Etiket: suspension of execution Turkey

  • Turkish Citizenship Criminal Investigations 2026 | KYOK

    Turkish Citizenship Criminal Investigations 2026 | KYOK

    DOLĞUN AKADEMİ | LEGAL RESEARCH

    Turkish Citizenship Revocation and Criminal Investigations in 2026: Police Statements, Prosecutors, KYOK, Administrative Lawsuits and Defence Rights

    Author: Attorney Murat Can Dolğun – Istanbul Bar Association

    Original Publication: October 22, 2026

    Legal Fields: Criminal Law, Criminal Procedure, Turkish Citizenship Law, Administrative Law, Administrative Litigation and Immigration Law.

    Read this article in Turkish:
    Click here to read the original Turkish version.

    Abstract

    Criminal investigations concerning Turkish citizenship acquired through investment in 2025 and 2026 have brought renewed attention to the relationship between nationality law, criminal liability and administrative judicial review.

    Investigations conducted by the Istanbul Chief Public Prosecutor’s Office have involved allegations of sham real estate transactions, inaccurate or fraudulent property valuation reports, artificial foreign-currency transfers, document forgery, fraud and organised criminal activity.

    These developments have confronted foreign investors who acquired Turkish citizenship in previous years with three separate legal questions.

    The first concerns the investor’s procedural status and possible personal criminal liability. The second concerns whether the original investment genuinely satisfied the statutory requirements for Turkish citizenship. The third concerns the administrative and judicial remedies available if a citizenship cancellation or withdrawal decision is issued.

    Although these questions may arise from the same transactions, they require distinct legal analyses.

    Being investigated as a criminal suspect does not establish guilt or automatically terminate Turkish citizenship. Equally, a prosecutor’s decision not to prosecute does not automatically invalidate a separate administrative decision withdrawing citizenship.

    This article examines police questioning, prosecutorial investigations, the right to counsel, interpretation rights, restrictions on access to investigation files, non-prosecution decisions (KYOK), indictments, acquittals, arrest measures, expert reports, administrative litigation and suspension of execution.

    The research draws upon legislation, official announcements and published Council of State decisions available up to October 22, 2026. It is applicable to all persons who acquired Turkish citizenship through investment or another exceptional naturalisation procedure, regardless of their national origin.

    1. Why Can a Turkish Citizenship-by-Investment File Become the Subject of a Criminal Investigation?

    Acquisition of Turkish citizenship through investment is primarily an administrative-law procedure. The applicant must satisfy the statutory conditions, the relevant institution must determine the eligibility of the investment, and the competent authority must issue the naturalisation decision.

    However, allegations that the supporting documents were falsified, that the investment amount was not genuinely paid, or that an organised arrangement was established to simulate compliance may also give rise to criminal-law questions.

    For example, where a property’s true market value is allegedly below the statutory minimum and an inaccurate appraisal report is knowingly prepared to show a higher value, the dispute may extend beyond a technical disagreement concerning valuation.

    Similarly, investigators may examine whether a bank transfer was fabricated, whether funds were returned through intermediary accounts after an apparent payment, or whether a land registry transaction concealed an agreement inconsistent with the apparent sale.

    Nevertheless, two separate matters must be distinguished: the failure of a transaction to satisfy citizenship legislation and the intentional commission of a criminal offence by a particular individual.

    Under Article 38 of the Turkish Constitution and Article 20 of Turkish Penal Code No. 5237, criminal responsibility is personal.

    Therefore, the existence of a criminal investigation concerning a construction company, property developer or appraisal professional does not establish the guilt of every investor who dealt with that person or organisation.

    2. Developments in Turkish Citizenship Investigations During 2025–2026

    2.1. September 24, 2025: Investigation Into Allegedly Sham Property Transactions

    An operation conducted across 19 Turkish provinces in September 2025 concerned allegations that fictitious real estate transactions had facilitated the acquisition of Turkish citizenship by foreign investors.

    According to publicly reported investigative statements, the allegations included inflated property values, artificial financial movements and subsequent transfers of properties back to previous owners or related parties.

    The investigation raised questions concerning the distinction between a formal property transfer recorded in the land registry and the genuine economic substance of the underlying transaction.

    Source: Anadolu Agency, September 24, 2025.

    2.2. August 4, 2026: Investigation Concerning 687 Individuals

    On August 4, 2026, the Turkish Ministry of Justice announced an investigation coordinated by the Organised Crime Investigation Bureau of the Istanbul Chief Public Prosecutor’s Office.

    The reported allegations concerned properties of comparatively low value allegedly being represented as qualifying high-value investments through inaccurate appraisal reports.

    The Ministry reported detention orders for 90 suspects, the apprehension of 72 suspects and protective measures involving companies and property assets.

    It also announced that legal proceedings had been initiated concerning the cancellation of citizenship acquired by 687 individuals.

    Source: Turkish Ministry of Justice, August 4, 2026.

    Initiating proceedings intended to cancel nationality does not mean that a final individual administrative cancellation decision had already been issued against every affected person.

    2.3. September 21, 2026: The Second-Wave Investigation

    The second-wave investigation announced on September 21, 2026, concerned the review of property transactions and financial records associated with investment-based citizenship acquisitions.

    According to information reported from the Ministry of Interior, the investigation covered 1,070 people, comprising 263 principal investors and 807 family members. Additional processes reportedly concerned 11 persons whose citizenship applications were still pending.

    Reports referred to the work of the Istanbul Police Department’s Anti-Migrant Smuggling and Border Gates Branch, expert examinations and analyses by the Financial Crimes Investigation Board, known as MASAK.

    On September 25, 2026, Anadolu Agency reported that 33 suspects had been remanded in custody and that other suspects were subject to judicial supervision measures.

    Sources:
    Anadolu Agency, September 21, 2026;
    Anadolu Agency, September 25, 2026.

    Arrest, pretrial detention and judicial supervision are criminal procedural measures. They do not constitute final convictions. The presumption of innocence continues to apply to all persons under investigation or prosecution.

    For a broader examination, see our research on the official citizenship revocation figures and international coverage in 2026.

    4. Why Does the Distinction Between Suspect, Witness, Complainant and Victim Matter?

    4.1. Suspect

    Under Article 2 of Criminal Procedure Code No. 5271, a suspect is a person under suspicion of committing a criminal offence during the investigation stage.

    Being questioned as a suspect means that allegations concerning the person’s conduct are being investigated. It does not establish criminal guilt.

    Suspects enjoy procedural rights including information about the allegation, legal representation, the right to remain silent, the opportunity to request the collection of favourable evidence and access to interpretation when legally required.

    4.2. Witness

    A witness is a person believed to possess information relevant to the investigated events.

    The procedural obligations of witnesses differ from those of suspects. However, protections concerning answers that could expose the person or protected relatives to criminal prosecution must also be considered.

    Questioning a person as a witness where the circumstances require treatment as a suspect may give rise to procedural concerns affecting defence rights.

    4.3. Complainant and Victim

    A complainant is a person reporting or complaining about an alleged criminal offence. A victim is a person directly affected by conduct infringing the legal interest protected by the criminal provision.

    Some foreign investors involved in citizenship investigations may themselves have been harmed by misleading conduct of property developers, agents or intermediaries.

    For example, an investor may have genuinely transferred the qualifying funds but later discovered that a developer or intermediary supplied false information concerning the property or investment documentation.

    Whether that investor qualifies as a victim or person harmed by the offence requires examination of the specific allegations.

    Even where an interview record describes the investor as a victim, this does not automatically resolve every administrative citizenship question.

    4.4. Different Procedural Roles Within One Investigation

    An individual may have different procedural positions concerning separate alleged acts within a broader factual investigation.

    The person’s precise status should therefore be determined for each allegation rather than inferred solely from the general subject of the case.

    5. Which Criminal Offences May Arise in Turkish Citizenship Investigations?

    Several offences under Turkish Penal Code No. 5237 have been mentioned in reports concerning the investigations.

    Nevertheless, the presence of an offence in an investigation file does not prove that its statutory elements are satisfied in relation to a particular investor.

    5.1. Establishing or Participating in a Criminal Organisation – Article 220

    Article 220 concerns organisations established for the purpose of committing criminal offences.

    The fact that multiple companies participated in property transactions, or that several investors used the same intermediary, does not itself establish the existence of a criminal organisation or membership by an investor.

    The organisation’s structure, purpose, continuity, relevant characteristics and the individual’s connection with it must be assessed under the applicable statutory elements.

    5.2. Migrant Smuggling – Article 79

    Article 79 regulates migrant smuggling.

    The involvement of a police unit responsible for investigating migrant smuggling does not mean that every transaction or individual mentioned in the investigation necessarily satisfies the elements of that offence.

    Ordinary assistance with citizenship applications should not automatically be equated with the conduct criminalised by Article 79. The actual statutory elements must be established.

    5.3. Fraud and Aggravated Fraud – Articles 157 and 158

    Fraud involves deceptive conduct and the obtaining of an unlawful benefit under the relevant legal conditions. Aggravated forms of fraud are separately regulated under Article 158.

    In citizenship-related investigations, allegedly inaccurate investment values, artificial transactions and misleading documents may lead investigators to consider fraud offences.

    However, the alleged deceptive act, its target, the resulting benefit and harm, and the individual’s role must be determined.

    The failure to satisfy an administrative investment condition does not automatically constitute aggravated fraud.

    5.4. Forgery of Official Documents – Article 204

    Article 204 concerns forgery involving official documents.

    In citizenship and real estate cases, it is important to determine whether the relevant document legally qualifies as an official document, the nature of the alleged falsification and the knowledge and conduct of the person said to have used it.

    5.5. Forgery of Private Documents – Article 207

    Allegations concerning private documents require separate consideration of their legal nature, authenticity, use and the person’s conduct.

    Not every erroneous private contract or inaccurate commercial communication constitutes criminal forgery.

    5.6. False Statements in the Preparation of Official Documents – Article 206

    Article 206 addresses certain false statements made to a public official authorised to prepare an official document.

    Allegedly misleading declarations during a citizenship application may be examined under this provision where the statutory elements are present.

    A document containing an inaccurate result, however, does not automatically establish that the applicant committed this particular offence.

    5.7. Multiple Charges Arising from the Same Transaction

    A series of transactions may generate allegations involving several criminal provisions.

    Whether each offence is legally established, whether the provisions governing concurrence apply and how the individual’s conduct is connected to the alleged acts require separate analysis.

    The essential question is not how many offence names appear in the investigation, but which particular criminal act is attributed to the individual and on what evidence.

    6. What Are the Suspect’s Rights During Police and Prosecutorial Questioning?

    The questioning of a suspect is subject to statutory safeguards. Article 147 of Criminal Procedure Code No. 5271 establishes fundamental rules governing the taking of statements and judicial interrogation.

    6.1. The Right to Be Informed of the Accusation

    The suspect must be informed of the alleged offence.

    Knowing only that a general citizenship investigation exists may be insufficient to understand the actual conduct alleged against the individual.

    For example, is the investor alleged to have prepared a fraudulent appraisal report, knowingly used such a report, participated in an artificial banking arrangement or merely purchased property from the company being investigated?

    The nature of the defence depends on those distinctions.

    6.2. The Right to Legal Counsel

    Article 149 allows suspects and defendants to receive assistance from one or more defence lawyers during investigation and prosecution, subject to applicable procedural provisions.

    The presence of defence counsel during questioning is an important safeguard. Article 150 also governs situations in which appointment of a defence lawyer is mandatory.

    Acquiring Turkish citizenship through naturalisation does not diminish the individual’s criminal procedural rights.

    6.3. The Right to Remain Silent

    Under Article 147, the suspect must be informed of the legal right not to make statements concerning the alleged offence.

    Exercising that right does not establish guilt and must not itself be treated as proof of criminal conduct.

    The decision whether to provide a statement should be considered with reference to the available evidence and the individual’s particular circumstances.

    6.4. The Right to Request Favourable Evidence

    A suspect may request the collection of specific evidence capable of supporting the defence.

    In citizenship-investment cases, such evidence may include bank statements, SWIFT records, property purchase contracts, title deeds, historical appraisal reports, communications with developers and proof that the consideration was not refunded.

    6.5. Accuracy of the Written Statement

    Discrepancies between what a person actually says and what appears in the written interview record can have serious consequences.

    This is particularly important when statements are interpreted from another language.

    Dates, monetary amounts, the sequence of transactions and the meaning of technical explanations should be recorded accurately.

    Requests to correct errors or omissions should be raised before the interview record is finalised and signed.

    6.6. Police Statements Taken Without Defence Counsel

    Article 148(4) provides that a statement obtained by the police in the absence of defence counsel cannot form the basis of a judgment unless subsequently confirmed by the suspect or defendant before a judge or court.

    This rule illustrates that the right to counsel is not merely a formality. It has substantive consequences for the admissibility and evaluation of criminal evidence.

    7. Interpreter Rights of Foreign Investors Who Do Not Speak Turkish

    Effective exercise of defence rights requires a person to understand the accusations and questions addressed to them.

    Article 202 of the Criminal Procedure Code regulates interpretation rights in the circumstances prescribed by law.

    Speaking English, Arabic, Russian, Chinese, Persian or another language does not create any legal disadvantage. The relevant question is whether the person can understand and participate effectively in the proceedings.

    7.1. Incorrect Translation of Legal and Financial Terminology

    Citizenship investigations may involve technical expressions such as genuine payment, repayment, sham transaction, property appraisal, certificate of conformity and forged document.

    An inaccurate interpretation may materially change the meaning of the person’s statement.

    For example, “I did not determine the property’s value” is different from “I did not know the property’s value.”

    Likewise, “The seller did not refund my payment” is not equivalent to “I do not know the seller’s banking transactions.”

    7.2. Challenging an Incorrect Interpretation

    Where the individual believes a statement has been inaccurately translated, the concern should be raised during questioning and, where appropriate, recorded in the official minutes.

    Ordinary conversational ability in a foreign language should not automatically be equated with the ability to understand complex legal and financial questions in that language.

    8. Can a Lawyer Examine the Investigation File? What Is a Restriction Order?

    One recurring problem in citizenship investigations is the existence of confidentiality rules or a judicial restriction on inspection of the investigation file.

    8.1. Confidentiality of Criminal Investigations

    Article 157 of the Criminal Procedure Code governs confidentiality during the investigation phase.

    However, general investigative confidentiality and a specific restriction on defence counsel’s file-inspection rights are separate legal matters.

    8.2. Article 153 and File Inspection

    Article 153 regulates the defence lawyer’s entitlement to examine investigation records and obtain copies of documents.

    Under specified statutory conditions and procedures, access to certain materials may be restricted.

    The existence of a restriction order does not eliminate every defence right or prevent counsel from undertaking all legal work.

    Documents excluded from the restriction and other statutory defence safeguards must be evaluated separately.

    8.3. Investigation Files Not Visible Through UYAP

    The absence of a file from an individual’s accessible UYAP or e-Devlet interface does not conclusively establish that no criminal investigation exists.

    Access may depend on the investigation’s status, the person’s procedural capacity, confidentiality rules and technical access permissions.

    8.4. Representation and Authorisation

    The ability to make an initial legal enquiry, formally represent an individual in an investigation and obtain copies of confidential documents are different matters.

    Appropriate authorisation and procedural status are important. Nevertheless, the appointment of defence counsel in criminal proceedings must be distinguished from the formal representation requirements applicable to an administrative citizenship file.

    9. Arrest, Police Custody, Pretrial Detention and Judicial Supervision

    Foreign investors who become concerned about citizenship-related criminal investigations often ask whether they may be arrested upon entering Türkiye.

    However, the existence of an investigation does not automatically result in arrest, police custody or pretrial detention.

    9.1. Summons for Questioning

    Under Article 145 and related provisions, a person may be summoned to give a statement.

    A summons and an arrest warrant are different procedural measures.

    9.2. Arrest and Apprehension

    Measures involving the apprehension of an individual require the relevant statutory conditions.

    The appearance of a person’s name in a criminal investigation does not by itself establish that an arrest warrant has been issued.

    9.3. Police Custody

    Police custody is a temporary measure that may follow apprehension under the conditions prescribed by law.

    The person concerned is entitled to applicable procedural safeguards, including access to counsel and legally required notifications.

    9.4. Pretrial Detention

    Under Article 100, pretrial detention requires consideration of concrete evidence indicating strong suspicion, statutory grounds for detention and proportionality.

    Detention is a preventive criminal procedural measure, not a criminal sentence.

    9.5. Judicial Supervision

    Article 109 regulates judicial supervision as an alternative to detention in the circumstances prescribed by law.

    Depending on the specific order, such measures may include restrictions on leaving the country, reporting obligations or requirements not to leave one’s residence.

    Accordingly, the absence of pretrial detention does not necessarily mean that no travel restrictions exist.

    9.6. Assessing Border-Control Risks

    Before travelling to Türkiye, the individual’s current citizenship status, valid travel documents, any judicial protective measures and applicable immigration rules should be examined separately.

    An ongoing investigation does not establish that the person will inevitably be detained at the border. However, an existing arrest warrant or another applicable judicial measure may have significant consequences for travel.

    10. How Are Bank Records, Title Deeds, Property Valuations and MASAK Reports Evaluated?

    One central issue in citizenship-by-investment investigations is whether the investment appearing in official documents corresponds to a genuine economic transaction.

    10.1. Bank Transfers

    Bank receipts, SWIFT messages, account statements, transfer instructions and foreign-exchange transaction records may provide important evidence that a qualifying investment was actually made.

    Nevertheless, a single receipt may not fully explain the economic nature of the payment.

    Investigators may examine whether funds transferred to the seller were subsequently returned to the investor, transferred to related parties or circulated through additional accounts.

    10.2. Land Registry and Sale Documents

    Registration of a property transfer is an important legal fact.

    However, investigators may separately examine whether the parties reached an undisclosed arrangement inconsistent with the apparent sale or whether the transaction was genuine in economic substance.

    10.3. Valuation Reports

    A real estate appraisal is a significant technical document when assessing the investment threshold applicable to property-based citizenship.

    Yet comparing a historic valuation with current property prices is not necessarily sufficient.

    The relevant examination should address the investment date, the property’s physical and legal characteristics at that time, comparable transactions, the project’s development stage and the market conditions then prevailing.

    10.4. MASAK Financial Analyses

    The Financial Crimes Investigation Board may analyse banking transactions, financial patterns and relationships between accounts.

    However, identification of a suspicious financial transaction does not itself conclusively establish that a particular person committed a crime or that every related payment was fictitious.

    Financial findings should be assessed together with other evidence and the specific elements of the alleged offence.

    10.5. Digital Evidence

    Emails, messaging records, draft contracts, payment instructions and electronic files may be relevant.

    Nevertheless, the source, integrity, method of collection and context of electronic evidence must be considered.

    An isolated screenshot, for example, may fail to show the full conversation or the circumstances in which a message was exchanged.

    11. How Can Expert Reports Be Examined or Challenged?

    Expert evidence is particularly important in citizenship investigations involving property valuation and financial records.

    11.1. The Scope and Methodology of the Expert Report

    Evaluation should address not only the expert’s conclusion but also the methodology employed.

    Does the report determine the historical value of an individual apartment, the average value of an entire parcel, the current market value or another technical measure?

    These distinctions may materially affect whether a historic investment satisfied the relevant legal threshold.

    11.2. Independent Expert Opinions

    Article 67(6) of the Criminal Procedure Code permits scientific opinions from specialists regarding matters relevant to the investigation or prosecution.

    Depending on the circumstances, an investor may obtain independent professional assessments from banking specialists, financial analysts, property valuation experts or other qualified professionals.

    However, a privately commissioned expert opinion and a report prepared by a court-appointed or prosecution-appointed expert do not have identical procedural status.

    11.3. Historical Value Versus Current Market Value

    Where property was acquired in 2022, a valuation conducted in 2026 must clearly identify the relevant valuation date.

    A determination of the property’s current market value does not, by itself, establish whether the investment satisfied the statutory requirements in 2022.

    Historical valuation should be distinguished from the assessment of the property’s present value.

    11.4. Preservation of Evidence and Expert Assessment

    Articles 400 and following of Civil Procedure Code No. 6100 govern preservation of evidence under specific civil procedural conditions.

    An expert examination within a criminal investigation and a separate civil proceeding for preservation of evidence are not the same legal procedure.

    Depending on the issues to be proved, both may be relevant for different purposes.

    The selection of an appropriate mechanism depends on the legal nature of the dispute and the evidence requiring preservation.

    For further examination, see Can a Genuine Investor Lose Turkish Citizenship? Historical Valuation, Banking Evidence and Judicial Protection.

    12. What Is KYOK? When Can a Prosecutor Decide Not to Prosecute?

    KYOK is the commonly used Turkish abbreviation for kovuşturmaya yer olmadığına dair karar, meaning a decision that there is no ground for criminal prosecution.

    Under Article 172 of Criminal Procedure Code No. 5271, the public prosecutor issues a non-prosecution decision if the investigation does not produce evidence sufficient to justify bringing a public prosecution or if prosecution is legally impossible.

    12.1. Insufficient Evidence to Establish the Required Suspicion

    One purpose of an investigation is to determine whether the evidence establishes sufficient suspicion to bring a criminal case.

    For example, where there is insufficient evidence that an investor participated in preparing a fraudulent appraisal or knowingly used a forged document, that evidentiary deficiency may be significant to the prosecutorial decision.

    However, it would be inappropriate to guarantee KYOK merely because one or two particular documents support the investor’s account.

    12.2. Legal Impossibility of Prosecution

    Article 172 also addresses situations in which prosecution is not legally possible.

    Accordingly, not every KYOK decision necessarily amounts to a conclusive factual finding that the alleged conduct never occurred. The actual reasons given by the prosecutor must be examined.

    12.3. KYOK Is Not an Acquittal

    KYOK is a prosecutorial decision issued during the investigation stage.

    It is legally distinct from an acquittal delivered by a criminal court following judicial proceedings.

    12.4. Objections to a Non-Prosecution Decision

    Article 173 provides a specific objection mechanism for a person harmed by the alleged offence, subject to the applicable statutory conditions.

    As a general rule, the person entitled to object may apply to the competent criminal judgeship of peace within two weeks following notification of the decision, subject to statutory exceptions and any applicable special rules.

    This is a remedy available to eligible persons harmed by the offence, not an objection mechanism automatically exercised by the suspect.

    12.5. New Evidence Following KYOK

    Article 172(2) regulates the conditions governing subsequent prosecution concerning the same act, including new evidence and the applicable judicial authorisation requirements.

    Consequently, the legal effects of subsequently discovered evidence must be assessed under the statutory framework.

    13. Does a KYOK Decision Prevent the Cancellation or Withdrawal of Turkish Citizenship?

    This is one of the most frequently misunderstood issues in citizenship law.

    A non-prosecution decision does not automatically prevent an administrative authority from examining the legality of a previous citizenship acquisition decision.

    The criminal-law question of whether a person committed a particular offence differs from the administrative-law question of whether the objective statutory conditions for citizenship were fulfilled.

    13.1. Scenario One: Genuine Investment and No Criminal Liability Established

    An investor may have genuinely paid the required purchase price, transferred the funds through the banking system, retained ownership of the property and received no refund.

    The investigation may fail to establish sufficient evidence that the investor knowingly participated in forgery, artificial transactions or other alleged crimes.

    In that situation, KYOK is an important procedural outcome concerning personal criminal liability.

    Its reasoning and supporting findings may also be relevant to an administrative citizenship dispute.

    Nevertheless, compliance with the objective statutory requirements for citizenship must still be assessed.

    13.2. Scenario Two: No Crime Established, but the Investment Requirement Was Not Fulfilled

    An investor may receive KYOK because the evidence does not sufficiently establish knowing participation in criminal conduct.

    However, the administration may separately contend that the investment did not satisfy the required legal amount or another objective condition at the date of acquisition.

    The termination of criminal proceedings does not automatically prevent an administrative assessment under Article 40 of Law No. 5901.

    13.3. Scenario Three: The Prosecutor’s Findings Contradict the Administrative Grounds

    Evidence examined in criminal proceedings may demonstrate that an important factual allegation relied upon by the administration was incorrect.

    Where the reasoning of a non-prosecution decision directly conflicts with the factual premise of an administrative withdrawal decision, that contradiction may be significant in administrative litigation.

    The administrative court must nevertheless reach its determination on the basis of the applicable legal provisions, the contested administrative act and the evidentiary record before it.

    13.4. Does KYOK Automatically Restore Citizenship?

    No.

    Where an administrative citizenship cancellation or withdrawal decision has already been issued, it remains necessary to consider the appropriate procedures for its withdrawal, amendment or judicial annulment.

    KYOK may form part of the evidence supporting those proceedings. It is not itself an administrative court judgment cancelling the nationality decision.

    14. What Happens If the Prosecutor Files an Indictment?

    Under Article 170 of the Criminal Procedure Code, where the evidence obtained during the investigation establishes sufficient suspicion for public prosecution, the public prosecutor prepares an indictment.

    The indictment is submitted to the competent criminal court. The prosecution stage begins following acceptance of the indictment in accordance with the applicable procedure.

    14.1. An Indictment Is Not Proof of Guilt

    An indictment is the formal document through which the prosecutor submits criminal allegations for judicial examination.

    Its acceptance does not constitute a conviction. The court must examine the evidence and defence during the proceedings.

    14.2. Distinguishing Criminal Allegations

    An indictment alleging document forgery or fraud does not, by itself, settle the different question of whether the investment objectively met the nationality requirements.

    Each alleged offence must be examined according to its own statutory elements and the defendant’s individual conduct.

    14.3. Must the Criminal Trial End Before Citizenship Can Be Withdrawn?

    Article 40 of Law No. 5901 does not generally make a final criminal conviction a mandatory prerequisite for the withdrawal of a citizenship decision granted without the necessary statutory conditions.

    Consequently, the competent administration may be required to examine the original citizenship conditions separately from the outcome of the criminal prosecution.

    Nevertheless, the sufficiency, accuracy and legality of the facts relied upon by the administration remain subject to judicial review.

    15. How Does a Criminal Acquittal Affect an Administrative Citizenship Case?

    An acquittal is a judgment delivered by a criminal court in accordance with criminal procedure.

    Not all acquittals rest on the same legal reasoning. Article 223 of the Criminal Procedure Code provides for acquittal in circumstances that may concern the absence of a criminal offence, the fact that the defendant did not commit the act or insufficient proof of criminal guilt, among other statutory grounds.

    15.1. An Acquittal Does Not Automatically Annul Administrative Withdrawal

    If the administration has already issued a citizenship withdrawal decision, a criminal acquittal does not automatically extinguish that separate administrative act.

    However, the criminal court’s findings regarding material facts may be significant where the administration relied on allegations involving the same conduct.

    15.2. The Presumption of Innocence

    The presumption of innocence is protected under Article 38 of the Turkish Constitution and Article 6(2) of the European Convention on Human Rights.

    Administrative or public statements that categorically treat a person as criminally guilty without a final conviction may, depending on their wording and circumstances, raise separate concerns under this principle.

    Nevertheless, an administrative assessment of objective citizenship conditions does not necessarily amount to a criminal finding of guilt.

    16. Cancellation and Withdrawal Under Turkish Citizenship Law No. 5901

    Articles 31 and 40 are of particular importance when allegations arising from criminal investigations are also examined in nationality proceedings.

    16.1. Article 31: False Declarations and Concealment of Material Facts

    Article 31 concerns cancellation of a citizenship acquisition decision where the acquisition resulted from false declarations by the individual or concealment of material circumstances relevant to the original decision.

    The analysis must determine which declaration was allegedly false, what material fact was concealed and how that conduct affected the acquisition of Turkish citizenship.

    A valuation report prepared by an independent professional and subsequently found to be inaccurate must be distinguished from an investor knowingly using a report that they understand to be fraudulent.

    16.2. Article 40: Decisions Granted Without the Required Legal Conditions

    Article 40 provides for the withdrawal of decisions concerning citizenship acquisition or loss where the required legal conditions were absent or the decision was issued in duplicate.

    The essential question is whether the necessary conditions existed at the time the original nationality decision was made.

    Therefore, the absence of proven criminal liability does not, in every case, suffice to establish that citizenship cannot be withdrawn under Article 40.

    Conversely, the administration must support a withdrawal decision with legally relevant and adequately established facts demonstrating that the original statutory requirements were not met.

    16.3. Different Temporal Consequences

    Under Article 32, a cancellation decision takes effect from the date of that decision and also applies to spouses and children who acquired Turkish citizenship dependently through the affected individual.

    For withdrawal, Article 66 of the Regulation on the Implementation of the Turkish Citizenship Law provides that the withdrawn decision becomes ineffective from the date of the original decision.

    The difference may affect family relationships, nationality acquired through birth, historical transactions and other legal statuses.

    For a detailed examination, see our earlier research on cancellation and withdrawal of Turkish citizenship acquired through investment.

    17. What Do the Council of State’s 2026 Decisions Show About Criminal and Administrative Law?

    17.1. Council of State, 10th Chamber, E.2024/3835, K.2026/324, February 4, 2026

    This case concerned withdrawal of citizenship previously acquired through exceptional naturalisation, with the administration relying on national-security and public-order considerations.

    The Council of State emphasised the need for concrete, sufficient and serious factual grounds supporting a decision to withdraw citizenship.

    The court also considered the distinction between circumstances existing at the date of naturalisation and subsequent events unrelated to the original statutory conditions.

    In light of the circumstances in the relevant file, the court annulled the withdrawal decision.

    Legal significance: Administrative authority to withdraw citizenship does not eliminate the need to establish an adequate factual and legal basis for the measure.

    Read the Council of State Decision E.2024/3835, K.2026/324.

    17.2. Council of State, 10th Chamber, E.2024/405, K.2026/361, February 5, 2026

    This case concerned an individual who acquired Turkish citizenship through property investment.

    The relevant authorities determined that documents concerning the foreign-exchange purchase transactions had been inaccurately prepared, and the investment certificate of conformity was subsequently cancelled.

    The Council of State examined whether the statutory requirements for acquiring citizenship through investment had actually been fulfilled.

    The absence of a separate legal challenge to the certificate’s cancellation was also significant to the assessment.

    The court dismissed the action challenging the withdrawal of citizenship.

    Legal significance: The objective legal conditions of the investment may remain decisive in administrative citizenship proceedings independently of questions concerning the investor’s personal criminal liability.

    Read the Council of State Decision E.2024/405, K.2026/361.

    17.3. Comparative Legal Assessment

    These decisions do not establish contradictory legal principles. They demonstrate the application of the nationality framework to different factual circumstances.

    Both concern the existence of the legal conditions required at the time of the original citizenship acquisition.

    In one case, the factual grounds for withdrawal were considered inadequate. In another, the court accepted that the necessary investment conditions had not been established as fulfilled in the circumstances.

    Accordingly, allegations originating in a criminal investigation must be supported by legally relevant facts concerning the citizenship acquisition before they can justify the applicable administrative measure.

    The finality and subsequent appellate history of each decision must be checked in any individual proceeding.

    18. Administrative Litigation Against Turkish Citizenship Cancellation or Withdrawal

    18.1. The Competent Court

    The court with jurisdiction depends on which authority issued the administrative act being challenged.

    Under Article 24 of Council of State Law No. 2575, the Council of State acts as a court of first instance in annulment proceedings challenging Presidential decisions.

    Different administrative acts, such as cancellation of an investment certificate by another authority, may require proceedings before a different competent administrative court.

    18.2. Filing Deadlines

    Under Article 7 of Administrative Judicial Procedure Law No. 2577, the general judicial filing period before the Council of State and administrative courts is 60 days unless a different statutory period applies.

    The applicable starting date must be evaluated with reference to the administrative act, notification requirements and the circumstances of the particular case.

    For individuals living abroad, previously completed notifications to authorised legal representatives may be particularly important.

    18.3. Administrative Applications

    A qualifying administrative application submitted in accordance with Article 11 may affect the running of the judicial filing period.

    However, not every enquiry, request for a file copy or application for information automatically suspends the deadline.

    18.4. Suspension of Execution

    Under Article 27, filing an administrative annulment action does not automatically suspend execution of the contested decision.

    A suspension-of-execution request requires the court to assess the cumulative legal conditions, including manifest unlawfulness and damage that would be difficult or impossible to remedy.

    Consequences affecting passports, residence, family life, professional activity and business management may be relevant to that assessment.

    Nevertheless, such consequences do not guarantee that interim relief will be granted.

    18.5. Use of Criminal Evidence in Administrative Litigation

    Lawfully obtained expert reports, banking analyses, interview records and other evidence from criminal proceedings may be relevant in administrative litigation under the applicable procedural rules.

    Where criminal evidence contradicts a material allegation relied upon by the administration, identifying and explaining that inconsistency may be important.

    However, restrictions arising from investigation confidentiality, personal-data protection and rules concerning the lawful acquisition of evidence must be respected.

    19. How Should Criminal and Administrative Citizenship Proceedings Be Coordinated?

    An investor may face criminal proceedings and administrative review arising from the same property transaction.

    Handling those processes without consideration of their factual overlap may create risks of inconsistent explanations, incomplete evidence and missed procedural deadlines.

    However, coherent representation does not mean mechanically submitting the same statements in every proceeding. Each legal process has distinct questions, procedural safeguards and evidentiary requirements.

    19.1. Establish the Current Official Status

    The existence of a criminal investigation, the competent prosecution office, the individual’s procedural capacity and any questioning or protective measures should be established to the extent legally possible.

    Separately, the existing citizenship status, investment conformity documents and any adverse administrative decisions must be examined.

    19.2. Prepare a Chronology of the Investment

    The relevant dates should be organised chronologically, including contract execution, banking transactions, title deed transfer, appraisal, certificate of conformity, citizenship application, naturalisation and subsequent administrative or criminal measures.

    19.3. Identify Individual Conduct

    The analysis must distinguish acts performed personally by the investor from documents prepared by third parties and representations made by intermediaries.

    Personal conduct is central to criminal liability, while administrative law additionally requires consideration of the objective legal conditions of the citizenship acquisition.

    19.4. Preserve Documents and Financial Evidence

    Historical bank statements, SWIFT records, old valuation reports, title deed documents, correspondence and contracts may become difficult to retrieve several years after a transaction.

    Lawful collection and preservation of original documents, transaction histories and relevant digital records are therefore important.

    19.5. Distinguish Technical Findings from Criminal Intent

    The historical value of a property is a technical valuation question.

    Whether a particular investor knowingly participated in criminal forgery or fraud is a separate legal question.

    An expert report may be important evidence, but does not automatically establish the investor’s intention or all the required elements of a criminal offence.

    19.6. Protect Independent Administrative Deadlines

    Awaiting the conclusion of a criminal investigation does not automatically suspend the filing period for an administrative lawsuit challenging a citizenship decision.

    Where an individual decision has already been issued, the available administrative applications and judicial deadlines require independent attention.

    20. Frequently Asked Questions About Turkish Citizenship and Criminal Investigations

    Does a criminal investigation mean my Turkish citizenship has been cancelled?

    No. A criminal investigation and an individual administrative decision terminating citizenship are different legal matters.

    I have been summoned to the police. Does an arrest warrant exist?

    A summons does not automatically establish the existence of an arrest warrant. Any applicable judicial measures require separate verification.

    Can I have a lawyer present during questioning?

    Yes. Suspects are entitled to the assistance of defence counsel under the relevant provisions of the Criminal Procedure Code, including Articles 149 and 150.

    I do not speak Turkish. Can I request an interpreter?

    Interpretation assistance is available under the applicable legal conditions. Article 202 governs relevant interpreter rights.

    Does a file-access restriction mean that my lawyer cannot obtain any information?

    No. The scope of the restriction and the applicable statutory exceptions must be evaluated separately.

    Will KYOK guarantee that I retain Turkish citizenship?

    No. KYOK concerns criminal prosecution, whereas compliance with the objective legal requirements for nationality requires a separate administrative assessment.

    Can a KYOK decision support my citizenship case?

    Yes, potentially. Its factual findings may be relevant where they concern allegations relied upon by the administration.

    Will an acquittal automatically reverse a citizenship withdrawal?

    No. Administrative withdrawal must be addressed through the appropriate administrative or judicial mechanisms.

    I did not prepare the appraisal report. Can I still face criminal liability?

    Criminal liability depends on the individual’s conduct and the statutory elements of the alleged offence. A third party’s conduct cannot automatically be attributed to the investor.

    I genuinely paid for the property. Is that enough?

    Genuine payment is important evidence, but the property, investment amount, applicable historical rules and other statutory conditions must also be assessed.

    Can I bring an administrative case while the criminal investigation is ongoing?

    Where an administrative act exists and the legal conditions for judicial review are satisfied, completion of the criminal investigation is not necessarily required.

    Does filing a citizenship lawsuit automatically suspend the administrative decision?

    No. A separate suspension-of-execution decision may be necessary under Article 27 of Administrative Judicial Procedure Law No. 2577.

    Is every purchaser from an investigated developer considered a suspect?

    No. A criminal investigation concerning a developer does not establish that every purchaser has the same procedural status.

    Does living abroad stop a Turkish criminal investigation?

    No. Residence outside Türkiye does not automatically terminate an investigation. The procedures for taking statements and other measures depend on the applicable legal framework.

    Can legal preparation begin before any citizenship withdrawal decision is issued?

    Depending on the circumstances, it may be possible to verify official status, preserve documents, examine investment compliance and prepare relevant legal or technical submissions.

    21. Conclusion: Criminal Liability, Administrative Legality and Citizenship Status Require Separate Examination

    The citizenship investigations conducted in 2025 and 2026 demonstrate the complex consequences that allegations concerning investment transactions may produce under Turkish criminal and administrative law.

    Claims involving fraudulent property valuation reports, sham sales, artificial currency transfers, document forgery and fraud require serious legal investigation.

    Nevertheless, personal criminal liability and fulfilment of the objective statutory requirements for citizenship are separate matters.

    Criminal responsibility is personal. Alleged unlawful conduct by a developer, appraiser, company or intermediary does not automatically establish that every investor dealing with that person participated in a criminal offence.

    Conversely, a decision not to prosecute or the absence of a criminal conviction does not itself prove that all investment requirements were satisfied at the date of naturalisation.

    The distinction between Articles 31 and 40 of Law No. 5901 is central. Article 31 addresses cancellation where citizenship resulted from false declarations or concealment of material facts attributable to the individual. Article 40 addresses withdrawal of decisions issued without the required statutory conditions or as duplicates.

    These legal mechanisms have distinct conditions, consequences and forms of judicial review.

    The Council of State’s published decisions in 2026 also demonstrate that citizenship withdrawal requires legally relevant and adequately established factual grounds. Where the underlying statutory conditions were not fulfilled, withdrawal may be found lawful; where those conditions are not properly established, the administrative act may be annulled.

    For an investor affected by a criminal investigation, the appropriate starting point is to determine the nature of the allegations and procedural status, reconstruct the genuine economic transaction, examine the citizenship file, identify any existing adverse administrative decision and preserve the relevant statutory filing deadlines.

    The central legal principle is that personal criminal responsibility and administrative review of objective nationality requirements cannot be substituted for one another. Effective legal protection requires these questions to be considered together, but under their respective statutory standards.

    23. Legislation, Case Law and References

    A. Constitutional and Statutory Sources

    1. Constitution of the Republic of Türkiye, particularly Articles 36, 38, 66 and 125. Constitutional Court – Official Text.
    2. Turkish Citizenship Law No. 5901, particularly Articles 12, 31, 32, 40 and 41. Official Legislation.
    3. Criminal Procedure Code No. 5271, particularly Articles 2, 67, 100, 109, 145, 147, 148, 149, 150, 153, 157, 170, 172, 173, 202 and 223. Official Legislation.
    4. Turkish Penal Code No. 5237, particularly Articles 20, 79, 157, 158, 204, 206, 207 and 220. Official Legislation.
    5. Administrative Judicial Procedure Law No. 2577, particularly Articles 7, 8, 11 and 27. Published Statutory Text.
    6. Council of State Law No. 2575, particularly Article 24.
    7. Civil Procedure Code No. 6100, particularly Article 400 and following provisions.
    8. Regulation on the Implementation of the Turkish Citizenship Law, particularly Articles 20 and 66.
    9. European Convention on Human Rights, Article 6(2).

    B. Council of State Decisions

    1. Council of State, 10th Chamber, February 4, 2026, E.2024/3835, K.2026/324. Full Decision.
    2. Council of State, 10th Chamber, February 5, 2026, E.2024/405, K.2026/361. Full Decision.
    3. Council of State, 10th Chamber, December 30, 2025, E.2025/6295, K.2025/7133. Notification and time-bar issues. Full Decision.

    C. Official Announcements and News Reporting

    1. Turkish Ministry of Justice, August 4, 2026. Official Announcement Concerning 687 Individuals.
    2. Anadolu Agency, September 24, 2025. Investigation Into Sham Real Estate Transactions.
    3. Anadolu Agency, September 21, 2026. Second-Wave Citizenship Investigation.
    4. Anadolu Agency, September 25, 2026. Pretrial Detention and Judicial Supervision Measures.

    Methodological Note: Statements attributed to investigative or administrative authorities are presented as official allegations or reported findings, not automatically as final judicial determinations. Each criminal allegation and citizenship decision requires individual consideration. Statutory amendments and subsequent appellate decisions must be checked when applying this research to a particular case.

    About the Author

    Attorney Murat Can Dolğun
    Istanbul Bar Association – Registration No. 75860
    TD Law Firm & Legal Consultancy
    Lecturer in Law – Istanbul University-Cerrahpaşa

    Practice Areas: Turkish Citizenship Law, Immigration Law, Criminal Defence, Administrative Litigation, Private International Law, Real Estate Disputes and Foreign Investment.

    Contact Information

    Office: Istanbul World Trade Center (IDTM), Block A2, Office 206, Yeşilköy, Bakırköy, Istanbul, Türkiye.

    Telephone: +90 212 299 44 22
    WhatsApp: +90 507 475 44 22
    Email: av.muratcandolgun@gmail.com
    Website: dolgun.av.tr

    Legal Disclaimer: This article is prepared for general legal and academic information only. It does not constitute advice concerning any specific criminal or administrative case, nor does it guarantee non-prosecution, acquittal, preservation or restoration of Turkish citizenship. The applicable legislation, individual investigation file, administrative records, evidence and procedural deadlines must be examined in each case.

    © 2026 DOLĞUN AKADEMİ | ATTORNEY MURAT CAN DOLĞUN

  • Turkish Citizenship Revocation 2026: Latest Updates, 1,070 Cases and Legal Remedies

    Turkish Citizenship Revocation 2026: Latest Updates, 1,070 Cases and Legal Remedies

    Last updated: October 8, 2026

    Author: Attorney Murat Can Dolğun – Istanbul Bar Association

    Legal Analysis | Turkish Citizenship Law | Citizenship by Investment | Criminal Investigations | Administrative Litigation

    Turkish Citizenship Revocation and Cancellation in 2026: Latest Developments, the 1,070-Person Investigation, 6,134 Citizenship Decisions, and Legal Remedies

    Turkish citizenship acquired through real estate investment is facing an unprecedented level of administrative and criminal scrutiny. Following major investigations initiated in 2025, Turkish authorities announced additional operations in August and September 2026 concerning allegedly fraudulent property valuations, sham real estate transactions, artificial banking arrangements, and irregularities in investment eligibility certificates.

    On September 21, 2026, Turkish authorities announced that an investigation involving 1,070 people, including investors and their family members, had been identified in connection with allegedly irregular citizenship acquisitions. On the same day, the Ministry of Interior reported that citizenship acquisition decisions concerning a total of 6,134 individuals had previously been annulled or withdrawn through various administrative procedures. These figures concern different categories of proceedings and must not be confused. [N4] [N7]

    The most important legal distinction is this: being mentioned in a criminal investigation does not establish that an individual’s Turkish citizenship has been cancelled or withdrawn. Equally, the absence of a notification does not conclusively prove that no administrative decision has been issued.

    For each investor, the legal position must be determined through a separate examination of citizenship records, the acquisition date, historical property valuations, the genuine source and movement of funds, investment eligibility certificates, relevant administrative decisions, criminal proceedings, and the citizenship status of family members.

    This article examines the developments reported up to October 8, 2026. It is based on publicly accessible official statements, Turkish legislation, decisions of the Council of State (Danıştay), academic scholarship, and anonymised observations concerning legal practice.

    Verified official information is expressly distinguished from verbal reports that have not been independently confirmed. No unverified information is presented as an established court decision or a definitive determination concerning an individual investor.

    Table of Contents

    1. What Happened in the Turkish Citizenship Investigations During 2025 and 2026?

    The investigations into Turkish citizenship acquired through real estate investment did not begin in September 2026. They form part of a series of investigations concerning allegedly irregular citizenship acquisitions, suspicious real estate transactions, financial arrangements, and property valuation practices.

    September 2025: An Earlier Major Citizenship Investigation

    On September 24, 2025, Turkish authorities conducted an operation across 19 provinces, coordinated from Istanbul, concerning allegations that Turkish citizenship had been obtained through sham property sales and fraudulent financial arrangements.

    Subsequent news reporting referred to 451 foreign investors and 1,198 citizenship acquisitions when family members were included. The allegations concerned the absence of genuine foreign currency inflows, artificial financial transactions, and property sales allegedly structured to satisfy citizenship requirements without a genuine underlying investment. [N1] [N2]

    It is important to distinguish the findings and allegations of investigating authorities from criminal responsibility established by a final court judgment.

    August 4, 2026: Investigation Involving 687 Citizenship Acquisitions

    On August 4, 2026, the Turkish Ministry of Justice announced an investigation involving allegations that properties of relatively low actual value had been presented as more valuable through inaccurate valuation reports and that sham transactions had been used to facilitate citizenship acquisitions.

    The authorities announced that legal procedures had been initiated concerning the possible cancellation of citizenship for 687 people. They also referred to an alleged failure to achieve approximately TRY 2.5 billion in genuine foreign currency inflows and the application of measures affecting various assets. [N3]

    The announcement of a legal process for cancelling citizenship is not identical to proof that a separate, final and duly notified cancellation decision already exists for every person concerned.

    On August 7, 2026, Anadolu Ajansı reported that 32 suspects had been placed in pre-trial detention and 48 others were subject to judicial-control measures. These are measures within criminal procedure, not findings of guilt. [N5]

    September 21, 2026: Second-Wave Operation Involving 1,070 People

    On September 21, 2026, another operation was announced concerning property transactions involving Gül İnşaat AŞ, Beyaz İnşaat and LİV İnşaat.

    According to the official statements, transactions involving 734 foreign purchasers had been examined and 274 sales were identified by the authorities as allegedly sham transactions. The investigation was said to involve 1,070 people, including investors and family members. [N4]

    September 25, 2026: Further Judicial Measures

    On September 25, 2026, Anadolu Ajansı reported that 33 suspects had been detained pending trial, 20 were subjected to house-arrest-type judicial control, and 21 were subjected to other judicial-control measures. [N6]

    As of October 8, 2026, these are among the latest material procedural developments that can be verified through the public sources examined for this article.

    However, the absence of a more recent public announcement does not establish that criminal prosecutors, administrative authorities or the relevant government institutions have ceased processing individual files.

    2. Have 6,134 People Already Lost Their Turkish Citizenship?

    The Ministry of Interior statement reported on September 21, 2026 provided cumulative figures concerning administrative decisions affecting citizenship acquired through investment and other exceptional citizenship procedures.

    Category of administrative action Principal investors Total including family members
    Annulments associated with cancelled investment eligibility certificates 1,150 5,391
    Withdrawal decisions involving public-order or national-security considerations 263 743
    Total reported by the Ministry 1,413 6,134
    Investors whose eligibility certificates were cancelled from February 11, 2026 onwards 458 1,393

    Sources: Ministry of Interior statement reported by Anadolu Ajansı and TRT Haber, September 21, 2026. The 1,393-person figure in the final row must not be added separately to the cumulative total without establishing the relevant overlap. [N4] [N7]

    These figures demonstrate that the Turkish authorities have publicly reported the adoption of substantial numbers of citizenship annulment and withdrawal decisions.

    Nevertheless, the figures should not be interpreted as establishing that every one of the 1,070 people identified in the latest investigation had already received a definitive administrative decision on September 21, 2026.

    It is also necessary to distinguish an administrative decision being issued from that decision being notified to the person concerned, becoming the subject of judicial review, or being upheld by a final judgment.

    The number of people identified in an investigation, the number of administrative decisions issued, and the number of decisions that have become final are legally different matters.

    3. What Exactly Is the 1,070-Person Turkish Citizenship Investigation?

    The investigation announced on September 21, 2026 concerns alleged irregularities in real estate transactions used to obtain Turkish citizenship through investment.

    The authorities referred to analyses of land registry records, banking information, financial investigation reports, and expert assessments.

    Investigation category Reported figure
    Property sales examined 734
    Sales alleged by the authorities to be sham transactions 274
    People identified as having acquired citizenship 1,070
    Principal investors 263
    Family members 807
    People who acquired citizenship at the date of the principal decision 1,015
    Children who reportedly acquired citizenship after that decision 55
    Additional people associated with citizenship application processes 11

    Source: Ministry of Interior statement of September 21, 2026, reported by Anadolu Ajansı. [N4]

    The investigation reportedly concerns allegations that the foreign currency needed for citizenship was not genuinely introduced into Türkiye, that transaction flows were artificially created through seller-related financing or intermediary companies, and that certain valuation reports overstated property values.

    These matters are highly relevant to the statutory requirements for citizenship by investment. However, allegations about an investment scheme must not be treated as conclusive evidence that every individual investor knowingly participated in wrongdoing.

    Of particular importance is the fact that only 274 of the 734 examined transactions were described as sham sales in the official announcement.

    The fact that a purchaser acquired property from a company under investigation does not, by itself, prove that the purchaser’s particular property transaction was sham, fraudulent or legally insufficient.

    4. Which Construction Companies Are Mentioned in the Citizenship Investigations?

    According to the September 21, 2026 statement reported by Anadolu Ajansı, the first wave of the 2026 investigation concerned transactions associated with Babacan İnşaat.

    The second wave concerned selected real estate transactions associated with Gül İnşaat AŞ, Beyaz İnşaat and LİV İnşaat. [N4]

    The mention of these companies in an official investigation must not be understood as proof that every property sold by these companies, every development project, or every independent residential unit was involved in an unlawful transaction.

    Each relevant property must be assessed by reference to its land registry information, individual unit identification, actual purchase price, historical valuation, payment records and the applicable citizenship requirements.

    Furthermore, lists of construction projects, apartment numbers or investors circulating on social media require particular caution. Unless independently verified through reliable official documents, such lists should not be presented as complete or authoritative records of affected citizenship cases.

    This article does not treat unverified project lists as established facts.

    5. Unconfirmed Verbal Information Concerning Investigation Procedures in October 2026

    Beyond official public announcements, various observations may arise during legal research, enquiries with relevant public authorities, and discussions concerning the practical administration of individual citizenship and criminal investigation files.

    Such information can be useful in identifying issues that require further investigation. However, statements received verbally are not equivalent to formal instructions, written administrative decisions, or judicial rulings.

    Important notice: The following observations concern information reportedly communicated verbally during the first days of October 2026. They have not been independently confirmed as general official policies applicable to every investigation. They are subject to change at any time.

    5.1. Reports of Temporary Suspension of Certain Police Interviews

    According to certain verbal accounts obtained in connection with the practical administration of investigation files, some planned police interviews were reportedly suspended or postponed pending further instructions.

    There have also been accounts of individuals attending law enforcement offices but not having their statements formally taken.

    These accounts must not be interpreted as evidence that all interviews in all citizenship-related investigations have been suspended or that the prosecutor’s office has issued a general nationwide order preventing further statements from being taken.

    Nor should they be understood as removing any individual’s obligation to comply with a lawful summons or other applicable criminal procedure requirements.

    The current position must be verified individually, taking account of the specific investigation, any new prosecutor’s instructions, the person’s legal status, and any outstanding summons or judicial measures.

    5.2. Reports Concerning the Separation of Investigation Files

    Another issue referred to in practical accounts is the possibility that matters connected to a broad citizenship investigation may be separated into different criminal files.

    Under Turkish criminal procedure, connected investigations may be separated or combined where the relevant legal requirements are satisfied.

    However, reports that a particular investor has been transferred to a different investigation, or that a new file has been created, cannot be accepted as established facts without examination of the relevant official records.

    In practice, the existence of a criminal investigation must be established for the particular individual rather than inferred solely from a developer’s name or the existence of another related proceeding.

    5.3. Different Stages of Administrative Citizenship Proceedings

    Investors connected to the same construction company or development project may be subject to different administrative stages.

    For one individual, the only available information may concern a criminal investigation into a seller or intermediary. Another person’s investment eligibility certificate may have been placed under review. A third person may already be subject to an administrative annulment or withdrawal decision.

    The fact that these processes may progress at different times does not permit a general conclusion concerning every investor in the same development.

    Continuous verification: All verbally reported observations in this section must be reassessed whenever reliable written information becomes available. These observations do not constitute an assurance that interviews will not be conducted, that an investigation has ended, or that citizenship will be retained.

    6. Are All Citizenship Investigations Being Conducted Under a Single Criminal File?

    No general assumption should be made that all citizenship investigations announced during 2025 and 2026 are being conducted under one prosecutor’s investigation number or one criminal court case.

    Different operations have involved different dates, companies, property transactions, suspects and alleged offences.

    A criminal investigation may remain at the preliminary evidence-gathering stage, while a connected or earlier matter may already have resulted in an indictment or court proceedings.

    Similarly, an investigation may involve the owners or managers of a construction company without every purchaser being formally designated as a suspect.

    For an accurate assessment, the relevant questions include whether an individual investigation exists, the identity of the investigating prosecutor’s office, the person’s procedural status, whether an interview has been requested, whether any judicial measure has been imposed, whether files have been separated or combined, and whether an indictment has been filed.

    The confidentiality of an ongoing criminal investigation can limit public access to detailed information. Therefore, the absence of a new press report is not proof that a particular investigation has been closed.

    A proper legal assessment of Turkish citizenship proceedings requires a clear distinction between Article 31 and Article 40 of Turkish Citizenship Law No. 5901.

    These mechanisms are sometimes discussed together under the broad expression “Turkish citizenship revocation”. However, they involve different legal grounds and must not be treated as interchangeable.

    7.1. Annulment of Citizenship – Article 31

    Article 31 provides for the annulment of a decision granting Turkish citizenship where that decision resulted from the individual’s false declaration or concealment of important matters relevant to the acquisition of citizenship.

    Accordingly, the individual’s conduct, the nature of the alleged false declaration or concealment, and its relationship to the citizenship acquisition decision are central to the legal analysis.

    Alleged wrongdoing by a property developer, broker or valuation expert does not automatically establish that the investor personally made a false declaration or knowingly concealed a material fact.

    7.2. Withdrawal of Citizenship Acquisition Decisions – Article 40

    Article 40 concerns the withdrawal of decisions relating to the acquisition or loss of Turkish citizenship where it is subsequently established that the necessary legal conditions were not satisfied or that the decision was issued more than once.

    Unlike Article 31, this provision is not confined to cases involving an applicant’s false statement or concealment.

    An investor may therefore face an administrative argument that the objective legal conditions for citizenship were never satisfied, even where the investor denies fraud and maintains that the property was genuinely purchased.

    However, the administration must still act within the law and establish the factual and legal grounds supporting the withdrawal decision. The existence and sufficiency of the evidence are matters capable of judicial review. [J1] [A1]

    Legal issue Article 31 – Annulment Article 40 – Withdrawal
    Primary legal ground False declaration or concealment of material facts by the individual Acquisition without the required legal conditions, or a duplicate decision
    Applicant’s conduct Relevant to the statutory ground Objective non-compliance may be decisive independently of personal fraud
    Legal effect Article 32 provides retrospective effect from the original decision date Article 66 of the implementing Regulation provides invalidity from the original decision date
    Family members Linked citizenship acquisitions may be affected under Article 32 The legal foundation of related citizenship decisions requires separate assessment
    Principal legal argument Absence of the required false declaration, concealment or causal connection Existence of all legally required conditions at the relevant acquisition date

    This distinction is examined in greater detail in our earlier academic-style publication, Annulment and Withdrawal of Turkish Citizenship Acquired Through Investment.

    Recent academic scholarship has also examined the relationship between investment conditions and the appropriate legal basis for subsequent administrative intervention. [A2]

    8. How Can I Find Out Whether My Turkish Citizenship Has Been Cancelled or Withdrawn?

    An accurate determination of Turkish citizenship status requires an examination of current official records and any administrative decisions issued in the individual’s case.

    Being named in news reports, owning property in a development under investigation or being associated with a company mentioned by the authorities does not establish that a person’s Turkish citizenship has been withdrawn.

    Equally, continued physical possession of a Turkish identity card or passport, access to an e-Devlet account, or the absence of a notification does not necessarily provide conclusive proof of current legal citizenship status.

    Situation Legal significance
    The developer is under criminal investigation This alone does not establish cancellation of the investor’s citizenship
    The investor’s name appears in an investigation Criminal status and administrative citizenship status must be examined separately
    The investment eligibility certificate has been cancelled This may create a serious administrative risk, but the citizenship decision must also be reviewed
    A citizenship annulment or withdrawal decision has been issued The date, legal ground, scope and notification must be established
    The decision has been formally notified Judicial time limits and urgent legal remedies must be assessed
    No official information has yet been obtained Neither continuation nor termination of citizenship can be concluded with certainty

    The relevant assessment may require enquiries with the Directorate General of Civil Registration and Citizenship Affairs (Nüfus ve Vatandaşlık İşleri Genel Müdürlüğü), the authorities responsible for investment eligibility, and other competent institutions.

    It is particularly important to distinguish the date on which an administrative decision was made from the date on which that decision was legally notified.

    This distinction may affect the calculation of judicial deadlines and the availability of procedural remedies.

    9. I Made a Genuine Investment and Committed No Fraud. Can My Turkish Citizenship Still Be Withdrawn?

    A recurring concern among affected investors is that they genuinely purchased their properties, transferred the required funds through their own bank accounts, received registered ownership and never received any refund from the seller or developer.

    Such facts may be extremely important to a legal defence.

    Banking records showing genuine payment, evidence that the seller received the purchase price, the absence of a circular movement of funds, and the continuation of property ownership may support the position that a real investment took place.

    Nevertheless, the existence of a genuine property transaction and compliance with every legal condition for citizenship are not necessarily identical questions.

    For example, an investor may have genuinely paid for an apartment while the authorities subsequently allege that its actual value at the relevant acquisition date was below the statutory citizenship threshold.

    Three separate matters must therefore be examined:

    1. Whether the property purchase and payment transactions were genuine.
    2. Whether the investment satisfied the legal requirements applicable at the relevant date.
    3. Whether the investor knowingly participated in any false declaration, concealment or fraudulent transaction.

    Good faith is legally relevant, but it does not guarantee that every citizenship withdrawal decision can be successfully challenged. Equally, an allegation of misconduct against a developer does not establish personal criminal liability on the part of every purchaser.

    Under Turkish criminal law, individual responsibility must be assessed by reference to the elements of the alleged offence and the conduct attributable to the particular person.

    Under administrative law, the relevant citizenship decision must be evaluated by reference to its statutory basis, factual grounds and applicable legal safeguards.

    10. Can an Old Property Valuation Report Be Re-examined? What If a New Valuation Is Lower?

    Retrospective property valuation has become a central issue in the 2026 investigations.

    The authorities may examine valuation reports prepared when citizenship was originally acquired and may obtain new expert evidence concerning the property’s value at that earlier date.

    However, a property’s market value in 2026 is not necessarily the same as its market value at the time of the investment.

    The relevant question is whether the original investment satisfied the applicable requirements at the legally relevant time.

    10.1. The USD 250,000 and USD 400,000 Thresholds

    The property investment threshold for Turkish citizenship was reduced to USD 250,000 on September 19, 2018. It was subsequently increased to USD 400,000 with effect from June 13, 2022, subject to the applicable transitional provisions.

    Consequently, a qualifying property investment made in 2021 should not simply be assessed by applying the later USD 400,000 requirement retrospectively. The relevant dates of the investment, contractual undertaking, application and eligibility documentation must be assessed under the law and transitional provisions applicable to the particular transaction. [L2]

    10.2. Does a Valuation of an Entire Project Establish the Value of Every Apartment?

    Not necessarily.

    An expert report concerning an entire development, parent parcel or construction project does not automatically establish the historical value of every independent residential unit.

    Relevant factors may include the unit’s location, block, floor, net and gross area, orientation, legal status, construction stage, view, property characteristics and comparable transactions at the relevant date.

    Special attention may be required where apartment numbers used during the construction stage differ from the unit numbers subsequently registered following the establishment of condominium ownership.

    Any discrepancy between project documentation and land registry descriptions should be investigated before conclusions are drawn from a general valuation report.

    10.3. Could Obtaining a New Expert Report Create Legal Risks?

    A new technical report may assist an investor in challenging a disputed valuation. However, its scope, methodology, evidential limitations and potential findings should be considered before commissioning the work.

    If an independent report concludes that a property’s historical value was below the threshold applicable at the relevant time, that conclusion may become a significant issue in an administrative dispute under Article 40.

    A properly designed legal strategy should therefore begin with an assessment of existing evidence, including the original valuation report, banking records, expert conclusions, development records and comparable historical transactions.

    Where justified, an independent expert opinion, judicial preservation of evidence or court-appointed expert examination may be considered.

    The purpose of expert evidence must be to establish the property’s actual historical value through a transparent and verifiable methodology, rather than to manufacture a preferred valuation result.

    11. What Do the Important 2026 Council of State Decisions Mean for Citizenship Revocation Cases?

    Two decisions of the Turkish Council of State (Danıştay), Tenth Chamber, issued in February 2026 provide important guidance concerning the judicial review of administrative decisions withdrawing Turkish citizenship.

    The decisions concern different factual circumstances and should not be treated as producing a single automatic outcome for all investment-based citizenship disputes.

    11.1. Council of State, Tenth Chamber, February 5, 2026, E.2024/405, K.2026/361

    This case concerned a person who acquired Turkish citizenship through investment. The administration subsequently cancelled the investment eligibility certificate after identifying irregularities concerning foreign currency purchase documents.

    The Council of State examined the withdrawal of citizenship under Article 40 of Law No. 5901 and found no illegality in the administrative withdrawal decision, having regard to the failure to satisfy the necessary legal requirements. [J1]

    The decision is important because the original approval of a citizenship application does not necessarily prevent the administration from subsequently withdrawing the decision where it is legally established that the necessary conditions were absent from the outset.

    It also demonstrates the significance of examining the investment eligibility certificate, the underlying financial documents and any available challenge to the cancellation of that certificate.

    11.2. Council of State, Tenth Chamber, February 4, 2026, E.2024/3835, K.2026/324

    This case concerned a citizenship withdrawal decision based on public-order and national-security considerations.

    Having examined the reasons and supporting material relied upon by the administration, the Council of State concluded that the grounds necessary to justify withdrawal had not been sufficiently established and annulled the relevant part of the administrative decision. [J2]

    This was not a property valuation dispute. Its significance lies in the requirement that an administrative decision affecting citizenship must have a legally sustainable and sufficiently substantiated basis.

    11.3. What Can Be Learned from These Two Judgments?

    These decisions should be read together.

    The first demonstrates that a withdrawal decision may be upheld where the statutory conditions for citizenship were not satisfied and the relevant facts have been established.

    The second demonstrates that the administration’s asserted grounds may be subjected to meaningful judicial scrutiny and that a withdrawal decision may be annulled where the necessary basis is not sufficiently established.

    Accordingly, neither the proposition that all citizenship withdrawal decisions are unlawful nor the proposition that all such decisions are immune from judicial challenge is legally sustainable.

    The decisive issues are the applicable legal provision, the factual position at the time of acquisition, the evidence relied upon by the authorities, and the legality of the particular administrative decision.

    12. What Happens to My Wife, Husband and Children If My Turkish Citizenship Is Cancelled?

    Article 32 of Turkish Citizenship Law No. 5901 addresses the consequences of an annulment decision for spouses and children who acquired Turkish citizenship in connection with the principal person’s acquisition.

    However, it would be legally inaccurate to assume that every family member must necessarily have exactly the same legal position.

    The manner and date of citizenship acquisition, whether citizenship was acquired derivatively or independently, and the relevant provisions of Turkish nationality law must be examined for each individual.

    The September 21, 2026 official statement identified 807 family members among the 1,070 persons concerned and separately referred to 55 children who acquired Turkish citizenship after the original citizenship decision. [N4]

    This distinction illustrates why family members should not be assessed solely by reference to the principal investor’s file.

    Particular care is required in cases involving children who acquired Turkish citizenship by birth, children whose nationality was connected to a parent’s subsequent naturalisation, or family members who may have acquired citizenship on a separate legal basis.

    The potential retrospective legal effects of withdrawal and annulment decisions must also be examined in light of the applicable legislation.

    13. Does a Seizure Order on My Property Mean My Turkish Citizenship Has Been Revoked?

    No. A seizure or freezing measure recorded against a property in TAKBİS or the land registry does not, by itself, establish that the owner’s Turkish citizenship has been annulled or withdrawn.

    A criminal-procedure measure concerning property and an administrative decision concerning citizenship are distinct legal acts.

    When a seizure measure is identified, the legal assessment should determine which judicial authority ordered it, the offences or facts relied upon, the specific property affected, the statutory basis of the measure, and the applicable objection procedures.

    The rights and safeguards provided under the Turkish Code of Criminal Procedure must be considered.

    Article 33 of Turkish Citizenship Law No. 5901 also contains special provisions concerning the liquidation of assets in certain cases involving annulled citizenship.

    However, the annulment of citizenship should not be treated as automatically transferring ownership of every property to the state or as producing identical asset consequences in every case.

    Whether asset liquidation is legally required must be assessed in accordance with the applicable statutory provisions and the relevant administrative decision.

    In addition, the legal effect of judicial proceedings against an annulment decision on the liquidation process requires separate examination.

    Continued registration of a property in the investor’s name, the existence of a criminal seizure measure, and the investor’s citizenship status are three legally different questions.

    14. What Criminal Charges Could Arise from a Turkish Citizenship by Investment Investigation?

    The investigations publicly announced in 2025 and 2026 have referred to several categories of alleged criminal conduct.

    Depending on the relevant facts, allegations may concern establishing, managing or participating in a criminal organisation, migrant smuggling, document forgery, false statements in the preparation of official documents, or aggravated fraud involving public institutions. [N4] [N6]

    However, the offences listed in a prosecutor’s public statement do not necessarily apply to every foreign investor whose property transaction is being examined.

    Criminal responsibility must be determined individually, having regard to the elements of the alleged offence, the person’s conduct, intent, knowledge, participation and the available evidence.

    For example, an allegation that a valuation expert knowingly prepared a false report does not independently establish that the purchaser knew of the falsity or participated in its preparation.

    Relevant defence materials may include purchase contracts, bank records, foreign exchange documentation, evidence concerning the source of funds, correspondence with the seller, real estate valuation reports, and documents submitted in the original citizenship application.

    Criminal proceedings and citizenship proceedings may influence each other, but they remain legally distinct.

    A criminal investigation being discontinued does not automatically eliminate every possible administrative issue concerning the original citizenship conditions.

    Conversely, an administrative decision withdrawing citizenship does not establish that the person has committed a criminal offence.

    15. I Live Outside Türkiye. What Should I Do Before Travelling to Istanbul?

    Many investors who acquired Turkish citizenship through real estate investment have subsequently continued living in other countries.

    Some may first learn about an investigation through public news reports, social media, or information concerning the developer from whom they purchased an apartment.

    Before travelling to Türkiye, individuals facing a concrete concern may consider obtaining an appropriate legal assessment of their current citizenship status and any known judicial measures affecting them.

    Relevant enquiries may concern the existence of an investigation, the person’s procedural status, any summons, arrest or compulsory appearance order, and the current validity of citizenship and identity documents.

    Where citizenship has already been annulled or withdrawn, immigration-law considerations may become important, including the person’s other nationality, legal residence position, possible statelessness concerns, and any deportation or administrative detention measures.

    Depending on the nature of the required legal acts, it may be possible to authorise a Turkish lawyer through a power of attorney executed before a Turkish diplomatic or consular authority abroad.

    However, the applicable identification and documentary requirements should be confirmed with the relevant consular authority.

    There is no reliable universal answer to the question of which passport an individual should use when travelling to Türkiye while a citizenship-related dispute is pending.

    The person must act consistently with their lawful current status and provide accurate information to the competent authorities.

    16. Which Documents Are Necessary to Assess the Risk of Turkish Citizenship Revocation?

    A comprehensive assessment should not rely exclusively on a title deed or a single bank receipt.

    Investment-based citizenship cases may require a coordinated examination of the administrative acquisition process, financial transactions, real estate records, valuation evidence, and any related criminal proceedings.

    Document category Purpose of the examination
    Original citizenship acquisition decision and records Establish the date, legal basis and family relationships
    Title deeds and historical land registry records Verify ownership, transaction history and the property unit
    Property purchase contracts and receipts Determine the actual contractual price and payment arrangements
    Foreign and Turkish bank statements Trace the source and movement of funds
    Foreign currency purchase certificates Examine compliance with the currency requirements applicable at the time
    Original and subsequent valuation reports Assess the property’s historical value and possible discrepancies
    Investment eligibility certificate Determine the basis and current status of the administrative eligibility assessment
    Developer and intermediary correspondence Identify the investor’s knowledge, instructions and communications
    Family members’ citizenship documents Establish derivative or independent citizenship acquisition
    Administrative notifications and institutional correspondence Identify decisions, notification dates and judicial deadlines
    Criminal investigation and judicial documents Establish the scope of any allegations or protective measures

    Articles 2 and 46 of the Turkish Attorneyship Law No. 1136 provide a framework for lawyers’ access to certain files and documents.

    Nevertheless, access without a power of attorney, obtaining copies, access to confidential investigation records and disclosure of personal civil registry information may be subject to statutory restrictions and institutional requirements.

    These rights should not be interpreted as giving unrestricted access to every confidential document or every individual’s personal records without appropriate legal authority.

    17. A Legal Roadmap for Investors Facing Turkish Citizenship Annulment or Withdrawal

    An effective legal response requires more than submitting a single petition or waiting for a notification from the authorities.

    The administrative, criminal, financial, real estate and, where necessary, immigration-law aspects of the case should be assessed as part of a coherent legal strategy.

    Step 1: Establish the Current Citizenship Status

    The first stage is to determine the date and legal basis of citizenship acquisition, the status of the investment eligibility certificate, and whether any annulment or withdrawal decision has been issued.

    If such a decision exists, its date, legal basis, notification and present procedural status must be established.

    Step 2: Identify the Criminal Investigation and Its Scope

    Enquiries should determine whether the investor is personally involved in a criminal investigation, whether the person is identified as a suspect, whether an interview has been requested, and whether any judicial protective measure exists.

    Any related or separated files should be considered where relevant and lawfully accessible.

    Step 3: Reconstruct the Investment Transaction

    The original acquisition process should be documented chronologically, beginning with the purchase agreement and continuing through payment, valuation, registration, eligibility assessment and the citizenship decision.

    This allows the legal requirements applicable at each stage to be assessed accurately.

    Step 4: Verify the Source and Movement of Funds

    A financial review should examine where the funds originated, which accounts were used, whether the required payments were made, whether the seller actually received the money, and whether any direct or indirect refund occurred.

    Where appropriate, documentary evidence may be sought from banks or other competent institutions through lawful procedures.

    Step 5: Examine the Property’s Historical Value

    If the case concerns an allegation of insufficient investment or inflated valuation, technical analysis should focus on the relevant historical valuation date.

    Comparable transactions, the property’s characteristics, the original expert report and any subsequent findings should be evaluated together.

    Step 6: Coordinate Administrative and Criminal Defence

    Statements and documents used in criminal proceedings should be considered alongside submissions made to administrative authorities.

    The objective is to avoid factual inconsistency while respecting the different legal standards, procedural rights and evidential requirements of each proceeding.

    Step 7: Pursue Appropriate Administrative and Judicial Remedies

    Where an annulment or withdrawal decision has already been issued, the appropriate court, filing deadline and possible request for suspension of execution must be determined.

    If the investment eligibility certificate has been separately cancelled, it may be necessary to assess whether that decision requires an independent challenge.

    Any seizure or other criminal-procedure measure should be considered under the relevant procedural rules and objection mechanisms.

    Step 8: Continue Reviewing Material Developments

    Citizenship and criminal files can evolve over time.

    An investigation initially concerning a construction company may subsequently produce evidence concerning specific transactions. An eligibility review may result in a separate administrative decision, and an existing decision may later be notified or challenged.

    For this reason, cases involving a concrete ongoing risk should be reassessed when material new information becomes available.

    18. How Can a Turkish Citizenship Revocation Decision Be Challenged in Court?

    Decisions annulling or withdrawing Turkish citizenship are administrative acts capable of judicial review.

    However, the competent court depends on the authority issuing the challenged decision and the legal nature of the specific administrative act.

    Certain decisions concerning exceptional acquisition or withdrawal of citizenship made by the President of the Republic may fall within the Council of State’s first-instance jurisdiction.

    Other administrative decisions, including certain investment eligibility decisions, may require a separate determination of the competent administrative court.

    18.1. Time Limits for Judicial Review

    Under the general framework of Administrative Procedure Law No. 2577, where no special period applies, the time limit for bringing an action before the Council of State or an administrative court is generally 60 days.

    Nevertheless, the precise time limit must be calculated by reference to the specific act, the lawful notification date, any applicable special rules, and the legal consequences of any administrative application.

    The Council of State’s decision dated December 30, 2025, E.2025/6295, K.2025/7133, illustrates the importance of complying with the applicable judicial filing period. The action considered in that case was rejected because it had not been filed within the relevant time limit. [J3]

    18.2. Can the Court Suspend the Citizenship Decision?

    A claimant may request a suspension of execution where the statutory conditions are satisfied.

    However, filing an annulment action does not automatically suspend the implementation of every administrative decision.

    Article 27 of Law No. 2577 governs the requirements for suspension of execution, including the relevant tests concerning unlawfulness and the consequences of implementation.

    The availability of interim judicial protection must therefore be evaluated on the circumstances of the particular case.

    Where a citizenship withdrawal or annulment decision has been notified, establishing the filing deadline and the need for urgent interim relief should be among the first legal priorities.

    19. Frequently Asked Questions About Turkish Citizenship Revocation in 2026

    1. Has Turkish citizenship been definitively cancelled for all 1,070 people?

    No such general conclusion can be drawn from the September 21, 2026 announcement. The authorities reported identifying the individuals concerned and initiating administrative procedures. This does not establish that separate decisions have been issued, notified or finally upheld for every individual.

    2. Is it true that 6,134 people have had their Turkish citizenship annulled or withdrawn?

    The Ministry of Interior publicly reported that citizenship decisions concerning 5,391 people had been annulled and decisions concerning 743 people had been withdrawn, producing a cumulative total of 6,134 individuals. These figures must be distinguished from the newer 1,070-person investigation.

    3. If my property developer is under investigation, will my citizenship automatically be revoked?

    No. An investigation into the developer does not automatically establish that the purchaser’s citizenship has been revoked or that the purchaser’s transaction was unlawful. The individual’s investment and administrative records require separate examination.

    4. Can my citizenship be withdrawn even though I genuinely paid for the property?

    Yes, a legal risk may still arise if the authorities allege that the objective conditions for citizenship were not satisfied. Genuine payment is an important factor, but the applicable investment requirements must also be examined.

    5. I acquired Turkish citizenship in 2021 through a USD 250,000 investment. Does the USD 400,000 threshold now apply to me?

    Past investments must be evaluated under the law applicable at the legally relevant time, taking account of transitional provisions. The later USD 400,000 threshold should not simply be applied retrospectively to every earlier investment.

    6. I did not prepare the valuation report. Can I still face citizenship withdrawal?

    The fact that the investor did not prepare or knowingly falsify the report may be important under Article 31. However, an allegation that the original objective citizenship conditions were absent may require a separate assessment under Article 40.

    7. Can a new expert report invalidate the original valuation report?

    Not automatically. The dates, methods, comparable sales and characteristics of the property must be assessed before determining the evidential weight of each report.

    8. Can I enter Türkiye if I am mentioned in a criminal citizenship investigation?

    The existence of an investigation is not the same as the existence of an arrest or compulsory appearance order. An informed assessment requires examination of the individual’s current legal status and any relevant judicial measures.

    9. Does possession of a Turkish passport prove that I am still a Turkish citizen?

    Possession of a physical passport alone is not conclusive proof that no subsequent administrative citizenship decision has been made. Current official records should be examined.

    10. If I can access e-Devlet, does that mean my citizenship has not been revoked?

    Access to an electronic government account is not, by itself, a definitive legal determination of citizenship status. The relevant administrative records and decisions must be checked.

    11. Will my spouse and children lose Turkish citizenship if my citizenship is cancelled?

    Linked citizenship acquisitions may be affected under Turkish nationality law. However, the legal basis and date of each family member’s acquisition must be examined individually.

    12. If my apartment is subject to a seizure order, will I lose ownership?

    A criminal seizure measure and the termination of ownership are different legal matters. The order’s grounds, scope, duration and available objection procedures must be assessed, together with any separately applicable citizenship-related asset provisions.

    13. Can I file a lawsuit against a Turkish citizenship revocation decision?

    Yes. Citizenship annulment and withdrawal decisions are subject to judicial review. The appropriate court, legal grounds, filing deadline and possible interim remedies must be determined according to the particular administrative act.

    14. Does filing a lawsuit automatically restore or preserve my Turkish citizenship?

    No automatic result should be assumed. Filing an action does not necessarily suspend the administrative decision. Any suspension of execution or final judgment must be assessed in accordance with Turkish administrative procedure.

    15. Can a Turkish lawyer investigate my citizenship status without a power of attorney?

    Turkish lawyers have certain statutory rights to examine documents and files, but these rights are subject to legal restrictions. Access to confidential material, personal civil registry records, certified copies or the receipt of notifications may require appropriate authorisation or a power of attorney.

    16. I have not received any official notification. Should I simply wait?

    Where there is a concrete risk, waiting for notification may not be sufficient. It may be appropriate to establish the current status through lawful enquiries, preserve relevant evidence and monitor applicable legal deadlines.

    17. If the criminal investigation is closed, will the citizenship problem also disappear?

    Not necessarily. The criminal and administrative processes operate under different legal rules. The outcome of a criminal investigation may be relevant, but it does not automatically dispose of every administrative question concerning citizenship acquisition.

    18. What if my property is still registered in my name?

    Continued ownership may be relevant to the reality of the investment. However, registration of ownership alone does not establish that every citizenship requirement was originally satisfied or that no administrative decision exists.

    19. Can I challenge an inaccurate retrospective property valuation?

    The methodology, factual assumptions, property identification, historical comparable sales and other technical aspects of a valuation may be examined and challenged through legally appropriate evidential procedures.

    20. What is the most important first step?

    The first priority is usually to establish the individual’s actual legal position rather than rely on news reports or unverified information. This includes identifying any existing citizenship decision, relevant criminal proceedings and time-sensitive legal remedies.

    20. Conclusion: What Is the Correct Legal Approach to Turkish Citizenship Revocation in 2026?

    The Turkish citizenship investigations announced in 2025 and 2026 have raised substantial questions for foreign investors who acquired citizenship through real estate.

    Official statements confirm that significant numbers of citizenship acquisition decisions have been annulled or withdrawn. However, they do not justify the assumption that every investor associated with the latest criminal investigations has already lost Turkish citizenship.

    Nor is it correct to assume that every genuine investor must necessarily retain citizenship regardless of whether the statutory acquisition conditions were satisfied.

    The legality of an administrative decision depends on the applicable statutory ground, the individual facts and the available evidence.

    A purchaser who genuinely transferred money, acquired real property and did not participate in fraudulent arrangements may possess important evidence supporting a defence. Yet the historical value of the property, the applicable investment threshold, eligibility documentation and other statutory conditions must also be examined.

    The law requires careful distinction between personal criminal wrongdoing, alleged defects in an investment transaction, and administrative deficiencies affecting citizenship acquisition.

    An effective legal response begins by establishing the investor’s current citizenship status, identifying any relevant criminal and administrative proceedings, and developing a document-based strategy that addresses the actual legal issues in the individual’s case.

    At dolgun.av.tr, research concerning Turkish citizenship law, investment-based naturalisation, administrative annulment and withdrawal decisions, and related judicial developments is reviewed as new reliable information becomes available.

    However, the availability of publicly reported or verbally communicated information does not establish unrestricted access to every confidential investigation or the definitive status of every individual citizenship file.

    Legal Assessment of Turkish Citizenship and Investment Investigations

    Individuals concerned about the possible annulment or withdrawal of Turkish citizenship acquired through real estate investment may seek an individual legal assessment based on their citizenship acquisition documents, land registry records, bank statements, property valuation reports, investment eligibility certificate and any relevant judicial or administrative decisions.

    When requesting an initial assessment, it may be useful to provide the year of citizenship acquisition, the name and location of the development project, available title deed information, evidence of payment and information about whether the investor currently resides in Türkiye or abroad.

    Attorney Murat Can Dolğun
    Istanbul Bar Association – Registration No. 75860
    Website: dolgun.av.tr
    Contact: Visit the official website for contact and consultation enquiries

    Legal disclaimer: This article is intended for general legal information and academic discussion. It does not constitute an individual legal opinion or a guarantee of any administrative or judicial outcome. Every case must be examined in light of its specific facts and the applicable law.


    21. Legislation, Academic Literature, Council of State Decisions and News Sources

    A. Legislation and Official Regulations

    [L1] Turkish Citizenship Law No. 5901, Official Gazette, June 12, 2009, No. 27256; particularly Articles 12, 31, 32, 33, 36, 37, 40 and 41. Official legislation (Turkish).

    [L2] General Directorate of Land Registry and Cadastre (Tapu ve Kadastro Genel Müdürlüğü), administrative guidance and applicable regulations regarding the transition from the USD 250,000 property investment threshold to the USD 400,000 threshold in 2022. Official institution website.

    [L3] Administrative Procedure Law No. 2577 (İdari Yargılama Usulü Kanunu), particularly Articles 7, 8 and 27.

    [L4] Attorneyship Law No. 1136 (Avukatlık Kanunu), particularly Articles 2 and 46.

    B. Academic Publications

    [A1] Güner, Cemil. “Türk Vatandaşlığının Kazanılması ve Kaybı Kararlarının Geri Alınması” [Withdrawal of Decisions Concerning the Acquisition and Loss of Turkish Citizenship]. Milletlerarası Hukuk ve Milletlerarası Özel Hukuk Bülteni, Vol. 37, No. 2, 2017. DergiPark academic article.

    [A2] Özgür, Çiçek. “Yatırım Yoluyla Kazanılan Türk Vatandaşlığının İptali ve Geri Alınması” [Annulment and Withdrawal of Turkish Citizenship Acquired Through Investment]. Ankara Üniversitesi Hukuk Fakültesi Dergisi, Vol. 75, No. 1, 2026, pp. 741–779. DOI: 10.33629/auhfd.1710185. DergiPark academic article.

    [A3] Erden, Hümeyra Zeynep. “Türk Vatandaşlığına Alınma Kararının İptalinde Süre” [Time Limits in the Annulment of Decisions Granting Turkish Citizenship]. Milletlerarası Hukuk ve Milletlerarası Özel Hukuk Bülteni, Vol. 36, No. 1, 2016. DergiPark academic article.

    C. Decisions of the Council of State (Danıştay)

    [J1] Council of State (Danıştay), Tenth Chamber, February 5, 2026, E.2024/405, K.2026/361. Withdrawal of investment-based Turkish citizenship following irregularities in foreign currency purchase documents and cancellation of the investment eligibility certificate. Official judgment (Turkish).

    [J2] Council of State (Danıştay), Tenth Chamber, February 4, 2026, E.2024/3835, K.2026/324. Judicial review of a withdrawal decision based on national-security and public-order considerations; legal grounds and supporting evidence. Official judgment (Turkish).

    [J3] Council of State (Danıştay), Tenth Chamber, December 30, 2025, E.2025/6295, K.2025/7133. Notification and time limits in citizenship-related administrative litigation. Official judgment (Turkish).

    D. Official Statements and News Reports

    [N1] Candan, Fatma Nur. “Muvazaalı gayrimenkul satışıyla vatandaşlık sağlayan suç örgütü çökertildi.” Anadolu Ajansı, September 24, 2025. Original report (Turkish).

    [N2] Anadolu Ajansı. “Yabancılara usulsüz vatandaşlık kazandıran suç örgütüne yönelik operasyonda yakalanan 113 şüpheli adliyede.” September 2025. Original report (Turkish).

    [N3] Republic of Türkiye, Ministry of Justice. “Bakan Gürlek: 687 Kişinin Vatandaşlığının İptali İçin Yasal Süreç Başlatıldı.” Official statement, August 4, 2026. Official statement (Turkish).

    [N4] Yeşildal, Zeynep; Gökmen, Emrah; Yıldız, Dilhan Türker; Eser, Zehra Tekeci. “İstanbul merkezli usulsüz vatandaşlık operasyonunda 73 zanlı yakalandı.” Anadolu Ajansı, September 21, 2026. The report includes statements from the Istanbul Chief Public Prosecutor’s Office, the Ministry of Justice and the Ministry of Interior. Original report (Turkish).

    [N5] Demir, İrem. “Haksız yollarla Türk vatandaşlığı kazandırdığı belirlenen suç örgütü operasyonunda 32 zanlı tutuklandı.” Anadolu Ajansı, August 7, 2026. Original report (Turkish).

    [N6] Yeşildal, Zeynep; Gökmen, Emrah. “İstanbul merkezli usulsüz vatandaşlık operasyonunda yakalanan 33 şüpheli tutuklandı.” Anadolu Ajansı, September 25, 2026. Original report (Turkish).

    [N7] TRT Haber / Anadolu Ajansı. “İçişleri Bakanlığı’ndan İstanbul’daki usulsüz vatandaşlık operasyonuna ilişkin açıklama.” September 21, 2026. Original report (Turkish).

    [N8] Gürel, Ayşe. “İstanbul merkezli 13 ilde sahte belgelerle vatandaşlık operasyonu: 73 gözaltı.” Demirören Haber Ajansı, September 21, 2026. Original report (Turkish).

    [N9] Habertürk Yerel Haberler / Anadolu Ajansı. “İçişleri Bakanlığından İstanbul’daki usulsüz vatandaşlık operasyonuna ilişkin açıklama.” September 21, 2026. Original report (Turkish).

    [N10] Haber Global / Anadolu Ajansı. “İçişleri Bakanlığı duyurdu: Binlerce yabancının vatandaşlığı iptal.” September 21, 2026. Original report (Turkish).

    Source methodology: Certain news outlets reproduced or summarised the same official statements originally reported by Anadolu Ajansı. Such publications are listed as reporting sources, not as separate independent confirmations of the underlying criminal allegations. Anonymous practice-based observations and unconfirmed verbal information are expressly distinguished from official records, judicial decisions and verified public announcements.


    September 19, 2026: Annulment and Withdrawal of Turkish Citizenship Acquired Through Investment: Fraudulent Valuation, Sham Transactions, Good-Faith Investors and Judicial Protection. An analysis of Articles 31 and 40, investment authenticity, legal certainty and judicial remedies. Original article in Turkish.

    September 26, 2026: The 1,070-Person Turkish Citizenship Investigation in 2026. Analysis of the September investigation, 263 principal investors, 807 family members and allegedly sham property transactions. Original article in Turkish.

    September 28, 2026: Turkish Citizenship Annulment and Withdrawal 2026: Frequently Asked Questions, Criminal Investigations and Judicial Remedies. Discussion of status verification, criminal proceedings and legal issues affecting investors living abroad. Original article in Turkish.

    September 28, 2026: Turkish Citizenship Annulment and Withdrawal 2026: New Property Valuations, Insufficient Investment, Families, Children and Construction Companies Under Investigation. Analysis of valuation disputes, family nationality issues and relevant construction projects. Original article in Turkish.

    All related publications: Dolgun Akademi – Citizenship Law.

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