Etiket: Turkish citizenship 400000 USD

  • Turkish Citizenship by Investment 2026 | Requirements & Risks

    Turkish Citizenship by Investment 2026 | Requirements & Risks

    DOLĞUN AKADEMİ | TURKISH CITIZENSHIP LAW | 2026

    Turkish Citizenship by Investment in 2026: Requirements, Legal Safeguards, Property Investments and Citizenship Revocation Risks

    Author: Attorney Murat Can Dolğun – Istanbul Bar Association

    Publication: TD Law Firm & Legal Consultancy – Dolğun Akademi

    Original Publication: October 22, 2026

    Legal Fields: Turkish Citizenship Law, Immigration Law, Administrative Law, Real Estate Law, Banking and Financial Regulations, Foreign Investment Law and Private International Law.

    Abstract

    Turkish citizenship through investment remains legally available in 2026. Nevertheless, criminal investigations and administrative reviews conducted during 2025 and 2026 concerning previously approved citizenship applications have raised important legal questions for prospective foreign investors.

    Can a foreign investor still acquire Turkish citizenship by purchasing real estate worth USD 400,000? Is depositing USD 500,000 in a Turkish bank sufficient? Does an investment certificate of conformity guarantee naturalisation? What happens if a property appraisal report is subsequently found to be inaccurate?

    Answering these questions requires examination of Turkish Citizenship Law No. 5901, the Regulation on the Implementation of the Turkish Citizenship Law, Land Registry Law No. 2644 and the applicable regulations and administrative instructions issued by the General Directorate of Land Registry and Cadastre.

    Citizenship by investment is not a system in which every person who makes a qualifying financial investment automatically becomes a Turkish citizen.

    The investment must satisfy the applicable statutory conditions, the competent institution must determine compliance, the application must be examined and the authorised state authority must issue a positive naturalisation decision.

    This article examines the investment alternatives available in 2026, the USD 400,000 property requirement, USD 500,000 alternative investment routes, the Property Investment Amount Determination Certificate (TTB), foreign-exchange purchase certificates, due diligence, three-year holding requirements, family members’ eligibility and the possibility of subsequent citizenship cancellation or withdrawal.

    The central argument is that legal protection should begin before the investment is made rather than only after a dispute arises.

    Independent legal verification, transparent payment arrangements, proper valuation procedures and enforceable contractual safeguards may substantially reduce the risk of future disputes.

    This research reflects the legislation and official information available as of October 22, 2026.

    I. Does Turkish Citizenship by Investment Still Exist in 2026?

    Yes. Acquisition of Turkish citizenship through qualifying investment remains legally possible in 2026.

    Article 12 of Turkish Citizenship Law No. 5901 and Article 20 of the Regulation on the Implementation of the Turkish Citizenship Law provide the legal framework for exceptional naturalisation based on specified investment criteria.

    The continued availability of the programme is also reflected in current information published by the Directorate General of Population and Citizenship Affairs, the General Directorate of Land Registry and Cadastre and Invest in Türkiye.

    However, administrative and criminal investigations into historical investment transactions have created some misunderstanding concerning whether the programme has been abolished.

    Two different matters must be distinguished: the continuing legal availability of citizenship through investment and retrospective investigations involving particular individuals who obtained Turkish citizenship in previous years.

    The administrative re-examination of historical appraisal reports, investigations concerning allegedly sham transactions or decisions withdrawing citizenship from particular individuals do not, by themselves, repeal the statutory mechanism for investment-based naturalisation.

    Conversely, the programme’s continued availability does not guarantee approval of every qualifying investment or citizenship application.

    Prospective investors should therefore assess the legal eligibility of the relevant property or other investment, the authenticity of payment records, applicable security requirements and the risk of subsequently discovered deficiencies.

    The correct starting point is not merely whether an investment exceeds a financial threshold, but whether the complete transaction meets the legal requirements for exceptional naturalisation.

    Official source: Invest in Türkiye – Acquiring Property and Citizenship.

    II. What Is the Legal Basis of Turkish Citizenship by Investment?

    Citizenship through investment is not an independent nationality category. It constitutes one method of exceptional acquisition of Turkish citizenship under Article 12 of Law No. 5901.

    The relevant provisions permit certain foreign nationals who satisfy statutory conditions to acquire Turkish citizenship by decision of the President, provided that there is no relevant obstacle concerning national security or public order.

    The investment requirements are principally detailed in Article 20 of the implementing Regulation.

    It is essential to understand that property developers, banks, financial intermediaries, investment consultants and private legal service providers cannot themselves grant Turkish citizenship.

    A developer may sell real estate. A bank may accept a deposit. An investment institution may execute a qualifying financial transaction. An attorney may provide legal advice and representation.

    However, the final nationality decision belongs to the competent Turkish state authority.

    Consequently, commercial expressions such as “guaranteed citizenship”, “automatic Turkish passport” or “certain approval” cannot lawfully replace the statutory citizenship decision.

    The certificate confirming that an investment satisfies the applicable financial requirements and the final naturalisation decision are separate administrative stages.

    Even where a certificate of conformity is issued, the nationality application remains subject to the relevant legal examination.

    III. How Much Must a Foreign Investor Invest to Qualify for Turkish Citizenship in 2026?

    Turkish law provides several routes to exceptional naturalisation through investment.

    Investment Category Minimum Requirement Principal Condition
    Real estate acquisition USD 400,000 Three-year non-sale undertaking
    Fixed capital investment USD 500,000 Determination by competent ministry
    Bank deposit USD 500,000 Three-year maintenance
    Government debt instruments USD 500,000 Three-year holding period
    Real estate or venture capital investment funds USD 500,000 Three-year holding period
    Private pension system USD 500,000 Three years in the designated system
    Employment creation 50 employees Official determination of employment

    Different investment categories are subject to different regulatory authorities and compliance procedures.

    For example, the Banking Regulation and Supervision Agency is relevant to the qualifying bank deposit route. The Capital Markets Board supervises the investment-fund route, while the Ministry of Industry and Technology is responsible for determining compliance with the fixed-capital investment requirement.

    For real estate investments, the applicable procedures of the General Directorate of Land Registry and Cadastre are particularly important.

    The financial figures above represent minimum qualifying investments. They do not necessarily include taxes, government charges, notarial fees, translation costs, technical assessments or professional service fees.

    Foreign-exchange conversion requirements and documentation rules also differ according to the investment mechanism.

    Therefore, compliance with the payment procedure applicable to one investment type should not automatically be assumed to establish compliance with another.

    Official source: Directorate General of Population and Citizenship Affairs – Citizenship Services FAQ.

    IV. Is Purchasing Real Estate Worth USD 400,000 Sufficient for Turkish Citizenship?

    In 2026, qualifying real estate with an accepted value of at least USD 400,000 may support an exceptional naturalisation application, subject to the statutory requirements.

    However, merely stating a price of USD 400,000 in a sale agreement does not establish compliance.

    The property must be legally eligible for acquisition by the foreign investor and suitable for the citizenship investment procedure.

    Payment documentation, valuation procedures, the official purchase instrument and the applicable land registry restrictions must also comply with the relevant rules.

    4.1. The Sale Price and Officially Recognised Investment Amount

    Consider an apartment marketed at USD 450,000.

    If the contractual price is USD 450,000 but the officially accepted investment amount reflected in the Property Investment Amount Determination Certificate is USD 360,000, the contractual price alone should not be treated as satisfying the USD 400,000 requirement.

    Likewise, a valuation establishing a figure above USD 400,000 may not suffice if the officially recognised payment documents show a lower amount.

    Under the applicable procedure, the officially declared sales price and documented payment amounts must independently satisfy the relevant threshold and be supported by the TTB.

    4.2. Legal Suitability Before Payment

    A foreign investor should therefore examine the property’s legal status and the relevant valuation process before transferring substantial funds.

    Failure to do so may create both citizenship eligibility risks and potential financial disputes with the seller.

    A transaction that is genuine in economic terms may still fail to satisfy a mandatory citizenship requirement.

    V. Which Types of Real Estate Cannot Be Used for Citizenship by Investment?

    Foreign ownership of real estate and eligibility of a particular property for investment-based citizenship are separate legal issues.

    Following the regulatory amendments effective from December 12, 2023, agricultural properties and undeveloped land without the required buildings cannot be used as qualifying property investments under the relevant citizenship mechanism.

    Current provisions emphasise independent units with condominium ownership or condominium easement rights, or other property meeting the specified building-related requirements.

    5.1. Agricultural Property and Undeveloped Land

    Purchasing a valuable undeveloped plot does not automatically create eligibility for Turkish citizenship.

    The land registry classification and the actual legal characteristics of the property are decisive.

    5.2. Restrictions Based on Previous Ownership

    Additional restrictions may arise from the property’s ownership history, the characteristics of the seller and whether the property has previously been involved in investment-based citizenship procedures.

    5.3. Foreign Ownership Restrictions

    Article 35 of Land Registry Law No. 2644 and other relevant provisions govern foreign real estate ownership and applicable limitations.

    The ability to acquire a particular property may depend on the investor’s nationality, property location and other legal restrictions.

    It would therefore be incorrect to assume that all foreign nationals may purchase every category of property anywhere in Türkiye.

    Official source: Your Key Türkiye – Citizenship Acquisition Through Real Estate.

    VI. Why Should Investors Investigate the Property’s Ownership History and the Seller?

    A proper legal examination should extend beyond obtaining the property’s current title deed.

    The history of previous transfers and the identity of former owners may be important in determining whether the property qualifies for citizenship purposes.

    Restrictions may arise where property was previously used for an exceptional citizenship investment or transferred through a transaction chain involving individuals who acquired nationality through that procedure.

    Accordingly, the fact that the current seller is a Turkish national or a Turkish company does not necessarily prove that the property is eligible.

    6.1. The Chain of Ownership

    Investors should examine relevant previous transfers, including their dates and relationships between the parties, in accordance with the applicable administrative guidance.

    Particular attention should be paid to restrictions affecting properties involved in previous citizenship transactions and changes of ownership within relevant periods.

    6.2. Encumbrances and Legal Claims

    The land registry should be examined for mortgages, attachments, injunctions, preliminary sale agreements, usufruct rights, litigation annotations and other encumbrances.

    These matters may affect the investor’s ownership rights, ability to transfer the property and economic interests.

    6.3. Corporate Sellers

    Where the seller is a company, its commercial registry records, powers of representation and authority to dispose of the property should be verified.

    The legal status of the company and the relevant transaction should be evaluated independently from marketing materials supplied by brokers or sales representatives.

    The purpose of due diligence is not only to support a future citizenship application but also to protect the investor’s property and financial rights.

    VII. How Are Property Valuation Reports and the TTB Certificate Issued in 2026?

    One of the most important issues in current property-based citizenship applications is the Property Investment Amount Determination Certificate, known in Turkish as the Taşınmaz Edinim Sureti ile Vatandaşlık Kazanımına Esas Tutar Tespit Belgesi (TTB).

    Under the relevant circulars and procedures of the General Directorate of Land Registry and Cadastre, the TTB establishes the amount that may be accepted for citizenship purposes in relation to the particular real estate transaction.

    7.1. The Electronic Valuation System

    Valuation requests for citizenship-related transactions are made through the WebTapu and TADEBİS systems.

    The TTB is prepared as part of the relevant electronic process and transmitted to the land registry system.

    A sales brochure, privately prepared price estimate or unsigned PDF supplied by the seller cannot substitute for a properly issued TTB.

    7.2. September 2026 Changes to Valuation Rules

    The amendments to Circular No. 2024/4 adopted in September 2026 are particularly important.

    Under the updated official guidance, the valuation report supporting a TTB may be prepared by a valuation company authorised by the Capital Markets Board and satisfying the applicable system requirements.

    Accordingly, valuation for citizenship purposes is not necessarily restricted to a single designated appraisal company.

    7.3. Twelve-Month Validity

    Under the official guidance applicable in October 2026, the period between issuance of the TTB and the application for the relevant citizenship-related land registry transaction must not exceed twelve months.

    Where that period has expired, the underlying valuation report may need to be renewed.

    Separate considerations may apply to a transaction already completed while the certificate was valid.

    7.4. Special Circumstances Involving Real Estate Investment Trusts

    September 2026 amendments also address specific valuation arrangements for transactions involving real estate investment trusts and relevant appraisal reports published on the Public Disclosure Platform.

    Such exceptions require examination of the applicable special procedure rather than reliance on a general sales representation.

    Official source: Your Key Türkiye – TTB and Valuation Procedures.

    The central concern for an investor is to establish the officially acceptable investment amount before committing substantial funds.

    Investments very close to the statutory threshold may be particularly vulnerable to differences between the purchase price, payment evidence and officially accepted valuation.

    VIII. Why Are Genuine Bank Transfers and Foreign-Exchange Purchase Certificates Important?

    Payment procedures must comply with the requirements applicable to real estate investments intended for Turkish citizenship.

    Where required, the relevant foreign-currency amount must be sold to a bank operating in Türkiye for onward sale to the Central Bank of the Republic of Türkiye, and the transaction must be documented through the appropriate foreign-exchange purchase certificate, commonly called the DAB.

    The relationship between the investor, originating bank account, foreign-exchange transaction, seller and land registry transaction should be clear.

    8.1. Documentary Consistency

    Payment receipts, SWIFT records, bank account statements, foreign-exchange certificates, the sales contract and land registry records should be consistent.

    An unidentified or inadequately explained payment may create legal difficulties even where substantial funds were transferred.

    8.2. Genuine Payment Versus Circular Transfers

    Suppose an investor transfers USD 400,000 to a seller but subsequently receives a concealed repayment of part of the purchase price.

    The apparent payment may then become the subject of examination concerning whether the investment was genuinely completed.

    By contrast, an investor who genuinely paid the contractual price and received no refund may occupy a materially different legal position.

    8.3. Payment Through Third Parties

    Payments from corporate accounts, payments made by third parties and transactions involving more than one currency require individual legal analysis.

    The use of an intermediary should not be assumed to satisfy every statutory requirement without examination of the applicable banking rules.

    8.4. Warning Signs

    Investors should exercise caution where intermediaries propose undocumented cash arrangements, fictitious payment receipts or financial records that do not correspond to actual bank transactions.

    A foreign-exchange purchase certificate is important evidence, but it does not automatically establish the property’s true historical value or disprove all allegations of a sham transaction.

    IX. Can a Foreign Investor Acquire Turkish Citizenship by Purchasing Multiple Properties?

    Yes. Under the applicable rules, it may be possible to satisfy the required property investment amount through more than one eligible property.

    There is no general requirement that the entire investment amount must be represented by a single apartment.

    For example, an investor may purchase two eligible independent units with qualifying values of USD 220,000 and USD 210,000.

    However, the combined contractual amounts are not sufficient by themselves.

    Each property must satisfy the applicable eligibility rules, and its relevant price, official valuation, banking records and holding restrictions must be properly documented.

    9.1. Properties Acquired on Different Dates

    Where properties were acquired at different times, the applicable rules governing each transaction and the conditions for combining those investments must be evaluated.

    9.2. Shared Ownership

    Shared ownership must be distinguished from the full ownership of several separate units.

    According to the General Directorate of Land Registry and Cadastre’s guidance, properties acquired in shared ownership after February 1, 2023, cannot be used for exceptional citizenship applications through the relevant real estate investment route.

    Thus, purchasing a fractional interest in an apartment does not necessarily create eligibility even where that interest has a substantial economic value.

    Official source: Your Key Türkiye – Frequently Asked Questions.

    X. Can a Notarised Preliminary Real Estate Sale Agreement Qualify for Citizenship?

    Turkish citizenship legislation permits certain qualifying real estate sale-promise arrangements, subject to specific requirements.

    However, an ordinary reservation agreement, informal preliminary protocol or simple written promise is not equivalent to a sale-promise contract satisfying the citizenship rules.

    The required formalities, legal status of the property, documented payment and relevant land registry annotation must be examined.

    10.1. Properties Under Construction

    For properties under construction, the legal position of the independent unit is particularly important.

    Condominium easement rights, building permits, approved plans and the seller’s legal authority should be examined before payment.

    10.2. Payment and Registration Requirements

    A qualifying preliminary sale arrangement may require full payment of the applicable amount and registration of the prescribed undertaking concerning transfer or cancellation of the annotated right for the statutory period.

    Those requirements must be distinguished from the payment terms of an ordinary private commercial agreement.

    10.3. Risk of Uncompleted Developments

    Where an independent unit is not properly identified in the land registry or the project does not satisfy the relevant requirements, making substantial advance payments may expose the investor to financial and legal risks.

    For such projects, payment conditions, construction completion obligations, cancellation provisions and citizenship-related documentation should be addressed before signing.

    XI. What Is the Legal Meaning of the Three-Year Non-Sale Undertaking?

    Property-based citizenship investments require the investment to be maintained for the statutory period.

    For qualifying completed property purchases, the land registry records must contain the required three-year non-sale undertaking.

    The relevant dates must be determined from the actual transaction and the applicable rules.

    An investor cannot assume that obtaining citizenship immediately permits unrestricted sale of the qualifying property.

    Sale or other conduct inconsistent with the undertaking during the prescribed period may give rise to serious administrative consequences.

    11.1. Sale After Three Years

    Once the statutory undertaking has been duly fulfilled, the investor may consider selling the property subject to the applicable land registry procedures.

    Sale following lawful completion of the holding period does not automatically mean that Turkish citizenship must be lost.

    11.2. Historical Irregularities

    Nevertheless, expiry of the three-year period does not necessarily prevent subsequent examination of allegations that the original citizenship acquisition was based on fraudulent or legally non-compliant transactions.

    The lawful completion of a holding obligation and the legality of the original investment are separate questions.

    XII. Alternative Routes to Turkish Citizenship Through USD 500,000 Investments

    Foreign investors who do not wish to purchase real estate may consider other investment options, each subject to its own eligibility and verification requirements.

    A. Bank Deposits

    A qualifying deposit of at least USD 500,000 or the legally recognised equivalent may support exceptional citizenship where the amount is maintained for at least three years in a bank operating in Türkiye and the competent authority confirms compliance.

    The Banking Regulation and Supervision Agency is relevant to the conformity determination.

    The bank’s willingness to open an account should not be confused with a final finding that the citizenship investment requirements have been fulfilled.

    The three-year maintenance undertaking, applicable restrictions, banking arrangements, currency conversion rules and early withdrawal consequences should be clarified before the transaction.

    B. Real Estate Investment Funds and Venture Capital Investment Funds

    An investor may qualify by acquiring eligible real estate investment fund or venture capital investment fund participation shares of at least USD 500,000 or the applicable foreign-currency equivalent and retaining those shares for at least three years.

    This investment route is supervised through procedures involving the Capital Markets Board of Türkiye and the Central Securities Depository, known as MKK.

    Compliance requires the relevant investment, ownership records, documentation and applicable blocking or holding arrangements.

    Purchasing fund shares through a financial intermediary does not automatically complete the entire certification process.

    The fund’s investment strategy, liquidity, management expenses, market risks and holding conditions should also be evaluated.

    The Capital Markets Board’s official guidance distinguishes voluntary reductions of holdings from changes in the fund’s value arising independently of the investor’s decision.

    A reduction below the initial USD 500,000 reference amount caused solely by exchange-rate movements does not necessarily have the same consequence as an investor voluntarily disposing of part of the qualifying holding.

    Official source: Capital Markets Board – Exceptional Citizenship Through Investment Funds.

    C. Government Debt Instruments

    Purchasing eligible Turkish government debt instruments with a minimum qualifying amount of USD 500,000 or its legally recognised equivalent may support an application where the instruments are held for the required three-year period.

    The nature of the instruments and compliance determination by the Ministry of Treasury and Finance must be examined.

    Investment risk, maturity and other financial considerations are separate from the nationality eligibility process.

    D. Fixed Capital Investment

    A fixed capital investment of at least USD 500,000 may qualify where the Ministry of Industry and Technology determines that the statutory requirements have been fulfilled.

    However, merely establishing a company or transferring funds to its bank account does not automatically establish that an eligible fixed capital investment has been completed.

    The nature of the investment, acquired assets, financial records and the competent ministry’s examination are relevant.

    E. Employment Creation

    Creating employment for at least 50 persons constitutes another qualifying route under the statutory framework.

    The relevant ministry must determine compliance with the requirements.

    Merely signing employment contracts with 50 people is not necessarily sufficient without examining the actual employment arrangements and official employment records.

    F. Private Pension System

    The private pension investment route requires a qualifying contribution of at least USD 500,000 or its legally recognised equivalent and maintenance of the investment in the prescribed funds and system for three years.

    The Insurance and Private Pension Regulation and Supervision Agency is relevant to the applicable certification process.

    The chosen pension arrangement, investment risks, fund eligibility and conditions governing continued participation should be reviewed.

    Comparative assessment: Property ownership, bank deposits, investment funds, government debt instruments, fixed capital and employment creation involve different financial risks, liquidity conditions and administrative verification requirements.

    The most appropriate investment route depends not only on the minimum amount but also on the investor’s financial circumstances, objectives and legal position.

    XIII. Which Legal and Technical Checks Should Be Completed Before Investing?

    One of the most effective forms of investor protection is comprehensive due diligence conducted before executing the investment.

    In a real estate transaction, this should extend beyond examining a copy of the current title deed.

    13.1. Ownership and Land Registry Examination

    The property’s legal owner, registered characteristics, encumbrances and relevant previous transfers should be verified.

    13.2. Planning and Construction Records

    Depending on the property, zoning records, construction permits, occupancy permits, development plans and the actual physical condition should be considered.

    13.3. The Seller’s Legal Authority

    Where the seller is a construction company, its commercial registry records and authorised representatives should be examined.

    It is necessary to determine whether the person signing the agreement is entitled to dispose of the property.

    13.4. Uncompleted Developments

    For ongoing construction projects, delivery deadlines, construction obligations, contractual remedies, the financial standing of the developer and insolvency-related risks should be considered.

    13.5. Independent Assessment

    Due diligence should not depend exclusively on representations supplied by the seller or marketing company.

    The seller’s commercial interest in completing the transaction may not fully coincide with the investor’s legal interest in obtaining a compliant and secure qualifying investment.

    Independent legal and technical assessments can identify potential inconsistencies before they become disputes.

    XIV. How Does the Turkish Citizenship-by-Investment Application Process Work in 2026?

    Exceptional naturalisation through investment involves several administrative stages.

    14.1. Completion of the Qualifying Investment

    The investor must first complete one of the investment types permitted under Article 20 of the implementing Regulation in accordance with the applicable conditions.

    14.2. Investment Conformity Determination

    The relevant public authority must determine that the investment satisfies the prescribed requirements and issue the appropriate conformity documentation.

    For property investments, land registry transactions, valuation, holding restrictions and the Property Investment Determination Certificate are particularly important.

    14.3. Residence Permit Stage

    The applicant’s short-term residence permit status is examined under Article 31(1)(j) of Law No. 6458 on Foreigners and International Protection.

    The relevant administrative procedure should be assessed according to the applicant’s circumstances and the current implementation rules.

    14.4. Nationality Application

    The investor subsequently submits the citizenship application to the competent population and citizenship authority through the prescribed process.

    Relevant documentation may include identification records, passport information, civil-status documents, information concerning family members and other supporting materials.

    14.5. Security and Public-Order Examination

    The administrative evaluation also includes the applicable national-security and public-order considerations.

    14.6. Final Decision

    The competent state authority issues the decision concerning acquisition of citizenship.

    The completion of a qualifying investment and the issuance of the final citizenship decision are not the same event.

    Investors should not assume that all applications are completed within a guaranteed period. Requests for additional documentation or other administrative examinations may affect processing times.

    Official source: Citizenship Application Procedures – Directorate General of Population and Citizenship Affairs.

    XV. Can the Investor’s Spouse and Children Also Acquire Turkish Citizenship?

    Exceptional naturalisation through investment may include certain qualifying family members, subject to the applicable legal conditions.

    These may include the investor’s foreign spouse and children who meet the relevant statutory requirements.

    However, it should not be assumed that every family member automatically has the same legal status or qualifies independently of their personal circumstances.

    15.1. Age and Dependency

    The child’s age, dependency status and the dates of application and decision may be important.

    For example, special questions may arise where a child is 17 when the family application begins but reaches the age of 18 before the procedure is concluded.

    The applicable administrative rules and the child’s individual legal position must be examined.

    15.2. Marriage and Family Documentation

    Marriage certificates, birth records, custody arrangements and other relevant civil-status documents may need to be submitted in the required authenticated form.

    Differences in names, dates or civil-status records between jurisdictions can create complications.

    15.3. Family Changes During the Application

    Marriage, divorce, the birth of a child or changes in custody during the application period may require further documentation or separate legal consideration.

    A properly prepared family application should address these issues before they delay the process or create future nationality disputes.

    XVI. Can an Investor Complete the Procedures Without Travelling to Türkiye?

    Many prospective investors reside outside Türkiye and wish to conduct part of the investment and application process through an authorised representative.

    Turkish law permits certain transactions and applications to be completed through a valid power of attorney.

    However, property purchases, investment documentation, residence permits and nationality procedures are governed by different requirements.

    16.1. Powers of Attorney

    For transactions undertaken by an attorney-in-fact, the power of attorney must contain the authority required for the relevant legal act.

    A general authorisation for legal representation may not be sufficient for every property transaction or administrative application.

    16.2. Powers of Attorney Issued Abroad

    Foreign powers of attorney may require an apostille or another form of legalisation, depending on the issuing country and applicable international treaties.

    Certified Turkish translations and additional formalities may also be required.

    16.3. Procedures Requiring Personal Attendance

    Certain stages, including biometric enrolment or fingerprinting, may require the individual’s personal presence.

    Accordingly, the ability to purchase property through a representative does not automatically establish that the entire nationality process can be completed without any personal attendance.

    Before issuing the power of attorney, the proposed wording should be reviewed against the requirements of the specific transaction and competent authority.

    XVII. Is Turkish Citizenship Guaranteed After Investing USD 400,000?

    No. The satisfaction of the prescribed investment requirement does not create an unconditional guarantee that Turkish citizenship will be granted.

    Exceptional naturalisation under Article 12 of Law No. 5901 requires a decision by the competent state authority.

    For example, an investor may lawfully purchase qualifying property worth USD 400,000, provide all relevant financial documents and obtain the investment conformity certificate.

    Nevertheless, additional questions may arise during the citizenship examination, including matters relating to security and public order.

    Therefore, completion of the investment documentation is not equivalent to guaranteed approval.

    Private developers, intermediaries, consultancy firms and attorneys should not promise a certain outcome in relation to a decision reserved to the state.

    The proper function of legal advice is to examine compliance, identify risks, assist with the application and protect the applicant’s rights where disputes arise.

    XVIII. What Do the 2025 and 2026 Citizenship Investigations Mean for New Investors?

    Investigations and administrative reviews conducted in 2025 and 2026 have brought attention to earlier citizenship applications involving allegedly irregular property transactions.

    Publicly reported allegations include inflated valuation reports, payments that were not genuinely completed and banking arrangements allegedly structured to simulate investment compliance.

    However, these investigations do not establish that all investment-based citizenship acquisitions were unlawful or that prospective investors are no longer eligible to apply.

    The principal lesson for new investors concerns the importance of understanding how documentary or financial irregularities may arise at different transaction stages.

    The greater the consistency between the actual payment, property valuation, land registry transaction and official conformity certificate, the more transparent the investment’s legal position becomes.

    Investors considering a development linked to a previous investigation should examine whether the relevant circumstances affect the property or transaction under consideration.

    The existence of an investigation concerning a company does not necessarily mean that all its properties are legally ineligible.

    Equally, the absence of a known investigation concerning a seller does not guarantee that a proposed transaction contains no legal risk.

    For further analysis, see our study concerning the investigation involving 1,070 individuals and our review of official figures and international media coverage.

    XIX. Can a New Investor’s Turkish Citizenship Be Cancelled or Withdrawn in the Future?

    Acquisition of Turkish citizenship does not mean that the original decision is necessarily immune from all subsequent legal examination.

    Articles 31 and 40 of Turkish Citizenship Law No. 5901 provide distinct legal mechanisms.

    19.1. Article 31: Cancellation Based on False Declarations or Concealment

    Article 31 concerns cancellation where the individual acquired citizenship through false declarations or concealment of material circumstances forming the basis of the decision.

    The nature of the individual’s conduct and its connection with the original acquisition must be examined.

    19.2. Article 40: Withdrawal Because the Statutory Conditions Were Absent

    Article 40 addresses withdrawal where the citizenship decision was issued without the required legal conditions or as a duplicate.

    It therefore raises a different legal question concerning whether the objective requirements for acquisition were present at the time.

    19.3. The Importance of Good Faith

    Suppose an investor genuinely pays the purchase price but the developer is subsequently accused of deliberately inflating the appraisal.

    The investor’s knowledge of the irregularity and the actual value of the property on the relevant date are distinct questions.

    Even if the investor prepared no forged document, a separate administrative dispute may arise if the property’s genuine historical value failed to satisfy the applicable minimum requirement.

    Accordingly, avoiding fraudulent conduct is essential, but the investor should also ensure that the transaction objectively satisfies the statutory conditions.

    For detailed discussion, see Can a Genuine Investor Lose Turkish Citizenship? Property Valuation Errors, Banking Evidence and Judicial Protection.

    XX. Which Contractual Safeguards Should Protect a Foreign Investor?

    A real estate sale agreement intended to support Turkish citizenship should do more than identify the property and purchase price.

    The parties’ obligations relating to the citizenship investment transaction should be expressly addressed where appropriate.

    20.1. Representations Concerning Legal Eligibility

    The seller may provide contractual representations concerning the property’s legal characteristics, disclosed encumbrances, previous ownership and information known to affect its suitability for the intended investment.

    20.2. Conditions Precedent to Payment

    Where the official valuation or legal eligibility has not yet been confirmed, it may be appropriate to link payment obligations to specified preliminary conditions, provided that the arrangement remains consistent with the relevant citizenship investment requirements.

    20.3. Remedies for Contractual Non-Compliance

    The agreement may address the consequences of failure to transfer the property, defects in title, inaccuracies in contractual representations and breaches of the seller’s obligations.

    Depending on the transaction, withdrawal rights, repayment conditions, agreed contractual remedies and compensation arrangements may be considered.

    20.4. Secure Payment Arrangements

    Transferring the entire purchase price before obtaining the relevant protections may expose an investor to substantial financial risk.

    Any escrow, staged payment or alternative protection arrangement must be structured consistently with the banking and payment documentation required for a qualifying citizenship investment.

    20.5. The Limits of Contractual Guarantees

    A seller cannot contractually bind the Turkish state to grant citizenship.

    However, the seller may accept enforceable private-law obligations concerning its own representations, contractual performance and the consequences of its misconduct.

    The distinction between guaranteeing the state’s nationality decision and assuming contractual liability for the seller’s own conduct is fundamental.

    XXI. What Legal Remedies Are Available If a Citizenship Application Is Rejected?

    Where an investment-based citizenship application is rejected, the first task is to identify the legal nature and reasons for the adverse decision.

    For example, refusal to issue an investment certificate of conformity is not necessarily the same administrative act as a final refusal of naturalisation.

    The issuing authority, applicable legal rules, procedural requirements, filing deadline and competent court may differ.

    21.1. Administrative Judicial Review

    Under Article 7 of Administrative Judicial Procedure Law No. 2577, the general filing period in administrative litigation is 60 days unless another applicable statutory period is prescribed.

    However, the starting date, competent judicial authority and available remedies must be examined in the context of the actual decision.

    21.2. Contractual and Financial Remedies

    An investor may also consider rights arising from the property purchase contract where the seller failed to fulfil its own obligations.

    These may involve restitution, termination or compensation under the applicable private-law rules.

    Such claims are distinct from an administrative action challenging a citizenship decision.

    21.3. The State Is Not Automatically Responsible for Refunding a Property Purchase

    Rejection of a nationality application does not automatically require the Turkish state to refund the price paid to a private seller.

    Any claim for repayment or damages must be based on the relevant contractual or statutory grounds and assessed according to the facts.

    A single standard lawsuit should not be assumed to address every consequence of a rejected investment-based citizenship application.

    XXII. Frequently Asked Questions About Turkish Citizenship by Investment in 2026

    1. Has Türkiye closed its citizenship-by-investment programme?

    No. As of October 22, 2026, the relevant legal framework and official public guidance continue to recognise exceptional naturalisation through qualifying investment.

    2. Does investing USD 400,000 guarantee Turkish citizenship?

    No. The investment must satisfy all relevant legal conditions, and the competent authority must issue a positive naturalisation decision.

    3. Can I qualify by purchasing undeveloped land?

    Undeveloped land without the required buildings and agricultural property cannot be used as qualifying property investments under the relevant rules applicable in 2026.

    4. Can I buy two apartments worth USD 200,000 each?

    Multiple eligible properties may be combined. However, each transaction must satisfy the relevant legal and documentation requirements, and the officially accepted aggregate amount must reach the required threshold.

    5. Can I sell my property after three years?

    Sale may be possible after lawful completion of the holding requirement and the necessary land registry procedures. Historical irregularities in the original investment may nevertheless remain subject to lawful examination.

    6. Does depositing USD 500,000 in a Turkish bank guarantee citizenship?

    No. The qualifying deposit and official conformity determination form part of the process. The final nationality decision is separate.

    7. Can I complete the process without visiting Türkiye?

    Certain transactions may be conducted through a valid representative. However, some residence or citizenship stages, including biometric procedures, may require personal attendance.

    8. How long does the citizenship application take?

    There is no universal guaranteed processing period. The relevant investment, documentation, security examination and administrative procedures may affect the timeline.

    9. Can my spouse and children obtain citizenship?

    Eligible family members may be included under the applicable conditions. Age, dependency, civil status and documentation must be assessed individually.

    10. Can a new investor’s citizenship later be cancelled?

    Possible future cancellation or withdrawal depends on the statutory grounds and the individual facts. The mere existence of investigations concerning earlier investors does not establish that every new application is at risk.

    11. Is relying on the official valuation company sufficient?

    Proper official valuation is important, but independent verification of the property’s legal and economic characteristics may provide additional protection.

    12. If my citizenship application is rejected, will the government refund my investment?

    Not automatically. Reimbursement or compensation may depend on the relevant contract and the legal responsibility of the parties involved.

    XXIII. Conclusion: Legal Security Should Be the Priority in Citizenship-by-Investment Transactions

    Exceptional acquisition of Turkish citizenship through investment remains legally possible in 2026.

    Qualifying routes include real estate purchases, bank deposits, fixed capital investment, investment funds, government debt instruments, private pension investments and employment creation.

    Nevertheless, the legality of a citizenship application cannot be determined solely by the amount invested.

    For property-based naturalisation, the property’s legal characteristics, historical ownership, genuine market value, banking records, foreign-exchange procedures, TTB documentation and three-year holding obligations must be examined together.

    The administrative reviews and criminal investigations of 2025 and 2026 demonstrate why prospective investors should not focus exclusively on obtaining an initial citizenship approval.

    The relevant legal conditions must actually exist when the citizenship decision is granted, and the investment should be capable of being substantiated through reliable documentation if subsequently examined.

    Accordingly, investor protection should not depend solely on a certificate of conformity or on promises made by a developer, broker or intermediary.

    Independent examination of the investment’s legal and economic characteristics, transparent banking procedures, appropriate valuation, properly prepared contracts and an accurate understanding of the administrative process are essential.

    The existence of cancellation and withdrawal mechanisms under Articles 31 and 40 of Turkish Citizenship Law No. 5901 further demonstrates the importance of legal due diligence before the investment is completed.

    The fundamental objective for a prospective investor in 2026 should not be merely to make a sufficiently large investment, but to complete a genuine, legally compliant, verifiable investment supported by reliable official records.

    The authority to grant Turkish citizenship belongs to the Turkish state. At the same time, protecting the investor’s ownership rights, financial interests and legal security must remain a central concern from the very beginning of the transaction.

    Legislation, Official Sources and Academic References

    1. Turkish Citizenship Law No. 5901. Particularly Articles 12, 31 and 40. Official legislation.
    2. Regulation on the Implementation of the Turkish Citizenship Law. Particularly Article 20 and the relevant amendments.
    3. Land Registry Law No. 2644. Particularly Articles 35 and 36.
    4. Law No. 6458 on Foreigners and International Protection. Particularly Article 31(1)(j).
    5. General Directorate of Land Registry and Cadastre. Circular No. 2024/4, including amendments applicable in September and October 2026, concerning citizenship through real estate acquisition and investment amount determination. Your Key Türkiye.
    6. General Directorate of Land Registry and Cadastre. Circular No. 2024/2 and relevant valuation procedures. Official TTB information.
    7. Directorate General of Population and Citizenship Affairs. Citizenship Services – Frequently Asked Questions. Official information.
    8. Invest in Türkiye. Acquiring Property and Citizenship – Investment Guide. Official English-language guide.
    9. Capital Markets Board of Türkiye. Exceptional Acquisition of Turkish Citizenship Through Investment. Official regulatory guidance.
    10. Özgür, Çiçek. “Yatırım Yoluyla Kazanılan Türk Vatandaşlığının İptali ve Geri Alınması” [Cancellation 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.
    11. Dülger, Ahmet. “Taşınmaz Satın Alınmasıyla Türk Vatandaşlığının İstisnai Yoldan Kazanılmasında Değerleme Raporu ve Uygunluk Belgesi Alınması” [Valuation Reports and Certificates of Conformity in Exceptional Turkish Citizenship Acquisition Through Property Purchase]. İnönü Üniversitesi Hukuk Fakültesi Dergisi, Vol. 16, No. 1, 2025, pp. 167–180. DOI: 10.21492/inuhfd.1600688.
    12. Administrative Judicial Procedure Law No. 2577. Particularly Articles 7, 11 and 27, concerning filing periods, administrative applications and suspension of execution.

    Author and Contact Information

    Attorney Murat Can Dolğun
    Istanbul Bar Association
    TD Law Firm & Legal Consultancy
    Lecturer in Law – Istanbul University-Cerrahpaşa

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

    Office: Istanbul World Trade Center (IDTM), Block A2, Floor 5, Office 206, Yeşilköy, Bakırköy, Istanbul, Türkiye.

    Telephone: +90 212 299 44 22
    WhatsApp: +90 507 475 44 22
    Website: dolgun.av.tr

    Legal Disclaimer: This article is intended for general academic and legal information. It does not constitute individual legal or financial advice, nor does it guarantee Turkish citizenship, a particular investment result or the outcome of administrative proceedings. Laws, investment requirements, valuation procedures and administrative practices may change. The current legal framework and the relevant investor’s individual circumstances should be verified before completing any transaction.

    © 2026 DOLĞUN AKADEMİ | ATTORNEY MURAT CAN DOLĞUN

  • Can a Genuine Investor Lose Turkish Citizenship? 2026

    Can a Genuine Investor Lose Turkish Citizenship? 2026

    DOLĞUN AKADEMİ | TURKISH CITIZENSHIP LAW | 2026

    Can a Genuine Investor Lose Turkish Citizenship? 2026 Legal Analysis of Property Valuation Errors, Banking Records, Preservation of Evidence and Judicial Protection

    Author: Attorney Murat Can Dolğun

    Publication: TD Law Firm & Legal Consultancy – Dolğun Akademi

    Original Publication Date: October 22, 2026

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

    Abstract

    Administrative reviews and criminal investigations concerning Turkish citizenship acquired through investment in 2025 and 2026 have raised an important legal question: Can a foreign investor who genuinely purchased real estate, transferred the purchase price through the banking system, obtained title to the property, relied upon an official valuation report and did not participate in any fraudulent activity subsequently lose Turkish citizenship?

    The question cannot be answered through a single universal rule.

    Under Turkish law, cancellation of a citizenship acquisition decision because of false declarations or concealment of material facts by the individual is legally distinct from withdrawal of a citizenship decision where the statutory requirements for acquisition were not actually satisfied.

    The distinction between Articles 31 and 40 of Turkish Citizenship Law No. 5901 is particularly important for genuine and good-faith investors.

    The fact that an investor genuinely transferred the purchase price does not necessarily establish that the property met the required statutory investment value at the relevant time.

    Conversely, an error in a valuation report does not automatically establish that the property’s actual historical value fell below the investment threshold or that the investor knew about the error.

    Accordingly, the evaluation of a citizenship file should address actual financial transfers, the legal requirements applicable on the investment date, the property’s historical value, the technical reliability of valuation reports, the investor’s knowledge and conduct, and the administration’s earlier examination of the investment.

    This study considers the evidentiary significance of bank statements, retrospective real estate valuation, independent expert opinions, preservation of evidence under Articles 400–403 of Civil Procedure Code No. 6100, the interaction between criminal investigations and administrative decisions, and judicial protection against citizenship cancellation or withdrawal.

    The analysis reflects the legislation, academic research and publicly available legal materials examined as of October 22, 2026.

    I. Why Are Genuine Foreign Investors Facing Citizenship Revocation Risks in 2026?

    Citizenship files involving foreigners who acquired Turkish nationality through real estate investment have become the subject of renewed administrative examinations and criminal investigations.

    Publicly reported investigations concern whether the required property purchase prices were genuinely paid, whether foreign-currency funds actually entered Türkiye, whether appraisal reports accurately reflected market values and whether certain real estate transactions were fictitious.

    According to the Ministry of Interior’s publicly reported statement of September 21, 2026, decisions concerning 5,391 individuals were associated with cancellation of citizenship acquisition decisions and 743 individuals with withdrawal measures, producing a reported total of 6,134 individuals including family members.

    A further investigation announced on the same date concerned 1,070 individuals comprising 263 principal investors and 807 family members.

    However, being identified within the scope of the investigation involving 1,070 people must be distinguished from the issuance of a final individual administrative decision cancelling the citizenship of every person concerned.

    The factual and procedural circumstances of each individual must be examined separately.

    Two foreign investors who purchased apartments from the same developer may occupy materially different legal positions.

    The amount actually paid, source of funds, property’s real value, arrangements with the seller, banking evidence and the investor’s knowledge of any irregularities may differ significantly.

    The existence of a broad investigation does not establish that all purchasers must necessarily be subjected to identical administrative or criminal consequences.

    For the general developments and official figures, see our earlier study The Turkish Citizenship Investigation Concerning 1,070 Individuals in 2026.

    II. A Genuine Investment Is Not Necessarily a Legally Sufficient Investment

    One of the most common conceptual mistakes in citizenship-by-investment disputes is treating evidence of a genuine payment as equivalent to proof that all statutory investment requirements were satisfied.

    Consider a foreign investor who actually transferred USD 400,000 through the banking system, paid the seller, obtained registered ownership of an apartment and received no refund.

    These circumstances provide significant evidence of a genuine financial transaction.

    Nevertheless, a separate question may arise concerning whether the property had the legally required market value at the relevant acquisition date and whether all other statutory requirements were satisfied.

    The opposite situation is also possible.

    A property may have possessed a historical market value exceeding the applicable minimum investment threshold, but the investor may nevertheless have failed to fulfil a separate mandatory banking, documentation or procedural requirement.

    Accordingly, three questions must be distinguished:

    1. Was the property sale a genuine economic and legal transaction?
    2. Did the investment satisfy the objective statutory requirements applicable at the relevant date?
    3. Did the investor personally engage in any legally relevant misrepresentation, concealment or fraudulent conduct?

    The answers to these questions may differ.

    An administrative authority should not automatically equate an investment shortfall with criminal fraud. Equally, evidence of genuine payment should not be treated as automatically resolving all requirements under citizenship legislation.

    This distinction is essential to a properly individualised legal assessment.

    III. Article 31 of Turkish Citizenship Law: False Declarations and Concealment of Material Facts

    Article 31 of Turkish Citizenship Law No. 5901 regulates cancellation of a decision granting Turkish citizenship where citizenship was acquired as a result of false declarations by the individual or concealment of material circumstances forming the basis of the acquisition.

    The wording and purpose of this provision require examination of the individual’s conduct and its relationship with the naturalisation decision.

    The mere identification of an irregularity in a transaction does not, by itself, resolve whether the requirements of Article 31 have been fulfilled.

    For example, if investigators allege that a property valuation report was deliberately inflated by an appraisal professional, it may be necessary to determine whether the investor instructed that professional to alter the result, attempted to influence the valuation, knew the report was inaccurate or knowingly submitted false information.

    The existence of an investigation concerning an appraisal company does not establish that every investor who relied upon one of its reports knew that the report was inaccurate.

    Similarly, allegations that a property developer conducted fictitious financial transactions in other sales do not establish that a purchaser who genuinely paid the price participated in those arrangements.

    In an Article 31 assessment, the investor’s declarations, knowledge, participation and other individual conduct must be examined through legally relevant evidence.

    An incorrect appraisal and a knowingly false declaration by the investor are not legally interchangeable.

    IV. Article 40: Withdrawal Where the Legal Conditions for Citizenship Were Absent

    Article 40 establishes a different administrative mechanism.

    Under this provision, decisions relating to the acquisition or loss of Turkish citizenship may be withdrawn where they were issued without the required legal conditions or as duplicate decisions.

    The central question is whether the statutory conditions existed when the original citizenship acquisition decision was made.

    An investor may have genuinely purchased the property, paid the complete contractual price, avoided the use of forged documents and participated in no fraudulent arrangement.

    Nevertheless, an administrative dispute may arise if the authorities contend that the property’s actual historical value did not meet the investment threshold applicable at the time.

    Consequently, reliance solely on the investor’s good faith may not be sufficient to address an Article 40 dispute.

    The historical value of the investment and other objective statutory conditions may require documentary and technical proof.

    However, Article 40 should not be interpreted as giving the administration unlimited power to terminate earlier citizenship decisions without identifying an adequate legal and factual basis.

    The statutory requirements, material facts and legal reasoning underlying a withdrawal decision remain subject to judicial scrutiny.

    In her 2026 academic article, Çiçek Özgür examines the distinction between cancellation and withdrawal in investment-based naturalisation, including questions concerning the legal basis for cancellation where the required investment is not maintained for the prescribed period.

    See: Çiçek Özgür, “Yatırım Yoluyla Kazanılan Türk Vatandaşlığının İptali ve Geri Alınması,” Ankara University Faculty of Law Journal, 2026.

    Our previous article also examines this distinction: Cancellation and Withdrawal of Turkish Citizenship Acquired Through Investment.

    V. Was the Required Real Estate Investment USD 250,000 or USD 400,000?

    When assessing historical citizenship acquisitions, one of the first requirements is to identify the legislation applicable on the date of the original transaction.

    The minimum property investment threshold changed during the operation of Türkiye’s citizenship-by-investment framework.

    Acquisition Period Minimum Property Investment
    January 12, 2017 – September 18, 2018 USD 1,000,000
    September 19, 2018 – June 12, 2022 USD 250,000
    June 13, 2022 onwards USD 400,000

    This chronology has direct legal significance.

    For example, a property acquired for citizenship purposes in 2020 cannot be considered insufficient merely because its value was below the USD 400,000 minimum introduced in 2022.

    For the appropriate historical assessment, the property acquisition date, payment dates, applicable form of transaction, investment certificate and legal provisions governing the original application must be examined together.

    The acquisition method may also matter. Requirements concerning completed sales, preliminary sale agreements, property categories, annotations in the land registry and other restrictions have changed over time.

    Accordingly, the monetary threshold is not the only legal requirement.

    Official source: General Directorate of Land Registry and Cadastre – Your Key Türkiye, Citizenship Acquisition.

    VI. What Do Genuine Bank Transfers Prove in a Citizenship Investigation?

    Banking records are among the most important forms of evidence in disputes involving citizenship through real estate investment.

    For investors residing outside Türkiye, it is particularly important to reconstruct the entire financial sequence rather than relying solely on one payment receipt.

    The investigation should examine the original source account, any intermediary banks, the recipient account in Türkiye, the applicable foreign-exchange transactions and the relationship between the payment and the registered property sale.

    Relevant documents may include SWIFT transfer confirmations, certified account statements, bank transaction references, payment instructions, foreign-exchange purchase certificates and the seller’s financial records.

    Consideration of those documents together may provide a reliable basis for evaluating whether the transaction was genuine.

    6.1. A Single Receipt May Not Be Sufficient

    A bank receipt demonstrates that a transaction was recorded, but may not explain every aspect of the underlying economic arrangement.

    Investigators may examine whether the payment was subsequently refunded, transferred to an associated person or circulated through multiple accounts.

    Accordingly, the financial records should, where possible and legally obtainable, demonstrate both the original transfer and relevant subsequent movements.

    6.2. Genuine Payment and Circular Payments

    An investor may have transferred USD 400,000 to the seller and never received any portion of the purchase price back.

    By contrast, another transaction may have involved the apparent payment of the required amount followed by repayment through a concealed arrangement.

    The legal and evidentiary positions of those investors are not identical.

    However, even proof that no refund occurred does not automatically resolve a separate technical dispute over the property’s historical market value.

    6.3. The Evidentiary Chain

    The strongest assessment usually involves a coherent chronological chain: source of funds, bank transfer, receipt by the seller, contractual payment obligation, title deed transfer and subsequent financial records.

    Where inconsistencies appear, they should be addressed through reliable primary documents rather than unsupported assumptions.

    VII. If the Property Valuation Report Is Incorrect, Can the Genuine Investor Lose Citizenship?

    An error in an appraisal report and proof that the property’s actual value was below the statutory investment threshold are different matters.

    Suppose an original report indicated that the property was worth USD 450,000.

    Several years later, a newly appointed expert retrospectively values the property at USD 370,000 on the original investment date.

    The difference is significant, but the legal examination cannot properly end with the comparison of two figures.

    The reports should be assessed according to their valuation methodologies, comparable sales, assumptions about the property’s characteristics and the economic conditions prevailing when the property was acquired.

    In a different example, an original appraisal may show a value of USD 450,000 while a reliable retrospective appraisal determines a historical value of USD 415,000.

    Although the original report may have overstated the property’s value, the later technical result would not, by itself, establish that the investment fell below a USD 400,000 threshold applicable to that transaction.

    Therefore, the decisive question is not simply whether the initial valuation was inaccurate.

    The essential question is whether the property actually satisfied the statutory value requirement at the legally relevant date.

    Separately, the investor’s knowledge of any alleged misrepresentation must be examined where personal misconduct forms part of the applicable legal grounds.

    VIII. How Should a Retrospective Real Estate Valuation Be Conducted?

    Retrospective valuation in nationality litigation is not an ordinary search for current real estate prices.

    It requires a reasoned reconstruction of the property’s characteristics and market conditions as they existed on the relevant historic date.

    Suppose an apartment was purchased in 2021 and its historical value is examined in 2026.

    Relying solely on property advertisements published in 2026 would generally be insufficient to establish the apartment’s value in 2021.

    8.1. Physical and Technical Characteristics

    A competent retrospective assessment may need to consider the property’s floor, orientation, location, construction quality, net and gross area, delivery condition, completion stage and available infrastructure at the time of acquisition.

    In projects under construction, the completion stage may significantly affect value.

    The value of a completed apartment should not automatically be treated as equivalent to its value when the project was at an earlier construction stage.

    8.2. Comparable Property Transactions

    Where reliable evidence is available, completed transactions involving comparable units within the same development or nearby projects may provide important reference points.

    Comparable properties should be evaluated in light of their physical condition, floor, location, size, amenities, date of sale and transaction terms.

    Advertised prices should not be automatically equated with actual completed sale prices.

    8.3. Individual Units Versus Entire Land Parcels

    A further technical problem may arise where an expert report determines the average value of an entire parcel or development rather than the value of the particular unit purchased by the investor.

    For example, the average square-metre value of an undeveloped main parcel may differ materially from the value attributable to a specific apartment on the tenth floor of a building.

    The use of general parcel-level calculations to estimate an individual unit’s historic value requires a reliable explanation of the adjustments made.

    8.4. Exchange Rates and Property Price Indices

    Historical exchange rates, inflation data and real estate price indices may provide supporting analytical information.

    However, a general index does not necessarily establish the actual market value of a specific apartment on a particular historical date.

    Its use should be supported by property-specific evidence and an appropriate valuation methodology.

    8.5. Scientific and Technical Reliability

    The valuation should clearly identify its effective date, available data, assumptions, limitations, selection of comparables, adjustments and reasoning.

    A conclusion unsupported by a transparent methodology may be vulnerable to technical challenge.

    IX. Can an Independent Technical Report Challenge an Official Expert Valuation?

    Where a new expert report has been prepared during an administrative examination or criminal investigation, it may be possible to obtain an independent technical assessment.

    However, a meaningful counter-expert report should do more than merely state a higher value.

    It should identify the original report’s data sources, methodology, assumptions and technical conclusions, and explain why any particular findings are considered unreliable.

    For example, relevant objections may concern inaccurate measurements, inappropriate comparable properties, incorrect assumptions about construction completion, the use of market data from the wrong period or failure to account for the characteristics of the individual unit.

    Those objections should be supported by documents and verifiable technical reasoning.

    9.1. The Importance of Objective Comparables

    An independent valuation should not selectively rely only on transactions favourable to the investor.

    A scientifically reliable assessment should consider both favourable and unfavourable market evidence and explain the significance of each comparable transaction.

    9.2. Practical Legal Uses

    An independent technical opinion may be relevant when preparing submissions to the administration, assessing evidence used by prosecutors, challenging an existing expert report or requesting further expert examination in judicial proceedings.

    However, a privately commissioned report does not have the same procedural character as a report produced by an expert officially appointed by a court or prosecutor.

    The final assessment of its evidentiary significance belongs to the competent authority or court.

    For an academic analysis of the valuation process, see Ahmet Dülger’s study on appraisal reports and certificates of conformity in exceptional Turkish citizenship acquisition through real estate.

    Ahmet Dülger, İnönü University Law Review, 2025.

    X. Can a Genuine Investor Request Court-Ordered Preservation of Evidence?

    Articles 400 and following of Turkish Civil Procedure Code No. 6100 regulate preservation of evidence under specified conditions, including before the commencement of a civil lawsuit or during pending proceedings.

    Depending on the circumstances, preservation of evidence may involve inspection, expert examination or witness testimony concerning particular facts.

    However, the applicant must establish the legal interest required by Article 400.

    This requirement may be relevant where evidence could be lost or where presenting it at a later stage may become substantially more difficult.

    10.1. Possible Relevance to Real Estate Investment Disputes

    Preservation of evidence may be considered where the physical condition of the property could change, construction characteristics may become difficult to establish or technical evidence relevant to a dispute with the seller may be at risk of becoming unavailable.

    For example, an investor and a developer may disagree about the property’s represented specifications, construction quality, promised characteristics or historical circumstances affecting value.

    Where those facts may be relevant to a contemplated civil action, the conditions for preservation of evidence may require examination.

    10.2. Preservation of Evidence Is Not Automatically Available

    Merely fearing the possible withdrawal of Turkish citizenship does not necessarily satisfy the statutory requirements for a court-ordered preservation procedure.

    The relevant factual issue, legal interest, competent court, potential opposing party and procedural conditions should be identified.

    Article 401 addresses jurisdiction and competence, while Article 402 regulates requirements relating to the application and relevant procedural matters.

    10.3. Different Procedures Serve Different Purposes

    Preservation of evidence should not be treated as a standard or mandatory measure in every citizenship case.

    An independent expert opinion, a civil evidence-preservation proceeding, an administrative file examination and a court-appointed expert examination may serve different purposes.

    The appropriate mechanism depends on which material fact needs to be established and in which legal proceeding that fact will be relevant.

    XI. Does an Evidence Preservation Report Prevent Turkish Citizenship Revocation?

    No. Obtaining a court-ordered evidence preservation report does not automatically prevent the cancellation or withdrawal of a Turkish citizenship decision.

    Evidence preservation and the administrative termination of nationality belong to different legal frameworks.

    A civil court’s arrangement for examining or preserving evidence concerning a particular factual matter does not, by itself, establish through a final judicial ruling that a citizenship acquisition decision was lawful.

    Nevertheless, technical findings obtained through lawful procedures may be submitted to administrative authorities or relied upon in other proceedings where the procedural requirements permit.

    Their evidentiary significance will depend on the issues in dispute and the manner in which they were obtained.

    Expert examination in criminal proceedings is governed by the relevant provisions of Criminal Procedure Code No. 5271, while administrative judicial proceedings are governed by the applicable rules of Administrative Judicial Procedure Law No. 2577 and other relevant provisions.

    Accordingly, a civil preservation-of-evidence report is not a mandatory substitute for expert examination conducted in a criminal investigation or administrative lawsuit.

    For a genuine investor, the first task is therefore to identify the factual issue requiring proof.

    Only then can the appropriate use of independent technical assessment, preservation of evidence, administrative record examination or judicial expert evidence be determined.

    XII. Good-Faith Investors, Legitimate Expectations and the Principle of Legal Certainty

    The role of Turkish public authorities in citizenship-by-investment procedures extends beyond the issuance of the final naturalisation decision.

    Real estate transactions, investment eligibility assessments, certificates of conformity, security checks and citizenship decisions involve a sequence of official procedures.

    An investor may have relied upon a valuation report obtained through the authorised system, submitted the required documentation, received an investment certificate of conformity and subsequently acquired Turkish citizenship.

    In those circumstances, principles concerning legal certainty, administrative stability, legitimate expectations and trust in official acts may become relevant.

    Article 2 of the Turkish Constitution establishes the rule-of-law principle, while Article 66 governs acquisition and loss of Turkish citizenship under statutory conditions.

    Where the administration re-examines a previously approved investment years later and reaches a different conclusion, the reasons for that conclusion and the relevant factual evidence should be adequately identified.

    Nevertheless, legal certainty does not mean that citizenship must invariably be preserved where the mandatory statutory conditions for acquisition were objectively absent.

    Accordingly, the defence of a genuine investor should not depend exclusively on the assertion that the investor trusted official documents.

    It should also examine whether the historical investment actually satisfied the applicable legal requirements.

    Possible mistakes made during earlier administrative reviews must be distinguished from the investor’s personal declarations and conduct.

    The principles of legitimate expectations and legal certainty are therefore relevant to the assessment, but their effects cannot be determined independently of the governing statutory provisions and established facts.

    XIII. Council of State Case Law and Judicial Review of Citizenship Withdrawal

    An important decision concerning the judicial review of citizenship withdrawal is the judgment of the Council of State, 10th Chamber, dated June 23, 2025, E.2021/279, K.2025/3174.

    The dispute did not directly concern property investment or fraudulent real estate appraisal reports.

    Instead, it concerned withdrawal under Article 40 of Turkish Citizenship Law No. 5901 of citizenship previously acquired through exceptional naturalisation, based on national-security and public-order considerations.

    The judicial examination addressed whether the administration’s stated grounds were supported by sufficient factual material, whether those circumstances existed at the relevant time and whether information relied upon in the withdrawal decision had already been known to the administration when the original nationality decision was made.

    The Council of State found the contested withdrawal unlawful and annulled the relevant administrative decision.

    The judgment was delivered by majority, and the decision expressly indicated the availability of an appeal.

    Legal significance: Although the decision does not directly resolve disputes concerning appraisal values, it illustrates the requirement that citizenship withdrawal must be supported by legally sufficient factual grounds and that the administration’s reasoning is subject to judicial examination.

    For example, if a new valuation report is prepared in 2026 concerning a property purchased several years earlier, the relevant legal question is whether that report reliably demonstrates that the applicable investment requirements were not fulfilled at the original acquisition date.

    The preparation of a new report and legally sufficient proof of historical non-compliance are not the same thing.

    Judicial precedents concerning different types of exceptional naturalisation cannot automatically be applied without considering factual and statutory differences.

    Decision: Council of State, 10th Chamber, June 23, 2025, E.2021/279, K.2025/3174 – Full Text.

    Any later appellate ruling and the finality of the decision should be verified separately when relying upon the judgment in an individual case.

    XIV. Do Criminal Investigations and KYOK Decisions Protect Genuine Investors from Citizenship Loss?

    Criminal investigations and administrative citizenship reviews have frequently arisen together during the 2026 developments.

    However, their objectives and legal requirements differ.

    Depending on the allegations, an investor may be examined in connection with suspected document forgery, aggravated fraud or other criminal offences.

    Nevertheless, the mere purchase of property from an investigated developer does not establish that the investor personally committed a criminal offence.

    Criminal responsibility is personal.

    Investigators must assess the conduct alleged against the individual, including any knowing participation in fictitious transactions, preparation or use of forged documents, and other elements required by the relevant criminal provisions.

    14.1. Non-Prosecution Decisions (KYOK)

    A prosecutor may issue a decision not to prosecute, commonly referred to as KYOK, where the requirements established by criminal procedure are satisfied.

    Such a decision may be important to the assessment of the investor’s personal criminal responsibility.

    However, it does not necessarily establish that every objective statutory condition for the original citizenship acquisition existed.

    14.2. KYOK and Administrative Withdrawal Are Distinct

    The fact that a prosecutor concludes that criminal prosecution is not justified does not automatically prevent the administration from examining whether the investment satisfied the legal conditions applicable at the date of naturalisation.

    Conversely, the continuation of a criminal investigation does not establish that citizenship has already been lawfully cancelled or withdrawn.

    14.3. Evidence May Be Relevant Across Proceedings

    Criminal records and financial evidence obtained through lawful procedures may be relevant to a separate administrative citizenship dispute.

    However, each proceeding must be assessed according to its own statutory framework, the relevant evidentiary questions and the procedural safeguards applicable to the individual.

    Our third article in this series examines the issue in detail: Turkish Citizenship Revocation and Criminal Investigations in 2026: KYOK, Acquittal and Administrative Lawsuits.

    XV. Which Lawsuits Can a Genuine Investor File Against Citizenship Cancellation or Withdrawal?

    A decision terminating the acquisition of Turkish citizenship constitutes an administrative act subject to judicial review under the applicable legal framework.

    Article 7 of Administrative Judicial Procedure Law No. 2577 generally establishes a 60-day filing period for administrative litigation unless a different statutory period applies.

    The period generally begins according to the legally applicable rules concerning written notification, but the precise starting date must be examined in each case.

    15.1. Identifying the Competent Court

    The competent judicial authority depends on the type of administrative decision and the institution that issued it.

    A decision cancelling or withdrawing the original citizenship acquisition may need to be distinguished from a separate administrative decision cancelling an investment certificate of conformity.

    These acts may differ in their legal character, competent court, evidentiary basis and available remedies.

    15.2. Grounds for an Annulment Action

    Depending on the case, judicial review may concern whether the administration correctly identified the historical investment threshold, whether it relied upon technically reliable valuation evidence, whether genuine payments were examined and whether the legal basis for cancellation or withdrawal was correctly applied.

    The administrative record and the investor’s individual conduct may also require assessment.

    15.3. Suspension of Execution

    Filing an administrative lawsuit does not normally suspend execution of the contested administrative act.

    Under Article 27 of Law No. 2577, suspension of execution may be requested subject to cumulative statutory requirements concerning manifest unlawfulness and harm that would be difficult or impossible to remedy.

    The loss of nationality may have serious implications for passports, entry into Türkiye, lawful residence, family life and other legal relationships.

    However, those possible consequences do not guarantee the granting of interim judicial relief.

    15.4. The Legal Position of Spouses and Children

    Article 32 of Turkish Citizenship Law provides for consequences affecting spouses and children who acquired Turkish citizenship dependently through the person whose nationality is cancelled.

    However, the legal basis and acquisition date of each family member’s citizenship may require separate consideration.

    Children who acquired citizenship by birth may raise different legal questions from family members naturalised together with the principal investor.

    XVI. Civil Liability of Property Developers, Sellers and Intermediaries

    In some cases, the legal problems arising in a genuine investor’s citizenship file may result from conduct attributed to a seller, developer, broker, adviser or another participant in the transaction.

    Where this occurs, the private-law relationship between the investor and those parties must be examined separately.

    16.1. Misrepresentations Concerning Citizenship Eligibility

    A developer or intermediary may have represented that a property possessed the required value for citizenship purposes.

    Alternatively, the investor may allege that the property was sold on the basis of misleading descriptions, concealed material facts or contractual commitments that were not fulfilled.

    Depending on the circumstances, questions concerning breach of contract, fraudulent inducement, defective performance or compensation may arise.

    16.2. Liability Is Not Automatic

    The administrative withdrawal of citizenship does not automatically establish that the seller or developer must compensate the investor.

    The contract, representations made, actual damage, applicable fault requirements and causal relationship must be examined.

    16.3. Determining the Investor’s Loss

    Any potential damages assessment should consider the relevant legal basis, the property’s continuing ownership and market value, the economic consequences of the alleged wrongdoing and the specific heads of loss.

    The original purchase price alone does not necessarily represent the recoverable loss.

    16.4. Civil Remedies and Administrative Citizenship Proceedings

    A private-law claim against a developer or broker must be distinguished from the state’s administrative power concerning nationality.

    The two matters may arise from the same underlying facts but involve different parties, legal requirements and remedies.

    XVII. Evidence and Defence Strategy for Genuine Foreign Investors

    An effective evidentiary review of an investment-based citizenship file should not be limited to the title deed and a single bank receipt.

    The relevant documentation must be organised according to the issues actually in dispute.

    17.1. Citizenship Acquisition Documents

    The original citizenship application, naturalisation decision, certificate of conformity, relevant administrative correspondence and any subsequent official measures should be identified.

    17.2. Property Documents

    Relevant records may include the title deed, official sales instrument, preliminary sale agreement, contract amendments, historical land registry documents and the appraisal report submitted with the citizenship application.

    17.3. Banking and Financial Evidence

    Important documents may include certified account statements, SWIFT messages, payment receipts, foreign-exchange purchase records, seller invoices and financial communications concerning the transaction.

    17.4. Historical Valuation Evidence

    Documents concerning the property’s historic physical condition, completion stage, relevant comparable sales, construction plans and other technical features may be important.

    17.5. Communications and Third-Party Representations

    Correspondence with the developer, broker, intermediary, appraisal company or previous legal representatives may help establish what information was provided and which actions the investor personally undertook.

    17.6. Administrative and Criminal Records

    Where lawfully available, administrative decisions, notifications, police records, expert reports and relevant criminal investigation documents should be reviewed.

    17.7. Determine the Actual Disputed Issue

    After collecting the documents, the fundamental question is which fact is contested.

    Is the administration alleging that no genuine payment occurred? Is it disputing the property’s historical market value? Does it question another objective investment requirement? Or does the investigation concern personal misrepresentation by the investor?

    The appropriate evidentiary response depends on the answer.

    Where the dispute concerns historic property value, a retrospective technical assessment may be essential.

    Where the allegation concerns fictitious financial transfers, analysis of the complete banking chain may be more important.

    Where personal misconduct is alleged, evidence relating to knowledge, participation, declarations and communications becomes particularly relevant.

    Even where no individual citizenship withdrawal decision has been identified, an investor may assess the documents and potential legal risks in advance.

    However, the existence, scope and procedural stage of any investigation should be verified through appropriate official channels before drawing definitive conclusions.

    XVIII. Conclusion: Genuine Investors Require Proof of Both Economic Reality and Legal Compliance

    Cancellation and withdrawal of Turkish citizenship acquired through investment have become important subjects of administrative and nationality-law disputes in 2026.

    A central requirement of a legally sound assessment is to distinguish an investor who genuinely completed a transaction from an individual who knowingly participated in a fictitious or fraudulent arrangement.

    Nevertheless, the genuine investor’s good faith does not automatically eliminate every possible legal risk.

    Article 31 of Turkish Citizenship Law concerns cancellation based on false declarations or concealment of material facts by the individual, while Article 40 addresses withdrawal where the statutory conditions for the original citizenship decision were not fulfilled.

    Accordingly, the fact that the investment price was actually paid does not necessarily establish that the property satisfied the historical statutory valuation threshold.

    Likewise, the discovery of an inaccurate appraisal does not automatically demonstrate that the investor knew about the error or that the actual historic value of the property was legally insufficient.

    Financial evidence establishing the economic reality of the transaction and technical evidence establishing the historical value of the property should therefore be evaluated together.

    The applicable legislation, original investment date, objective investment conditions, administrative records, individual conduct and legal grounds of any adverse decision are all essential to the assessment.

    Depending on the case, independent expert analysis, objections to official expert reports, preservation of evidence, administrative submissions and judicial proceedings may be appropriate.

    The central purpose of legal analysis is not merely to defend the accuracy of the original appraisal report. It is to determine whether the statutory conditions for citizenship actually existed at the relevant date and whether allegations concerning the investor’s personal conduct are supported by sufficient evidence.

    Legal certainty and effective enforcement of citizenship legislation are not necessarily competing objectives.

    Both require administrative decisions to be lawful, individualised, evidence-based and subject to meaningful judicial review.

    Academic References, Legislation and Judicial Decisions

    1. Turkish Citizenship Law No. 5901. Particularly Articles 12, 31, 32, 40 and 41. Official statutory text.
    2. Regulation on the Implementation of the Turkish Citizenship Law. Particularly Articles 20 and 66, together with the rules applicable on the date of the original investment.
    3. General Directorate of Land Registry and Cadastre. Citizenship through real estate acquisition, investment threshold verification, valuation procedures and Circular No. 2024/4. Official information.
    4. 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.
    5. Dülger, Ahmet. “Taşınmaz Satın Alınmasıyla Türk Vatandaşlığının İstisnai Yoldan Kazanılmasında Değerleme Raporu ve Uygunluk Belgesi Alınması” [Valuation Reports and Certificates of Conformity in Exceptional Turkish Citizenship Acquisition Through Property Purchase]. İnönü Üniversitesi Hukuk Fakültesi Dergisi, Vol. 16, No. 1, 2025, pp. 167–180. DOI: 10.21492/inuhfd.1600688.
    6. Council of State, 10th Chamber. Judgment dated June 23, 2025, E.2021/279, K.2025/3174. Judicial review of the factual and legal basis for withdrawal of exceptional naturalisation. Full decision.
    7. Civil Procedure Code No. 6100. Particularly Articles 400–403 concerning preservation of evidence.
    8. Administrative Judicial Procedure Law No. 2577. Particularly Articles 7 and 27 concerning filing deadlines and suspension of execution. Statutory text.
    9. Ministry of Interior, September 21, 2026. Officially reported figures concerning cancellation and withdrawal of citizenship decisions acquired through investment. TRT Haber coverage of the official statement.

    Research Methodology: This article distinguishes legal requirements, administrative decisions, allegations arising from criminal investigations and technical questions requiring expert evidence. Neither a press statement nor an expert opinion is treated as automatically determining the legal status of a particular investor.

    Author and Contact Information

    Attorney Murat Can Dolğun
    Istanbul Bar Association
    TD Law Firm & Legal Consultancy
    Lecturer in Law – Istanbul University-Cerrahpaşa

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

    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 publication is intended for general academic and legal information. It does not constitute legal advice concerning a particular property investment, criminal investigation or citizenship case. The application of statutory rules, appraisal standards, procedural remedies and filing deadlines requires examination of the specific transaction and official file. No particular outcome is guaranteed.

    © 2026 DOLĞUN AKADEMİ | ATTORNEY MURAT CAN DOLĞUN