whether an eventual judgment can be effectively enforced.

Where the statutory conditions are satisfied, provisional attachment may be sought in relation to qualifying monetary claims under Article 257 et seq. of the Enforcement and Bankruptcy Law No. 2004.

Enforcement and Bankruptcy Law No. 2004:
https://www.mevzuat.gov.tr/mevzuatmetin/1.3.2004.pdf

Where preservation of a particular asset or right is required, an interim injunction may be considered under Article 389 et seq. of the Code of Civil Procedure No. 6100.

Code of Civil Procedure No. 6100:
https://www.mevzuat.gov.tr/mevzuatmetin/1.5.6100.pdf

Provisional attachment and interim injunctions are distinct forms of interim judicial protection and the appropriate remedy must be determined by reference to the nature of the substantive claim.

XXV. CONSUMER LAW

Where an individual acquiring property did not act for commercial or professional purposes, the applicability of Consumer Protection Law No. 6502 may also require consideration depending upon the nature of the transaction.

The mere fact that property was acquired for citizenship purposes does not, by itself, determine whether the dispute is a consumer dispute.

The legal status of the parties, the purpose of the transaction and the nature of the contractual relationship must be considered together.

Consumer Protection Law No. 6502:
https://www.mevzuat.gov.tr/mevzuatmetin/1.5.6502.pdf

XXVI. EVIDENCE THAT SHOULD BE COLLECTED

The central task in these disputes is frequently to reconstruct the factual and economic reality existing at the date of the investment.

Relevant evidence may therefore include:

the citizenship acquisition decision;

the cancellation or withdrawal decision;

documents evidencing notification;

the Certificate of Conformity;

any decision cancelling the Certificate of Conformity;

the title deed and official deed of sale;

records concerning the restriction on disposal;

the sale or preliminary sale agreement;

valuation reports;

the applicable investment amount determination documentation;

foreign currency purchase documents;

bank receipts;

SWIFT records;

complete bank account movements relating to the investment period;

invoices and receipts;

communications with the seller, developer and intermediaries;

emails and WhatsApp correspondence;

advertisements and marketing materials representing the property as citizenship-eligible;

banking evidence demonstrating that the investment amount was not returned to the investor;

comparable historical property values; and

available documents from any related criminal investigation.

The objective is not simply to accumulate documents, but to reconstruct, through reliable evidence, the economic substance of the transaction at the relevant historical date and the individual conduct of the investor.

XXVII. CONSTITUTIONAL COURT AND EUROPEAN COURT OF HUMAN RIGHTS

Following exhaustion of the ordinary domestic remedies, an individual application to the Turkish Constitutional Court may be considered where the circumstances disclose an alleged violation of a fundamental right falling within the common protection afforded by the Constitution and the European Convention on Human Rights.

Turkish Constitutional Court – Individual Application:
https://www.anayasa.gov.tr/tr/bireysel-basvuru/

The European Convention on Human Rights does not establish an independent right to acquire or retain the nationality of a particular State.

Nevertheless, the case law of the European Court of Human Rights recognises that nationality may form part of an individual’s social identity and private life, and that arbitrary deprivation of nationality may, in certain circumstances, raise issues under Article 8 of the Convention.

European Court of Human Rights, Guide on Nationality:
https://ks.echr.coe.int/documents/d/echr-ks/nationality

These remedies are not additional appellate instances for reconsidering ordinary questions of administrative law. The alleged interference with a Convention or constitutionally protected right must be identified and substantiated in the individual case.

CONCLUSION

The investigations that became public in 2025 and 2026 have resulted in renewed scrutiny of numerous historical Turkish citizenship-by-investment files.

Allegations involving fraudulent or inaccurate valuation reports, artificial inflation of property values, sham sales and fictitious financial movements are serious. Nevertheless, Turkish citizenship law requires individual legal assessment rather than generalised assumptions.

An investigation against a developer does not, of itself, establish that every person who purchased property from that developer unlawfully acquired Turkish citizenship.

Likewise, establishing that a valuation report was inaccurate does not, by itself, prove that the investor knew of the inaccuracy.

Turkish Citizenship Law No. 5901 provides two materially different mechanisms.

Article 31 concerns cancellation of a citizenship acquisition decision where citizenship resulted from a false statement by the person concerned or the concealment of a material matter forming the basis of citizenship.

Article 40 concerns withdrawal where it is subsequently established that the legal requirements for the citizenship decision had not been satisfied.

The scope and requirements of these provisions must be distinguished.

Particularly where unlawful acts are alleged to have been committed by third parties, the individual conduct of the investor requires separate examination.

An investor may have submitted no false document, made no false statement, had no knowledge that a valuation report was inaccurate and genuinely paid the qualifying investment amount. Where Article 31 is invoked in such circumstances, the false statement or concealment attributable to that investor must be identified and established.

Conversely, even in the absence of fraud by the investor, a separate issue may arise under Article 40 if an objective legal requirement for citizenship did not in fact exist when the citizenship decision was issued.

The 2025 judgments of the 10th Chamber of the Council of State further demonstrate the importance, in withdrawal cases, of concrete, sufficient and serious information and of examining whether the relevant legal requirements actually existed when citizenship was acquired.

Accordingly, each file should be examined by reference to:

the legislation applicable at the date of investment;

the investment threshold applicable at that time;

the true market value of the property at the relevant historical date;

the amount genuinely paid by the investor;

the source and subsequent movement of the funds;

whether any direct or indirect refund was made;

whether the investor participated in or knew of any manipulation of the valuation process;

whether the investor knew of unlawful conduct by third parties;

the factual basis upon which the Certificate of Conformity was issued;

the accuracy of the statements made in the citizenship application;

the concrete evidence relied upon by the administration; and

whether the measure terminating citizenship is based upon Article 31 or Article 40 TCL.

Disputes concerning the cancellation and withdrawal of Turkish citizenship acquired by investment therefore cannot be examined solely through citizenship law. They frequently require an integrated analysis of administrative law, administrative procedure, real estate law, the law of obligations, consumer law and, where relevant, criminal law.

TD LAW FIRM

TD Law Firm advises and represents investors in disputes concerning the cancellation and withdrawal of Turkish citizenship acquired by investment, cancellation of Certificates of Conformity, allegations concerning fraudulent or inaccurate property valuations, citizenship proceedings arising from investigations involving developers and real estate companies, and related private-law claims.

In these cases, examining the citizenship decision in isolation is frequently insufficient. The administrative measure should be assessed together with the legislation applicable at the date of investment, title deed records, valuation reports, the Certificate of Conformity, banking records, sale agreements, the historical value of the property and, where relevant, documents obtained from related criminal proceedings.

Attorney Murat Can Dolğun

TD Law Firm

Telephone: +90 212 299 44 22

WhatsApp / Mobile: +90 507 475 44 22

E-mail: av.muratcandolgun@gmail.com

Website: https://dolgun.av.tr

Address: Istanbul World Trade Center (IDTM), A2 Block, No. 206, Bakırköy, Istanbul, Türkiye

SOURCES AND REFERENCES

Turkish Citizenship Law No. 5901:
https://www.mevzuat.gov.tr/mevzuatmetin/1.5.5901.pdf

Constitution of the Republic of Türkiye:
https://www.mevzuat.gov.tr/mevzuatmetin/1.5.2709.pdf

Law No. 2575 on the Council of State:
https://www.mevzuat.gov.tr/mevzuatmetin/1.5.2575.pdf

Administrative Procedure Law No. 2577:
https://www.mevzuat.gov.tr/mevzuatmetin/1.5.2577.pdf

Turkish Code of Obligations No. 6098:
https://www.mevzuat.gov.tr/mevzuatmetin/1.5.6098.pdf

Code of Civil Procedure No. 6100:
https://www.mevzuat.gov.tr/mevzuatmetin/1.5.6100.pdf

Enforcement and Bankruptcy Law No. 2004:
https://www.mevzuat.gov.tr/mevzuatmetin/1.3.2004.pdf

Consumer Protection Law No. 6502:
https://www.mevzuat.gov.tr/mevzuatmetin/1.5.6502.pdf

Çiçek Özgür, “Yatırım Yoluyla Kazanılan Türk Vatandaşlığının İptali ve Geri Alınması” [Cancellation and Withdrawal of Turkish Citizenship Acquired Through Investment], Ankara University Faculty of Law Journal, Vol. 75, No. 1, 2026, pp. 741–779:
https://dergipark.org.tr/tr/pub/auhfd/article/1710185

Full text:
https://dergipark.org.tr/en/download/article-file/4918969

Ahmet Dülger, “Taşınmaz Satın Alınmasıyla Türk Vatandaşlığının İstisnai Yoldan Kazanılmasında Değerleme Raporu ve Uygunluk Belgesi Alınması”, İnönü University Faculty of Law Review, Vol. 16, No. 1, 2025, pp. 167–180:
https://dergipark.org.tr/tr/pub/inuhfd/article/1600688

Işıl Egemen Demir, “İdare Hukuku İlkeleri Çerçevesinde Türk Vatandaşlığına Alınma Kararının İptali ve Geri Alınması Kavramları”, Turkish Bar Association Review, No. 139, 2018, pp. 129–164:
https://tbbdergisi.barobirlik.org.tr/ViewPDF-idare-hukuku-ilkeleri-cercevesinde-turk-vatandasligina-alinma-kararinin-iptali-ve-geri-alinmasi-kavramlari-1807

Aslı Bayata Canyaş, “Hukuki Şartlar Oluşmadan Verilmiş Olan Türk Vatandaşlığını Kazanma Kararının Geri Alınmasında Süre Sorunu”, Turkish Bar Association Review, No. 114, 2014, pp. 347–360.

Esra Dardağan Kibar, “Türk Vatandaşlık Mevzuatı ve Güncel Gelişmeler Işığında Vatandaşlığın Kanuniliği İlkesi”, Milletlerarası Özel Hukukta Güncel Meseleler Sempozyumu, Savaş Yayınları, 2019, pp. 3–17.

“Türk Vatandaşlığına Alınma Kararının İptalinde Süre”, Public and Private International Law Bulletin:
https://dergipark.org.tr/tr/pub/iumhmohb/article/383774

“Yabancıların Yatırım Yoluyla Türk Vatandaşlığı Kazanmalarının Hukuki Yönden Değerlendirilmesi ve Yeni Model Önerisi”, Selçuk University Law Review:
https://dergipark.org.tr/tr/pub/suhfd/article/1705055

Council of State, 10th Chamber, E.2022/7637, K.2025/3313, 26 June 2025:
https://hukas.com.tr/ictihat/danistay/10-daire-2022-7637-esas-2025-3313-karar/aa20d570-25fb-4ee9-a4ec-f174f89cdce8

Council of State, 10th Chamber, E.2021/279, K.2025/3174, 23 June 2025:
https://mevzuat.adalet.gov.tr/ictihat/1170303600

Republic of Türkiye Ministry of Justice, 4 August 2026:
https://basin.adalet.gov.tr/bakan-gurlek-687-kisinin-vatandasliginin-iptali-icin-yasal-surec-baslatildi

Anadolu Agency, 24 September 2025:
https://www.aa.com.tr/tr/gundem/muvazaali-gayrimenkul-satisiyla-vatandaslik-saglayan-suc-orgutu-cokertildi/3697125

Anadolu Agency, subsequent 2025 investigation report:
https://www.aa.com.tr/tr/gundem/yabancilara-usulsuz-vatandaslik-kazandiran-suc-orgutune-yonelik-operasyonda-yakalanan-113-supheli-adliyede/3699547

Anadolu Agency, 4 August 2026:
https://www.aa.com.tr/tr/gundem/haksiz-turk-vatandasligi-kazandirdigi-tespit-edilen-suc-orgutune-operasyon-/4017632

Anadolu Agency, 7 August 2026:
https://www.aa.com.tr/tr/gundem/-haksiz-yollarla-turk-vatandasligi-kazandirdigi-belirlenen-suc-orgutu-operasyonunda-32-zanli-tutuklandi/4021485

Turkish Constitutional Court – Individual Application:
https://www.anayasa.gov.tr/tr/bireysel-basvuru/

European Court of Human Rights, Guide on Nationality:
https://ks.echr.coe.int/documents/d/echr-ks/nationality

LEGAL INFORMATION NOTICE

This article has been prepared as of 19 September 2026 for general legal information purposes on the basis of legislation in force, published academic studies, accessible judicial decisions, official announcements and publicly available news sources.

Statements concerning criminal investigations reflect allegations and information made public by the relevant authorities and news sources. An investigation, detention or remand order does not constitute a final criminal conviction. The presumption of innocence applies unless and until a final conviction is entered.

The existence of an investigation concerning a developer, real estate company, intermediary or valuation expert does not, of itself, establish that every investor who dealt with those persons unlawfully acquired Turkish citizenship. Equally, an investor’s good faith does not necessarily preserve citizenship where an objective statutory requirement for acquisition was never satisfied.

Each case must be assessed individually by reference to the date of investment, the legislation then in force, the true economic substance of the investment, the individual conduct of the investor, the administration’s own examination process and the statutory basis of the measure terminating citizenship.

The legal regime governing the liquidation of assets following cancellation of citizenship under Article 33 TCL falls outside the scope of this article and will be examined separately.

This article does not constitute a legal opinion, a guarantee of outcome or individual legal advice in relation to any specific dispute.