Police Statements in Turkish Citizenship by Investment Investigations: Key Areas of Examination and the Importance of Legal Preparation
Understanding the scope of criminal investigations involving investment-based Turkish citizenship, the evidence examined by authorities, and the essential role of professional legal representation.
By Av. Murat Can Dolğun TD Law Firm – Istanbul, Türkiye Updated: October 30, 2026
1. Introduction: Criminal Investigations Involving Turkish Citizenship by Investment
Recent criminal investigations in Türkiye concerning citizenship acquired through real estate investment have increased the importance of proper legal representation during police interviews and prosecutorial proceedings.
Certain investigations involve allegations concerning property valuation reports, real estate transactions, payment records, intermediary relationships, and documents used in citizenship applications. Depending on the circumstances, authorities may examine whether investment transactions complied with the legal requirements applicable at the time of acquisition.
Individuals who acquired Turkish citizenship through legitimate investments may also be contacted by investigative authorities because of transactions involving developers, sellers, valuation companies, intermediaries, or other persons under investigation.
The existence of a criminal investigation does not establish that an investor committed an offence. Each person’s knowledge, conduct, financial transactions, and supporting documentation must be assessed individually.
Police statements can become important components of the evidentiary record. Therefore, preparation before giving a statement is a fundamental part of an effective legal defence.
2. Principal Areas Examined During Police Statements
In investigations involving citizenship by real estate investment, authorities may examine several interconnected aspects of the investment process. The exact scope varies according to the allegations, available evidence, and the individual’s procedural status.
2.1. Personal Background and Financial Circumstances
Investigations may include an examination of an investor’s professional background, commercial activities, financial capacity, and the general circumstances surrounding the decision to invest in Türkiye.
These matters may assist authorities in understanding the economic context of the investment and the relationship between the investor’s financial resources and the acquisition.
2.2. Source of Investment Funds
The origin of the funds used to purchase real estate is a significant area of examination.
Authorities may review foreign bank transfers, domestic account movements, currency conversions, payment instructions, and the financial records supporting the acquisition.
International investment transactions frequently involve several banking stages. Funds may be transferred between personal accounts, converted into Turkish lira, and subsequently paid to a seller or developer.
A proper legal review should establish a clear financial chronology supported by verifiable banking records.
2.3. Property Acquisition and Ownership Records
The legal and factual characteristics of acquired real estate may be examined through title deeds, sale agreements, land registry documents, development records, and other official materials.
Particular attention may be given to the timing of acquisition, registered ownership, contractual obligations, and compliance with the investment requirements applicable during the relevant period.
Where an investor acquired several properties, the transactions may need to be examined both individually and collectively.
2.4. Real Estate Valuation Reports
Real estate valuation is among the most technically significant subjects in investment-based citizenship investigations.
Authorities may examine valuation reports submitted during the original citizenship process and compare them with subsequent expert assessments, registered sale prices, market information, and historical property values.
Differences between valuation reports require careful technical examination. Valuation dates, methodologies, comparable properties, market conditions, and the historical economic environment can materially affect the results.
A subsequent valuation that differs from an earlier assessment does not, by itself, establish deliberate manipulation by the investor.
Where necessary, independent retrospective valuations and specialist reports may form part of the defence.
2.5. Relationships with Developers, Sellers, and Intermediaries
Investigative authorities may examine the roles of real estate developers, sellers, brokers, representatives, valuation professionals, and other persons involved in investment transactions.
The nature of these relationships may be relevant to establishing the investor’s knowledge, participation, and actual involvement in the transaction.
Ordinary commercial contact or the purchase of real estate from a person subsequently investigated for an alleged offence does not independently establish criminal responsibility.
Criminal responsibility must be considered in light of the legally required elements of the relevant offence and evidence attributable to the individual concerned.
2.6. Banking Records and Financial Intelligence
Financial records, including material obtained or evaluated in connection with the Financial Crimes Investigation Board (MASAK), may form part of the evidentiary assessment.
The relationship between bank transfers, declared sale prices, contractual amounts, payment dates, and transaction beneficiaries can be important.
Any apparent inconsistency should be assessed against the complete documentation rather than isolated entries.
2.7. Subsequent Use of the Property
The investor’s conduct following the acquisition may also have evidentiary significance.
Property tax payments, rental agreements, declared rental income, maintenance expenses, occupancy records, and continued ownership may help establish the commercial reality and history of the investment.
However, subsequent use of property does not replace the requirement to establish compliance with the legal investment conditions applicable when citizenship was acquired.
3. Why Preparation Before a Police Statement Is Essential
A police statement is a formal procedural act. The content of the recorded statement may subsequently be considered by prosecutors, experts, courts, and, where legally relevant, administrative authorities.
Preparation should begin with an accurate understanding of the allegations and an examination of the documents available to the defence.
Investment-based citizenship cases may involve transactions conducted many years before the investigation. An investor may have difficulty recalling precise dates, transfer amounts, contractual arrangements, or the identities of individuals involved in a transaction.
In these circumstances, attempting to reconstruct events solely from memory can create avoidable inconsistencies.
Effective preparation requires documentary verification, a reliable chronology, and a clear understanding of the investor’s procedural rights.
3.1. Reviewing the Available Case Materials
Legal counsel should examine accessible investigation documents, the nature of the allegations, relevant expert assessments, and the connection between the investor and the transactions under scrutiny.
Access to investigation materials may be subject to lawful restrictions under Article 153 of the Turkish Criminal Procedure Code.
Such restrictions must be assessed within the statutory framework, while preserving the defence rights guaranteed by law.
3.2. Establishing a Documentary Chronology
A structured chronology should bring together the principal stages of the investment, including contractual commitments, international transfers, currency conversions, payments to the seller, valuation assessments, title deed registrations, and citizenship-related administrative documents.
This chronology allows counsel to identify missing records, explain apparent discrepancies, and distinguish verified events from matters requiring further investigation.
3.3. Identifying Evidentiary Gaps
Certain records may remain with banks, land registry offices, valuation companies, public authorities, or former commercial counterparties.
Where appropriate and legally available, counsel may seek official copies, request relevant records, arrange technical examinations, and pursue measures necessary to preserve evidence.
An investor should identify uncertainties openly and avoid speculation or unverified statements. Legal preparation must respect the truthfulness and independence of the investor’s own account.
3.4. Preparing for Interpretation and Statement Accuracy
Language differences can create substantial procedural difficulties, especially in investigations involving financial terminology, technical valuation reports, and historical transactions.
Where the statutory conditions are satisfied, the assistance of an interpreter is provided for under Article 202 of the Turkish Criminal Procedure Code.
The recorded statement should accurately reflect the person’s own explanations. The contents of the record, including any translation, should be carefully checked before signature. Any inaccuracies should be raised for correction.
4. Fundamental Rights During Criminal Proceedings
Turkish criminal procedure provides important safeguards for persons questioned as suspects.
Under Article 147 of Law No. 5271, these safeguards include notification of the alleged offence, information about the right to legal counsel, the right not to make statements concerning the allegation, and the opportunity to identify evidence supporting the defence.
Article 149 addresses the right to benefit from defence counsel during the relevant stages of criminal proceedings.
Article 153 regulates defence counsel’s access to investigation materials, including the statutory conditions under which access may be restricted.
Article 202 governs interpretation in the circumstances specified by law.
These rights should be considered before and during the statement procedure. The assistance of a criminal defence lawyer is particularly important where the investigation involves extensive financial records, multiple parties, or complex technical allegations.
5. Criminal Investigations and the Protection of Turkish Citizenship
Criminal investigations involving investment transactions may also raise concerns regarding the continued validity of Turkish citizenship acquired through those investments.
The legal analysis requires a distinction between criminal proceedings and administrative decisions concerning citizenship status.
Article 31 of Turkish Citizenship Law No. 5901 regulates the cancellation of a citizenship acquisition decision where the decision resulted from false statements or the concealment of essential circumstances relevant to acquiring citizenship.
Article 40 separately regulates the withdrawal of citizenship decisions where it is subsequently established that the legal conditions were absent or that the decision was issued more than once.
These provisions have different legal requirements and must be examined in light of the specific circumstances.
The commencement of a criminal investigation does not itself terminate Turkish citizenship. Similarly, a valuation dispute, a property-related precautionary measure, or the taking of a police statement does not independently constitute a final citizenship cancellation decision.
Where citizenship status may be affected, a coordinated legal strategy can be required across criminal proceedings, administrative applications, property records, and potential administrative litigation.
An important part of this assessment is identifying the legal investment threshold and substantive requirements applicable at the original acquisition date. Turkish citizenship-by-investment regulations have changed over time, and present requirements should not simply be applied retrospectively to earlier transactions.
6. The Importance of Early Legal Representation
Professional legal assistance is valuable before a formal statement appointment, where preparation is legally and practically possible.
Early involvement allows counsel to assess accessible evidence, identify relevant documents, examine potential criminal and administrative exposure, and coordinate the preparation process.
The legal work may include reviewing property transactions, obtaining official records, examining financial documentation, coordinating with technical experts, and preparing written submissions where appropriate.
Each investigation requires an individual assessment. The evidentiary position of one investor cannot be assumed to be identical to that of another investor, even where transactions involve the same development project or commercial counterparties.
Accordingly, generic statements or standardised defence narratives cannot replace a case-specific legal assessment.
The objective is to ensure that the individual’s actual circumstances are examined accurately, that relevant defence evidence is identified, and that procedural rights are effectively protected.
7. Legal Assistance from TD Law Firm
TD Law Firm provides legal representation and advisory services in matters involving Turkish citizenship by investment, criminal investigations, real estate transactions, and administrative proceedings.
Our work in relevant cases may include:
Pre-statement legal consultation and preparation.
Criminal defence representation during police and prosecutorial proceedings.
Examination of investment transactions and financial documentation.
Review of property valuation reports and coordination of independent technical assessments.
Requests for relevant records from competent public institutions.
Preparation of written defence submissions and evidentiary applications.
Legal assessment of citizenship cancellation and withdrawal risks.
Representation in administrative proceedings and litigation concerning citizenship decisions.
Legal services are determined according to the procedural status of the individual, the available documentation, the scope of the investigation, and the specific instructions of the client.
Investors who have received a request to provide a statement, learned of an investigation involving their property transactions, or become concerned about their citizenship status may contact our office to arrange a legal consultation.
Professional Legal Consultation
Protect your procedural rights through informed legal preparation.
TD Law Firm assists investors in assessing their legal position, preparing for formal statements, and addressing related criminal and citizenship proceedings under Turkish law.
TD LAW FIRM
Av. Murat Can Dolğun Attorney at Law – Istanbul Bar Association Bar Registration No: 75860 World Trade Center, A2 Block, Floor 5, Office 206 Bakırköy, Istanbul, Türkiye
The principal legal framework discussed in this article includes the following legislation:
Turkish Citizenship Law No. 5901, particularly Articles 12, 31, 32 and 40. Official legislation.
Turkish Criminal Procedure Code No. 5271, particularly Articles 147, 149, 153, 157 and 202. Official legislation portal.
Regulation on the Implementation of the Turkish Citizenship Law, particularly Article 20 concerning exceptional acquisition of citizenship through investment. Official legislation portal.
General Directorate of Land Registry and Cadastre, official guidance concerning investment-based citizenship property transactions. Official institutional website.
Confidentiality and Legal Disclaimer
This publication provides general legal information concerning the subjects commonly examined in criminal investigations involving Turkish citizenship acquired through investment. It does not reproduce or disclose any confidential police statement, investigative question, case file, personal information, or identifying information concerning any individual or commercial entity.
The discussion is based on general legal principles and areas of examination encountered in relevant proceedings. It must not be interpreted as a representation that every investigation follows the same procedure or involves the same allegations.
This article does not constitute individual legal advice, establish an attorney-client relationship, or guarantee any procedural or administrative outcome. Legal rules and factual circumstances must be assessed as of the relevant dates. Every case requires a separate examination of its evidence and applicable law.
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
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.
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:
Was the property sale a genuine economic and legal transaction?
Did the investment satisfy the objective statutory requirements applicable at the relevant date?
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.
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.
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.
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.
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.
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.
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
Turkish Citizenship Law No. 5901. Particularly Articles 12, 31, 32, 40 and 41. Official statutory text.
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.
General Directorate of Land Registry and Cadastre. Citizenship through real estate acquisition, investment threshold verification, valuation procedures and Circular No. 2024/4. Official information.
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.
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.
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.
Administrative Judicial Procedure Law No. 2577. Particularly Articles 7 and 27 concerning filing deadlines and suspension of execution. Statutory text.
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.
Criminal investigations concerning Turkish citizenship acquired through investment in 2025 and 2026 have brought renewed attention to the relationship between nationality law, criminal liability and administrative judicial review.
Investigations conducted by the Istanbul Chief Public Prosecutor’s Office have involved allegations of sham real estate transactions, inaccurate or fraudulent property valuation reports, artificial foreign-currency transfers, document forgery, fraud and organised criminal activity.
These developments have confronted foreign investors who acquired Turkish citizenship in previous years with three separate legal questions.
The first concerns the investor’s procedural status and possible personal criminal liability. The second concerns whether the original investment genuinely satisfied the statutory requirements for Turkish citizenship. The third concerns the administrative and judicial remedies available if a citizenship cancellation or withdrawal decision is issued.
Although these questions may arise from the same transactions, they require distinct legal analyses.
Being investigated as a criminal suspect does not establish guilt or automatically terminate Turkish citizenship. Equally, a prosecutor’s decision not to prosecute does not automatically invalidate a separate administrative decision withdrawing citizenship.
This article examines police questioning, prosecutorial investigations, the right to counsel, interpretation rights, restrictions on access to investigation files, non-prosecution decisions (KYOK), indictments, acquittals, arrest measures, expert reports, administrative litigation and suspension of execution.
The research draws upon legislation, official announcements and published Council of State decisions available up to October 22, 2026. It is applicable to all persons who acquired Turkish citizenship through investment or another exceptional naturalisation procedure, regardless of their national origin.
1. Why Can a Turkish Citizenship-by-Investment File Become the Subject of a Criminal Investigation?
Acquisition of Turkish citizenship through investment is primarily an administrative-law procedure. The applicant must satisfy the statutory conditions, the relevant institution must determine the eligibility of the investment, and the competent authority must issue the naturalisation decision.
However, allegations that the supporting documents were falsified, that the investment amount was not genuinely paid, or that an organised arrangement was established to simulate compliance may also give rise to criminal-law questions.
For example, where a property’s true market value is allegedly below the statutory minimum and an inaccurate appraisal report is knowingly prepared to show a higher value, the dispute may extend beyond a technical disagreement concerning valuation.
Similarly, investigators may examine whether a bank transfer was fabricated, whether funds were returned through intermediary accounts after an apparent payment, or whether a land registry transaction concealed an agreement inconsistent with the apparent sale.
Nevertheless, two separate matters must be distinguished: the failure of a transaction to satisfy citizenship legislation and the intentional commission of a criminal offence by a particular individual.
Under Article 38 of the Turkish Constitution and Article 20 of Turkish Penal Code No. 5237, criminal responsibility is personal.
Therefore, the existence of a criminal investigation concerning a construction company, property developer or appraisal professional does not establish the guilt of every investor who dealt with that person or organisation.
2. Developments in Turkish Citizenship Investigations During 2025–2026
2.1. September 24, 2025: Investigation Into Allegedly Sham Property Transactions
An operation conducted across 19 Turkish provinces in September 2025 concerned allegations that fictitious real estate transactions had facilitated the acquisition of Turkish citizenship by foreign investors.
According to publicly reported investigative statements, the allegations included inflated property values, artificial financial movements and subsequent transfers of properties back to previous owners or related parties.
The investigation raised questions concerning the distinction between a formal property transfer recorded in the land registry and the genuine economic substance of the underlying transaction.
2.2. August 4, 2026: Investigation Concerning 687 Individuals
On August 4, 2026, the Turkish Ministry of Justice announced an investigation coordinated by the Organised Crime Investigation Bureau of the Istanbul Chief Public Prosecutor’s Office.
The reported allegations concerned properties of comparatively low value allegedly being represented as qualifying high-value investments through inaccurate appraisal reports.
The Ministry reported detention orders for 90 suspects, the apprehension of 72 suspects and protective measures involving companies and property assets.
It also announced that legal proceedings had been initiated concerning the cancellation of citizenship acquired by 687 individuals.
Initiating proceedings intended to cancel nationality does not mean that a final individual administrative cancellation decision had already been issued against every affected person.
2.3. September 21, 2026: The Second-Wave Investigation
The second-wave investigation announced on September 21, 2026, concerned the review of property transactions and financial records associated with investment-based citizenship acquisitions.
According to information reported from the Ministry of Interior, the investigation covered 1,070 people, comprising 263 principal investors and 807 family members. Additional processes reportedly concerned 11 persons whose citizenship applications were still pending.
Reports referred to the work of the Istanbul Police Department’s Anti-Migrant Smuggling and Border Gates Branch, expert examinations and analyses by the Financial Crimes Investigation Board, known as MASAK.
On September 25, 2026, Anadolu Agency reported that 33 suspects had been remanded in custody and that other suspects were subject to judicial supervision measures.
Arrest, pretrial detention and judicial supervision are criminal procedural measures. They do not constitute final convictions. The presumption of innocence continues to apply to all persons under investigation or prosecution.
3. Criminal Investigations and Administrative Citizenship Proceedings Are Not the Same Legal Process
One of the most significant mistakes in evaluating Turkish citizenship cases is treating criminal investigations and administrative citizenship reviews as if they formed a single legal proceeding.
A criminal investigation seeks to establish whether an offence was committed and, if so, who may be responsible. The public prosecutor, judicial police and competent criminal courts operate within the criminal procedure framework.
Cancellation or withdrawal of citizenship, by contrast, concerns administrative decisions issued by the competent authorities under Turkish Citizenship Law No. 5901.
Issue
Criminal Proceedings
Citizenship Proceedings
Primary question
Has a crime been committed?
Were the statutory conditions for citizenship fulfilled?
Legislation
Penal Code and Criminal Procedure Code
Citizenship Law No. 5901 and related regulations
Authorities
Public prosecutors and criminal courts
Competent administrative authorities
Possible outcomes
KYOK, indictment, acquittal or conviction
Cancellation, withdrawal or other administrative decisions
Judicial remedies
Criminal procedural remedies
Administrative judicial review
The distinction does not prevent the same facts from producing consequences in both legal systems.
For example, knowingly using a forged document to demonstrate a fictitious investment may raise questions of document forgery and, separately, whether the statutory conditions for citizenship were genuinely fulfilled.
Each proceeding, however, has its own legal requirements and issues of proof.
4. Why Does the Distinction Between Suspect, Witness, Complainant and Victim Matter?
4.1. Suspect
Under Article 2 of Criminal Procedure Code No. 5271, a suspect is a person under suspicion of committing a criminal offence during the investigation stage.
Being questioned as a suspect means that allegations concerning the person’s conduct are being investigated. It does not establish criminal guilt.
Suspects enjoy procedural rights including information about the allegation, legal representation, the right to remain silent, the opportunity to request the collection of favourable evidence and access to interpretation when legally required.
4.2. Witness
A witness is a person believed to possess information relevant to the investigated events.
The procedural obligations of witnesses differ from those of suspects. However, protections concerning answers that could expose the person or protected relatives to criminal prosecution must also be considered.
Questioning a person as a witness where the circumstances require treatment as a suspect may give rise to procedural concerns affecting defence rights.
4.3. Complainant and Victim
A complainant is a person reporting or complaining about an alleged criminal offence. A victim is a person directly affected by conduct infringing the legal interest protected by the criminal provision.
Some foreign investors involved in citizenship investigations may themselves have been harmed by misleading conduct of property developers, agents or intermediaries.
For example, an investor may have genuinely transferred the qualifying funds but later discovered that a developer or intermediary supplied false information concerning the property or investment documentation.
Whether that investor qualifies as a victim or person harmed by the offence requires examination of the specific allegations.
Even where an interview record describes the investor as a victim, this does not automatically resolve every administrative citizenship question.
4.4. Different Procedural Roles Within One Investigation
An individual may have different procedural positions concerning separate alleged acts within a broader factual investigation.
The person’s precise status should therefore be determined for each allegation rather than inferred solely from the general subject of the case.
5. Which Criminal Offences May Arise in Turkish Citizenship Investigations?
Several offences under Turkish Penal Code No. 5237 have been mentioned in reports concerning the investigations.
Nevertheless, the presence of an offence in an investigation file does not prove that its statutory elements are satisfied in relation to a particular investor.
5.1. Establishing or Participating in a Criminal Organisation – Article 220
Article 220 concerns organisations established for the purpose of committing criminal offences.
The fact that multiple companies participated in property transactions, or that several investors used the same intermediary, does not itself establish the existence of a criminal organisation or membership by an investor.
The organisation’s structure, purpose, continuity, relevant characteristics and the individual’s connection with it must be assessed under the applicable statutory elements.
5.2. Migrant Smuggling – Article 79
Article 79 regulates migrant smuggling.
The involvement of a police unit responsible for investigating migrant smuggling does not mean that every transaction or individual mentioned in the investigation necessarily satisfies the elements of that offence.
Ordinary assistance with citizenship applications should not automatically be equated with the conduct criminalised by Article 79. The actual statutory elements must be established.
5.3. Fraud and Aggravated Fraud – Articles 157 and 158
Fraud involves deceptive conduct and the obtaining of an unlawful benefit under the relevant legal conditions. Aggravated forms of fraud are separately regulated under Article 158.
In citizenship-related investigations, allegedly inaccurate investment values, artificial transactions and misleading documents may lead investigators to consider fraud offences.
However, the alleged deceptive act, its target, the resulting benefit and harm, and the individual’s role must be determined.
The failure to satisfy an administrative investment condition does not automatically constitute aggravated fraud.
5.4. Forgery of Official Documents – Article 204
Article 204 concerns forgery involving official documents.
In citizenship and real estate cases, it is important to determine whether the relevant document legally qualifies as an official document, the nature of the alleged falsification and the knowledge and conduct of the person said to have used it.
5.5. Forgery of Private Documents – Article 207
Allegations concerning private documents require separate consideration of their legal nature, authenticity, use and the person’s conduct.
Not every erroneous private contract or inaccurate commercial communication constitutes criminal forgery.
5.6. False Statements in the Preparation of Official Documents – Article 206
Article 206 addresses certain false statements made to a public official authorised to prepare an official document.
Allegedly misleading declarations during a citizenship application may be examined under this provision where the statutory elements are present.
A document containing an inaccurate result, however, does not automatically establish that the applicant committed this particular offence.
5.7. Multiple Charges Arising from the Same Transaction
A series of transactions may generate allegations involving several criminal provisions.
Whether each offence is legally established, whether the provisions governing concurrence apply and how the individual’s conduct is connected to the alleged acts require separate analysis.
The essential question is not how many offence names appear in the investigation, but which particular criminal act is attributed to the individual and on what evidence.
6. What Are the Suspect’s Rights During Police and Prosecutorial Questioning?
The questioning of a suspect is subject to statutory safeguards. Article 147 of Criminal Procedure Code No. 5271 establishes fundamental rules governing the taking of statements and judicial interrogation.
6.1. The Right to Be Informed of the Accusation
The suspect must be informed of the alleged offence.
Knowing only that a general citizenship investigation exists may be insufficient to understand the actual conduct alleged against the individual.
For example, is the investor alleged to have prepared a fraudulent appraisal report, knowingly used such a report, participated in an artificial banking arrangement or merely purchased property from the company being investigated?
The nature of the defence depends on those distinctions.
6.2. The Right to Legal Counsel
Article 149 allows suspects and defendants to receive assistance from one or more defence lawyers during investigation and prosecution, subject to applicable procedural provisions.
The presence of defence counsel during questioning is an important safeguard. Article 150 also governs situations in which appointment of a defence lawyer is mandatory.
Acquiring Turkish citizenship through naturalisation does not diminish the individual’s criminal procedural rights.
6.3. The Right to Remain Silent
Under Article 147, the suspect must be informed of the legal right not to make statements concerning the alleged offence.
Exercising that right does not establish guilt and must not itself be treated as proof of criminal conduct.
The decision whether to provide a statement should be considered with reference to the available evidence and the individual’s particular circumstances.
6.4. The Right to Request Favourable Evidence
A suspect may request the collection of specific evidence capable of supporting the defence.
In citizenship-investment cases, such evidence may include bank statements, SWIFT records, property purchase contracts, title deeds, historical appraisal reports, communications with developers and proof that the consideration was not refunded.
6.5. Accuracy of the Written Statement
Discrepancies between what a person actually says and what appears in the written interview record can have serious consequences.
This is particularly important when statements are interpreted from another language.
Dates, monetary amounts, the sequence of transactions and the meaning of technical explanations should be recorded accurately.
Requests to correct errors or omissions should be raised before the interview record is finalised and signed.
6.6. Police Statements Taken Without Defence Counsel
Article 148(4) provides that a statement obtained by the police in the absence of defence counsel cannot form the basis of a judgment unless subsequently confirmed by the suspect or defendant before a judge or court.
This rule illustrates that the right to counsel is not merely a formality. It has substantive consequences for the admissibility and evaluation of criminal evidence.
7. Interpreter Rights of Foreign Investors Who Do Not Speak Turkish
Effective exercise of defence rights requires a person to understand the accusations and questions addressed to them.
Article 202 of the Criminal Procedure Code regulates interpretation rights in the circumstances prescribed by law.
Speaking English, Arabic, Russian, Chinese, Persian or another language does not create any legal disadvantage. The relevant question is whether the person can understand and participate effectively in the proceedings.
7.1. Incorrect Translation of Legal and Financial Terminology
Citizenship investigations may involve technical expressions such as genuine payment, repayment, sham transaction, property appraisal, certificate of conformity and forged document.
An inaccurate interpretation may materially change the meaning of the person’s statement.
For example, “I did not determine the property’s value” is different from “I did not know the property’s value.”
Likewise, “The seller did not refund my payment” is not equivalent to “I do not know the seller’s banking transactions.”
7.2. Challenging an Incorrect Interpretation
Where the individual believes a statement has been inaccurately translated, the concern should be raised during questioning and, where appropriate, recorded in the official minutes.
Ordinary conversational ability in a foreign language should not automatically be equated with the ability to understand complex legal and financial questions in that language.
8. Can a Lawyer Examine the Investigation File? What Is a Restriction Order?
One recurring problem in citizenship investigations is the existence of confidentiality rules or a judicial restriction on inspection of the investigation file.
8.1. Confidentiality of Criminal Investigations
Article 157 of the Criminal Procedure Code governs confidentiality during the investigation phase.
However, general investigative confidentiality and a specific restriction on defence counsel’s file-inspection rights are separate legal matters.
8.2. Article 153 and File Inspection
Article 153 regulates the defence lawyer’s entitlement to examine investigation records and obtain copies of documents.
Under specified statutory conditions and procedures, access to certain materials may be restricted.
The existence of a restriction order does not eliminate every defence right or prevent counsel from undertaking all legal work.
Documents excluded from the restriction and other statutory defence safeguards must be evaluated separately.
8.3. Investigation Files Not Visible Through UYAP
The absence of a file from an individual’s accessible UYAP or e-Devlet interface does not conclusively establish that no criminal investigation exists.
Access may depend on the investigation’s status, the person’s procedural capacity, confidentiality rules and technical access permissions.
8.4. Representation and Authorisation
The ability to make an initial legal enquiry, formally represent an individual in an investigation and obtain copies of confidential documents are different matters.
Appropriate authorisation and procedural status are important. Nevertheless, the appointment of defence counsel in criminal proceedings must be distinguished from the formal representation requirements applicable to an administrative citizenship file.
9. Arrest, Police Custody, Pretrial Detention and Judicial Supervision
Foreign investors who become concerned about citizenship-related criminal investigations often ask whether they may be arrested upon entering Türkiye.
However, the existence of an investigation does not automatically result in arrest, police custody or pretrial detention.
9.1. Summons for Questioning
Under Article 145 and related provisions, a person may be summoned to give a statement.
A summons and an arrest warrant are different procedural measures.
9.2. Arrest and Apprehension
Measures involving the apprehension of an individual require the relevant statutory conditions.
The appearance of a person’s name in a criminal investigation does not by itself establish that an arrest warrant has been issued.
9.3. Police Custody
Police custody is a temporary measure that may follow apprehension under the conditions prescribed by law.
The person concerned is entitled to applicable procedural safeguards, including access to counsel and legally required notifications.
9.4. Pretrial Detention
Under Article 100, pretrial detention requires consideration of concrete evidence indicating strong suspicion, statutory grounds for detention and proportionality.
Detention is a preventive criminal procedural measure, not a criminal sentence.
9.5. Judicial Supervision
Article 109 regulates judicial supervision as an alternative to detention in the circumstances prescribed by law.
Depending on the specific order, such measures may include restrictions on leaving the country, reporting obligations or requirements not to leave one’s residence.
Accordingly, the absence of pretrial detention does not necessarily mean that no travel restrictions exist.
9.6. Assessing Border-Control Risks
Before travelling to Türkiye, the individual’s current citizenship status, valid travel documents, any judicial protective measures and applicable immigration rules should be examined separately.
An ongoing investigation does not establish that the person will inevitably be detained at the border. However, an existing arrest warrant or another applicable judicial measure may have significant consequences for travel.
10. How Are Bank Records, Title Deeds, Property Valuations and MASAK Reports Evaluated?
One central issue in citizenship-by-investment investigations is whether the investment appearing in official documents corresponds to a genuine economic transaction.
10.1. Bank Transfers
Bank receipts, SWIFT messages, account statements, transfer instructions and foreign-exchange transaction records may provide important evidence that a qualifying investment was actually made.
Nevertheless, a single receipt may not fully explain the economic nature of the payment.
Investigators may examine whether funds transferred to the seller were subsequently returned to the investor, transferred to related parties or circulated through additional accounts.
10.2. Land Registry and Sale Documents
Registration of a property transfer is an important legal fact.
However, investigators may separately examine whether the parties reached an undisclosed arrangement inconsistent with the apparent sale or whether the transaction was genuine in economic substance.
10.3. Valuation Reports
A real estate appraisal is a significant technical document when assessing the investment threshold applicable to property-based citizenship.
Yet comparing a historic valuation with current property prices is not necessarily sufficient.
The relevant examination should address the investment date, the property’s physical and legal characteristics at that time, comparable transactions, the project’s development stage and the market conditions then prevailing.
10.4. MASAK Financial Analyses
The Financial Crimes Investigation Board may analyse banking transactions, financial patterns and relationships between accounts.
However, identification of a suspicious financial transaction does not itself conclusively establish that a particular person committed a crime or that every related payment was fictitious.
Financial findings should be assessed together with other evidence and the specific elements of the alleged offence.
10.5. Digital Evidence
Emails, messaging records, draft contracts, payment instructions and electronic files may be relevant.
Nevertheless, the source, integrity, method of collection and context of electronic evidence must be considered.
An isolated screenshot, for example, may fail to show the full conversation or the circumstances in which a message was exchanged.
11. How Can Expert Reports Be Examined or Challenged?
Expert evidence is particularly important in citizenship investigations involving property valuation and financial records.
11.1. The Scope and Methodology of the Expert Report
Evaluation should address not only the expert’s conclusion but also the methodology employed.
Does the report determine the historical value of an individual apartment, the average value of an entire parcel, the current market value or another technical measure?
These distinctions may materially affect whether a historic investment satisfied the relevant legal threshold.
11.2. Independent Expert Opinions
Article 67(6) of the Criminal Procedure Code permits scientific opinions from specialists regarding matters relevant to the investigation or prosecution.
Depending on the circumstances, an investor may obtain independent professional assessments from banking specialists, financial analysts, property valuation experts or other qualified professionals.
However, a privately commissioned expert opinion and a report prepared by a court-appointed or prosecution-appointed expert do not have identical procedural status.
11.3. Historical Value Versus Current Market Value
Where property was acquired in 2022, a valuation conducted in 2026 must clearly identify the relevant valuation date.
A determination of the property’s current market value does not, by itself, establish whether the investment satisfied the statutory requirements in 2022.
Historical valuation should be distinguished from the assessment of the property’s present value.
11.4. Preservation of Evidence and Expert Assessment
Articles 400 and following of Civil Procedure Code No. 6100 govern preservation of evidence under specific civil procedural conditions.
An expert examination within a criminal investigation and a separate civil proceeding for preservation of evidence are not the same legal procedure.
Depending on the issues to be proved, both may be relevant for different purposes.
The selection of an appropriate mechanism depends on the legal nature of the dispute and the evidence requiring preservation.
12. What Is KYOK? When Can a Prosecutor Decide Not to Prosecute?
KYOK is the commonly used Turkish abbreviation for kovuşturmaya yer olmadığına dair karar, meaning a decision that there is no ground for criminal prosecution.
Under Article 172 of Criminal Procedure Code No. 5271, the public prosecutor issues a non-prosecution decision if the investigation does not produce evidence sufficient to justify bringing a public prosecution or if prosecution is legally impossible.
12.1. Insufficient Evidence to Establish the Required Suspicion
One purpose of an investigation is to determine whether the evidence establishes sufficient suspicion to bring a criminal case.
For example, where there is insufficient evidence that an investor participated in preparing a fraudulent appraisal or knowingly used a forged document, that evidentiary deficiency may be significant to the prosecutorial decision.
However, it would be inappropriate to guarantee KYOK merely because one or two particular documents support the investor’s account.
12.2. Legal Impossibility of Prosecution
Article 172 also addresses situations in which prosecution is not legally possible.
Accordingly, not every KYOK decision necessarily amounts to a conclusive factual finding that the alleged conduct never occurred. The actual reasons given by the prosecutor must be examined.
12.3. KYOK Is Not an Acquittal
KYOK is a prosecutorial decision issued during the investigation stage.
It is legally distinct from an acquittal delivered by a criminal court following judicial proceedings.
12.4. Objections to a Non-Prosecution Decision
Article 173 provides a specific objection mechanism for a person harmed by the alleged offence, subject to the applicable statutory conditions.
As a general rule, the person entitled to object may apply to the competent criminal judgeship of peace within two weeks following notification of the decision, subject to statutory exceptions and any applicable special rules.
This is a remedy available to eligible persons harmed by the offence, not an objection mechanism automatically exercised by the suspect.
12.5. New Evidence Following KYOK
Article 172(2) regulates the conditions governing subsequent prosecution concerning the same act, including new evidence and the applicable judicial authorisation requirements.
Consequently, the legal effects of subsequently discovered evidence must be assessed under the statutory framework.
13. Does a KYOK Decision Prevent the Cancellation or Withdrawal of Turkish Citizenship?
This is one of the most frequently misunderstood issues in citizenship law.
A non-prosecution decision does not automatically prevent an administrative authority from examining the legality of a previous citizenship acquisition decision.
The criminal-law question of whether a person committed a particular offence differs from the administrative-law question of whether the objective statutory conditions for citizenship were fulfilled.
13.1. Scenario One: Genuine Investment and No Criminal Liability Established
An investor may have genuinely paid the required purchase price, transferred the funds through the banking system, retained ownership of the property and received no refund.
The investigation may fail to establish sufficient evidence that the investor knowingly participated in forgery, artificial transactions or other alleged crimes.
In that situation, KYOK is an important procedural outcome concerning personal criminal liability.
Its reasoning and supporting findings may also be relevant to an administrative citizenship dispute.
Nevertheless, compliance with the objective statutory requirements for citizenship must still be assessed.
13.2. Scenario Two: No Crime Established, but the Investment Requirement Was Not Fulfilled
An investor may receive KYOK because the evidence does not sufficiently establish knowing participation in criminal conduct.
However, the administration may separately contend that the investment did not satisfy the required legal amount or another objective condition at the date of acquisition.
The termination of criminal proceedings does not automatically prevent an administrative assessment under Article 40 of Law No. 5901.
13.3. Scenario Three: The Prosecutor’s Findings Contradict the Administrative Grounds
Evidence examined in criminal proceedings may demonstrate that an important factual allegation relied upon by the administration was incorrect.
Where the reasoning of a non-prosecution decision directly conflicts with the factual premise of an administrative withdrawal decision, that contradiction may be significant in administrative litigation.
The administrative court must nevertheless reach its determination on the basis of the applicable legal provisions, the contested administrative act and the evidentiary record before it.
13.4. Does KYOK Automatically Restore Citizenship?
No.
Where an administrative citizenship cancellation or withdrawal decision has already been issued, it remains necessary to consider the appropriate procedures for its withdrawal, amendment or judicial annulment.
KYOK may form part of the evidence supporting those proceedings. It is not itself an administrative court judgment cancelling the nationality decision.
14. What Happens If the Prosecutor Files an Indictment?
Under Article 170 of the Criminal Procedure Code, where the evidence obtained during the investigation establishes sufficient suspicion for public prosecution, the public prosecutor prepares an indictment.
The indictment is submitted to the competent criminal court. The prosecution stage begins following acceptance of the indictment in accordance with the applicable procedure.
14.1. An Indictment Is Not Proof of Guilt
An indictment is the formal document through which the prosecutor submits criminal allegations for judicial examination.
Its acceptance does not constitute a conviction. The court must examine the evidence and defence during the proceedings.
14.2. Distinguishing Criminal Allegations
An indictment alleging document forgery or fraud does not, by itself, settle the different question of whether the investment objectively met the nationality requirements.
Each alleged offence must be examined according to its own statutory elements and the defendant’s individual conduct.
14.3. Must the Criminal Trial End Before Citizenship Can Be Withdrawn?
Article 40 of Law No. 5901 does not generally make a final criminal conviction a mandatory prerequisite for the withdrawal of a citizenship decision granted without the necessary statutory conditions.
Consequently, the competent administration may be required to examine the original citizenship conditions separately from the outcome of the criminal prosecution.
Nevertheless, the sufficiency, accuracy and legality of the facts relied upon by the administration remain subject to judicial review.
15. How Does a Criminal Acquittal Affect an Administrative Citizenship Case?
An acquittal is a judgment delivered by a criminal court in accordance with criminal procedure.
Not all acquittals rest on the same legal reasoning. Article 223 of the Criminal Procedure Code provides for acquittal in circumstances that may concern the absence of a criminal offence, the fact that the defendant did not commit the act or insufficient proof of criminal guilt, among other statutory grounds.
15.1. An Acquittal Does Not Automatically Annul Administrative Withdrawal
If the administration has already issued a citizenship withdrawal decision, a criminal acquittal does not automatically extinguish that separate administrative act.
However, the criminal court’s findings regarding material facts may be significant where the administration relied on allegations involving the same conduct.
15.2. The Presumption of Innocence
The presumption of innocence is protected under Article 38 of the Turkish Constitution and Article 6(2) of the European Convention on Human Rights.
Administrative or public statements that categorically treat a person as criminally guilty without a final conviction may, depending on their wording and circumstances, raise separate concerns under this principle.
Nevertheless, an administrative assessment of objective citizenship conditions does not necessarily amount to a criminal finding of guilt.
16. Cancellation and Withdrawal Under Turkish Citizenship Law No. 5901
Articles 31 and 40 are of particular importance when allegations arising from criminal investigations are also examined in nationality proceedings.
16.1. Article 31: False Declarations and Concealment of Material Facts
Article 31 concerns cancellation of a citizenship acquisition decision where the acquisition resulted from false declarations by the individual or concealment of material circumstances relevant to the original decision.
The analysis must determine which declaration was allegedly false, what material fact was concealed and how that conduct affected the acquisition of Turkish citizenship.
A valuation report prepared by an independent professional and subsequently found to be inaccurate must be distinguished from an investor knowingly using a report that they understand to be fraudulent.
16.2. Article 40: Decisions Granted Without the Required Legal Conditions
Article 40 provides for the withdrawal of decisions concerning citizenship acquisition or loss where the required legal conditions were absent or the decision was issued in duplicate.
The essential question is whether the necessary conditions existed at the time the original nationality decision was made.
Therefore, the absence of proven criminal liability does not, in every case, suffice to establish that citizenship cannot be withdrawn under Article 40.
Conversely, the administration must support a withdrawal decision with legally relevant and adequately established facts demonstrating that the original statutory requirements were not met.
16.3. Different Temporal Consequences
Under Article 32, a cancellation decision takes effect from the date of that decision and also applies to spouses and children who acquired Turkish citizenship dependently through the affected individual.
For withdrawal, Article 66 of the Regulation on the Implementation of the Turkish Citizenship Law provides that the withdrawn decision becomes ineffective from the date of the original decision.
The difference may affect family relationships, nationality acquired through birth, historical transactions and other legal statuses.
17. What Do the Council of State’s 2026 Decisions Show About Criminal and Administrative Law?
17.1. Council of State, 10th Chamber, E.2024/3835, K.2026/324, February 4, 2026
This case concerned withdrawal of citizenship previously acquired through exceptional naturalisation, with the administration relying on national-security and public-order considerations.
The Council of State emphasised the need for concrete, sufficient and serious factual grounds supporting a decision to withdraw citizenship.
The court also considered the distinction between circumstances existing at the date of naturalisation and subsequent events unrelated to the original statutory conditions.
In light of the circumstances in the relevant file, the court annulled the withdrawal decision.
Legal significance: Administrative authority to withdraw citizenship does not eliminate the need to establish an adequate factual and legal basis for the measure.
17.2. Council of State, 10th Chamber, E.2024/405, K.2026/361, February 5, 2026
This case concerned an individual who acquired Turkish citizenship through property investment.
The relevant authorities determined that documents concerning the foreign-exchange purchase transactions had been inaccurately prepared, and the investment certificate of conformity was subsequently cancelled.
The Council of State examined whether the statutory requirements for acquiring citizenship through investment had actually been fulfilled.
The absence of a separate legal challenge to the certificate’s cancellation was also significant to the assessment.
The court dismissed the action challenging the withdrawal of citizenship.
Legal significance: The objective legal conditions of the investment may remain decisive in administrative citizenship proceedings independently of questions concerning the investor’s personal criminal liability.
These decisions do not establish contradictory legal principles. They demonstrate the application of the nationality framework to different factual circumstances.
Both concern the existence of the legal conditions required at the time of the original citizenship acquisition.
In one case, the factual grounds for withdrawal were considered inadequate. In another, the court accepted that the necessary investment conditions had not been established as fulfilled in the circumstances.
Accordingly, allegations originating in a criminal investigation must be supported by legally relevant facts concerning the citizenship acquisition before they can justify the applicable administrative measure.
The finality and subsequent appellate history of each decision must be checked in any individual proceeding.
18. Administrative Litigation Against Turkish Citizenship Cancellation or Withdrawal
18.1. The Competent Court
The court with jurisdiction depends on which authority issued the administrative act being challenged.
Under Article 24 of Council of State Law No. 2575, the Council of State acts as a court of first instance in annulment proceedings challenging Presidential decisions.
Different administrative acts, such as cancellation of an investment certificate by another authority, may require proceedings before a different competent administrative court.
18.2. Filing Deadlines
Under Article 7 of Administrative Judicial Procedure Law No. 2577, the general judicial filing period before the Council of State and administrative courts is 60 days unless a different statutory period applies.
The applicable starting date must be evaluated with reference to the administrative act, notification requirements and the circumstances of the particular case.
For individuals living abroad, previously completed notifications to authorised legal representatives may be particularly important.
18.3. Administrative Applications
A qualifying administrative application submitted in accordance with Article 11 may affect the running of the judicial filing period.
However, not every enquiry, request for a file copy or application for information automatically suspends the deadline.
18.4. Suspension of Execution
Under Article 27, filing an administrative annulment action does not automatically suspend execution of the contested decision.
A suspension-of-execution request requires the court to assess the cumulative legal conditions, including manifest unlawfulness and damage that would be difficult or impossible to remedy.
Consequences affecting passports, residence, family life, professional activity and business management may be relevant to that assessment.
Nevertheless, such consequences do not guarantee that interim relief will be granted.
18.5. Use of Criminal Evidence in Administrative Litigation
Lawfully obtained expert reports, banking analyses, interview records and other evidence from criminal proceedings may be relevant in administrative litigation under the applicable procedural rules.
Where criminal evidence contradicts a material allegation relied upon by the administration, identifying and explaining that inconsistency may be important.
However, restrictions arising from investigation confidentiality, personal-data protection and rules concerning the lawful acquisition of evidence must be respected.
19. How Should Criminal and Administrative Citizenship Proceedings Be Coordinated?
An investor may face criminal proceedings and administrative review arising from the same property transaction.
Handling those processes without consideration of their factual overlap may create risks of inconsistent explanations, incomplete evidence and missed procedural deadlines.
However, coherent representation does not mean mechanically submitting the same statements in every proceeding. Each legal process has distinct questions, procedural safeguards and evidentiary requirements.
19.1. Establish the Current Official Status
The existence of a criminal investigation, the competent prosecution office, the individual’s procedural capacity and any questioning or protective measures should be established to the extent legally possible.
Separately, the existing citizenship status, investment conformity documents and any adverse administrative decisions must be examined.
19.2. Prepare a Chronology of the Investment
The relevant dates should be organised chronologically, including contract execution, banking transactions, title deed transfer, appraisal, certificate of conformity, citizenship application, naturalisation and subsequent administrative or criminal measures.
19.3. Identify Individual Conduct
The analysis must distinguish acts performed personally by the investor from documents prepared by third parties and representations made by intermediaries.
Personal conduct is central to criminal liability, while administrative law additionally requires consideration of the objective legal conditions of the citizenship acquisition.
19.4. Preserve Documents and Financial Evidence
Historical bank statements, SWIFT records, old valuation reports, title deed documents, correspondence and contracts may become difficult to retrieve several years after a transaction.
Lawful collection and preservation of original documents, transaction histories and relevant digital records are therefore important.
19.5. Distinguish Technical Findings from Criminal Intent
The historical value of a property is a technical valuation question.
Whether a particular investor knowingly participated in criminal forgery or fraud is a separate legal question.
An expert report may be important evidence, but does not automatically establish the investor’s intention or all the required elements of a criminal offence.
Awaiting the conclusion of a criminal investigation does not automatically suspend the filing period for an administrative lawsuit challenging a citizenship decision.
Where an individual decision has already been issued, the available administrative applications and judicial deadlines require independent attention.
20. Frequently Asked Questions About Turkish Citizenship and Criminal Investigations
Does a criminal investigation mean my Turkish citizenship has been cancelled?
No. A criminal investigation and an individual administrative decision terminating citizenship are different legal matters.
I have been summoned to the police. Does an arrest warrant exist?
A summons does not automatically establish the existence of an arrest warrant. Any applicable judicial measures require separate verification.
Can I have a lawyer present during questioning?
Yes. Suspects are entitled to the assistance of defence counsel under the relevant provisions of the Criminal Procedure Code, including Articles 149 and 150.
I do not speak Turkish. Can I request an interpreter?
Interpretation assistance is available under the applicable legal conditions. Article 202 governs relevant interpreter rights.
Does a file-access restriction mean that my lawyer cannot obtain any information?
No. The scope of the restriction and the applicable statutory exceptions must be evaluated separately.
Will KYOK guarantee that I retain Turkish citizenship?
No. KYOK concerns criminal prosecution, whereas compliance with the objective legal requirements for nationality requires a separate administrative assessment.
Can a KYOK decision support my citizenship case?
Yes, potentially. Its factual findings may be relevant where they concern allegations relied upon by the administration.
Will an acquittal automatically reverse a citizenship withdrawal?
No. Administrative withdrawal must be addressed through the appropriate administrative or judicial mechanisms.
I did not prepare the appraisal report. Can I still face criminal liability?
Criminal liability depends on the individual’s conduct and the statutory elements of the alleged offence. A third party’s conduct cannot automatically be attributed to the investor.
I genuinely paid for the property. Is that enough?
Genuine payment is important evidence, but the property, investment amount, applicable historical rules and other statutory conditions must also be assessed.
Can I bring an administrative case while the criminal investigation is ongoing?
Where an administrative act exists and the legal conditions for judicial review are satisfied, completion of the criminal investigation is not necessarily required.
Does filing a citizenship lawsuit automatically suspend the administrative decision?
No. A separate suspension-of-execution decision may be necessary under Article 27 of Administrative Judicial Procedure Law No. 2577.
Is every purchaser from an investigated developer considered a suspect?
No. A criminal investigation concerning a developer does not establish that every purchaser has the same procedural status.
Does living abroad stop a Turkish criminal investigation?
No. Residence outside Türkiye does not automatically terminate an investigation. The procedures for taking statements and other measures depend on the applicable legal framework.
Can legal preparation begin before any citizenship withdrawal decision is issued?
Depending on the circumstances, it may be possible to verify official status, preserve documents, examine investment compliance and prepare relevant legal or technical submissions.
21. Conclusion: Criminal Liability, Administrative Legality and Citizenship Status Require Separate Examination
The citizenship investigations conducted in 2025 and 2026 demonstrate the complex consequences that allegations concerning investment transactions may produce under Turkish criminal and administrative law.
Nevertheless, personal criminal liability and fulfilment of the objective statutory requirements for citizenship are separate matters.
Criminal responsibility is personal. Alleged unlawful conduct by a developer, appraiser, company or intermediary does not automatically establish that every investor dealing with that person participated in a criminal offence.
Conversely, a decision not to prosecute or the absence of a criminal conviction does not itself prove that all investment requirements were satisfied at the date of naturalisation.
The distinction between Articles 31 and 40 of Law No. 5901 is central. Article 31 addresses cancellation where citizenship resulted from false declarations or concealment of material facts attributable to the individual. Article 40 addresses withdrawal of decisions issued without the required statutory conditions or as duplicates.
These legal mechanisms have distinct conditions, consequences and forms of judicial review.
The Council of State’s published decisions in 2026 also demonstrate that citizenship withdrawal requires legally relevant and adequately established factual grounds. Where the underlying statutory conditions were not fulfilled, withdrawal may be found lawful; where those conditions are not properly established, the administrative act may be annulled.
For an investor affected by a criminal investigation, the appropriate starting point is to determine the nature of the allegations and procedural status, reconstruct the genuine economic transaction, examine the citizenship file, identify any existing adverse administrative decision and preserve the relevant statutory filing deadlines.
The central legal principle is that personal criminal responsibility and administrative review of objective nationality requirements cannot be substituted for one another. Effective legal protection requires these questions to be considered together, but under their respective statutory standards.
22. Related Publications by Dolğun Akademi
This article forms the third part of our five-part 2026 research series on Turkish citizenship cancellation, withdrawal, criminal investigations and investment-related legal protection.
Methodological Note: Statements attributed to investigative or administrative authorities are presented as official allegations or reported findings, not automatically as final judicial determinations. Each criminal allegation and citizenship decision requires individual consideration. Statutory amendments and subsequent appellate decisions must be checked when applying this research to a particular case.
One of the most important legal questions facing individuals who acquired Turkish citizenship through investment or other exceptional naturalisation procedures is whether their citizenship remains legally valid.
Following the criminal investigations and administrative reviews publicly announced in 2025 and 2026, many naturalised Turkish citizens living abroad have become concerned about their citizenship records, Turkish passports, national identity cards, family members’ legal status and ability to enter Türkiye.
However, purchasing property from a construction company under investigation, being mentioned in an investigative file or becoming subject to a review of investment eligibility does not necessarily mean that Turkish citizenship has been cancelled.
Conversely, continued access to the Turkish e-Government portal, the presence of population records or possession of a passport that has not reached its printed expiry date does not conclusively establish that no subsequent citizenship decision has been issued.
The correct legal inquiry must determine whether an administrative decision exists, which authority issued it, the statutory provision relied upon, the decision date, whether and how notification occurred, and how the decision was reflected in official records.
This article analyses the relevant provisions of Turkish Citizenship Law No. 5901, Administrative Judicial Procedure Law No. 2577, Council of State Law No. 2575 and Law No. 6458 on Foreigners and International Protection.
It also examines three significant Council of State decisions from 2025 and 2026 concerning the evidentiary grounds for withdrawal, irregular investment documentation and the consequences of missing a judicial filing deadline.
The discussion applies to people of all national origins who have acquired Turkish citizenship, including Arab, Chinese, Russian, Iranian, Afghan, European and other foreign-born Turkish citizens.
1. Do Reports About Turkish Citizenship Revocations Mean That Everyone Has Lost Citizenship?
Investigations concerning alleged irregularities in investment-based Turkish citizenship acquisitions attracted increasing public attention in 2025 and expanded during 2026.
On August 4, 2026, the Turkish Ministry of Justice announced that legal proceedings had been initiated concerning the cancellation of citizenship acquired by 687 individuals.
A second operation announced on September 21, 2026, involved the citizenship files of 1,070 people, comprising 263 principal investors and 807 family members.
These announcements demonstrate that extensive criminal and administrative investigations were underway. They do not establish that every person mentioned had already received a final individual administrative decision terminating citizenship.
1.1. Different Stages of Citizenship Review
The following legal and factual situations must be distinguished:
A criminal investigation involving a construction company or property development.
The appearance of an investor’s name in documents examined by investigators.
An individual criminal investigation concerning the investor.
Re-examination or cancellation of an investment certificate of conformity.
An administrative review of a previous citizenship acquisition decision.
Issuance of an individual citizenship cancellation or withdrawal decision.
Official notification of that decision to the affected person or authorised representative.
Judicial proceedings challenging the administrative measure.
These stages may be related, but they are not legally interchangeable.
For example, a foreign investor who purchased a genuine property from a developer subsequently investigated for irregularities does not lose citizenship merely because of that commercial connection.
Nevertheless, cancellation of the investment certificate on which citizenship was originally based may create a serious administrative-law issue requiring immediate examination.
2. Cancellation, Withdrawal and Deprivation of Turkish Citizenship: What Is the Difference?
The terminology used to describe the termination of nationality is not merely academic. Different legal mechanisms have different statutory conditions, temporal consequences, effects on family members and judicial implications.
2.1. Cancellation Under Article 31 of Law No. 5901
Article 31 of the Turkish Citizenship Law provides for cancellation where the decision to grant citizenship resulted from a false declaration by the individual or concealment of material circumstances forming the basis of citizenship acquisition.
The relevant examination concerns the information provided in the application, the circumstances allegedly concealed and their legal relationship with the original naturalisation decision.
A subsequent reassessment of a property’s market value is not necessarily equivalent to establishing that the investor knowingly made a false declaration or concealed material facts.
However, the absence of an objective statutory investment requirement may raise a separate issue under Article 40.
2.2. Withdrawal Under Article 40
Article 40 governs the withdrawal of citizenship acquisition or loss decisions subsequently found to have been issued without the required legal conditions or as duplicate decisions.
The central inquiry is whether the legally required conditions existed at the time the original decision was issued.
Article 66 of the Regulation on the Implementation of the Turkish Citizenship Law provides that a withdrawn decision becomes legally ineffective from the date of the original decision.
This retrospective effect distinguishes withdrawal from cancellation and can generate complex consequences where the individual has subsequently married, had children, established companies, acquired property or relinquished a previous nationality.
2.3. Deprivation Under Article 29
Article 29 establishes a separate statutory mechanism commonly translated as deprivation or loss of citizenship by decision of the competent authority.
Its legal grounds differ from the cancellation of an investment eligibility certificate or a technical review of real estate valuation.
The consequences and notification rules applicable to Article 29 decisions must therefore be assessed separately.
2.4. Why the Distinction Matters
Under Article 32, an Article 31 cancellation decision takes effect from the date of the cancellation decision.
By contrast, the implementing regulation describes Article 40 withdrawal as rendering the earlier decision ineffective from its original date.
Accordingly, a person informed that their Turkish citizenship has been “revoked” must first obtain and analyse the actual administrative decision before selecting an appropriate legal remedy.
3. How Can I Find Out Whether My Turkish Citizenship Is Still Valid?
A reliable citizenship-status investigation should not be based solely on an online screenshot, an old passport or an informal statement from a third party.
Article 36 of Law No. 5901 provides that official population records, identity documents and passports constitute presumptive evidence of Turkish citizenship unless proven otherwise.
These documents therefore have significant evidentiary value, but their evidentiary presumption may be displaced by a legally relevant decision or contrary official record.
3.1. Directorate General of Population and Citizenship Affairs
The principal administrative authority responsible for citizenship records is the Directorate General of Population and Citizenship Affairs under the Ministry of Interior.
The individual or a duly authorised representative may request information within the limits permitted by the relevant administrative procedures.
The investigation should determine the original citizenship acquisition date, the underlying decision, any subsequent cancellation or withdrawal measure and the relevant notification records.
3.2. Provincial Population and Citizenship Directorates
Provincial authorities have important application and correspondence functions in citizenship procedures.
Article 37 of Law No. 5901 governs applications submitted through the competent governorate in Türkiye or through diplomatic and consular missions abroad, either personally or through an appropriately authorised representative.
However, the ability to submit an application does not establish an unrestricted right to access every confidential document in every governmental file.
3.3. Examination of the Competent Authority’s Decision
For individuals naturalised through an exceptional procedure involving a Presidential decision, it may be necessary to determine whether a subsequent Presidential withdrawal decision has been issued.
Obtaining a decision number alone may be insufficient. Its date, legal grounds, affected individuals and relationship with the original citizenship file should also be confirmed.
Written official confirmation ordinarily provides a stronger basis for legal analysis than an oral representation.
3.4. Separate Examination of Criminal Records
Citizenship-status records and criminal investigation records are maintained for different purposes.
The absence of an identified citizenship cancellation decision does not conclusively establish that no criminal investigation exists. Conversely, the existence of a criminal investigation does not automatically terminate citizenship.
4. My e-Devlet Account Still Works. Does That Prove My Citizenship Remains Valid?
Türkiye’s e-Government platform, known as e-Devlet, provides access to important official services and documents.
Nevertheless, the ability to log in or retrieve previously issued documents does not conclusively establish that no subsequent administrative citizenship decision exists.
4.1. Official Population Registration Extracts
The e-Devlet service titled “Nüfus Kayıt Örneği Belgesi Sorgulama” allows eligible users to obtain official population registration extracts.
A digitally authenticated population record can be important evidence of the status currently recorded by the relevant administration.
However, the absence of a cancellation notation in a particular extract does not necessarily establish that no review is pending or that no decision has yet to be reflected across administrative systems.
The citizenship application enquiry service is useful for following an application process.
It should not automatically be treated as a comprehensive legal verification mechanism for every possible subsequent withdrawal decision issued several years after naturalisation.
The continued appearance of a Turkish identity number in historical documents or electronic systems does not, by itself, replace the need to examine the most recent legally operative citizenship decision.
4.4. The Difference Between Technical Records and Legal Status
The issuance of an administrative decision, communication between public institutions, updating of population records and synchronisation of electronic databases may constitute separate steps.
Such distinctions do not diminish the legal importance of population records. Rather, they explain why a complete status assessment must consider the underlying administrative decision as well as the available official records.
5. Which Documents Should Be Examined in an Official Citizenship File?
A comprehensive legal review should organise the available documents according to their legal function.
5.1. Documents Relating to the Original Acquisition
These may include the citizenship application date, statutory grounds of naturalisation, application reference number, original decision number, the decision date and the documents evidencing notification.
For investment-based applications, the property title deed, investment certificate of conformity, valuation reports, foreign-currency documents and the legislation applicable on the investment date are especially important.
5.2. Documents Relating to a Possible Cancellation or Withdrawal
The individual cancellation or withdrawal decision, if any.
The statutory and regulatory provisions relied upon.
The decision date and official reference number.
The factual allegations or findings relied upon against the individual.
Documents showing communication to relevant authorities.
Notification records concerning the individual or authorised representative.
Changes made in the population registration system.
Any subsequent correction or reconsideration decisions.
5.3. Investment Certificates and Citizenship Decisions Are Distinct
A property investment certificate of conformity and the subsequent decision granting Turkish citizenship are separate administrative instruments.
Cancellation of a conformity certificate may provide the factual and legal basis for the withdrawal of an earlier naturalisation decision.
However, the legality of each administrative act and the available judicial remedies should be independently considered.
This distinction was particularly significant in the Council of State’s decision numbered E.2024/405, K.2026/361, which concerned allegedly inaccurate foreign-exchange purchase documents and the subsequent cancellation of a property investment certificate.
5.4. Individual Files of Family Members
The principal investor’s file may contain important information about family members, but the citizenship acquisition date and legal grounds applicable to each spouse and child should be examined separately.
Children born after the original naturalisation, spouses who acquired citizenship independently and family members whose status arose under different provisions may require different legal assessments.
6. What Happens If I Never Received Official Notification of My Citizenship Cancellation?
Notification is one of the most important procedural questions for naturalised Turkish citizens residing outside Türkiye.
Article 41 of Law No. 5901 governs the notification of decisions concerning citizenship acquisition and loss.
A specific publication mechanism exists for deprivation decisions under Article 29. Other cancellation or withdrawal decisions should not automatically be treated as notified merely because a newspaper or government press release discussed the broader investigation.
6.1. Does the Absence of Notification Mean No Decision Exists?
No. The legal existence of an administrative decision and notification of that decision are distinct issues.
Article 32 expressly provides that an Article 31 cancellation decision takes effect from the date of the decision.
Consequently, absence of notification does not necessarily establish that the administrative act is legally nonexistent or incapable of producing any legal consequences.
Nevertheless, missing or defective notification may be highly significant for the commencement of judicial filing periods and access to an effective legal remedy.
6.2. Individuals Residing Abroad
Several explanations may exist where a person residing abroad has not personally received any document.
The administrative authority may not yet have completed the notification process. The address on record may be outdated. The notification may have been transmitted through a diplomatic mission, or another legally permitted service method may have been used.
Residence outside Türkiye does not automatically invalidate all official notifications.
Likewise, the absence of personal physical delivery does not conclusively establish that no legally effective notification occurred.
6.3. Notification to an Authorised Attorney
Where an attorney has been validly authorised to receive documents relating to citizenship proceedings, service upon that representative may have important consequences for the filing period.
In its decision E.2025/6295, K.2025/7133, the Council of State’s 10th Chamber treated notification to the authorised attorney as relevant to the commencement of the statutory period.
Therefore, individuals who previously retained legal counsel should examine former powers of attorney and the existence of any prior notifications.
7. When Does the Deadline for Challenging a Citizenship Decision Begin?
Judicial filing deadlines are a central concern in Turkish administrative litigation.
A potentially strong substantive argument against a citizenship withdrawal decision does not eliminate the consequences of failing to institute proceedings within the legally applicable period.
7.1. The General 60-Day Filing Period
Under Article 7 of Administrative Judicial Procedure Law No. 2577, the general period for initiating an administrative action before the Council of State or an administrative court is 60 days unless another applicable law provides a different period.
Article 8 governs the calculation of periods, generally beginning from the day following the legally relevant notification, publication or announcement.
However, the identification of the legally effective starting date requires examination of the decision, its notification method and the applicable procedural rules.
7.2. Administrative Applications Under Article 11
Article 11 permits an eligible person, within the judicial filing period, to request the withdrawal, annulment, amendment or replacement of an administrative decision from the competent superior authority or, in the absence of such an authority, the authority that issued the decision.
A qualifying Article 11 application suspends the running of the judicial filing period.
Where no response is given within 30 days, the request is deemed rejected under the applicable statutory rule. Following express or implied rejection, the remaining judicial filing period continues to run, taking account of the time that elapsed before the application.
Not every administrative letter automatically qualifies for this legal effect. The nature of the request, its recipient and the statutory conditions must be examined.
7.3. Does a Request for Information Suspend the Filing Period?
Merely asking an authority for a document, a copy of a file or confirmation of citizenship status should not automatically be treated as an Article 11 application capable of suspending a running litigation deadline.
A request for access to information and a formal request to withdraw an existing administrative decision are legally distinct.
Accordingly, an individual who has already become aware of a withdrawal decision may face procedural risks by waiting for documents without evaluating the filing deadline.
7.4. The Importance of Notification Evidence
A complete legal review should identify who received the notification, on what date, with which authority and through which method.
Where electronic notification or service abroad is involved, the relevant special procedural rules must also be considered.
8. Important Council of State Decisions from 2025 and 2026
Judicial decisions demonstrate why citizenship disputes cannot be resolved merely by referring to general media statements.
The following cases concern different legal issues: the sufficiency of evidence, allegedly false investment documents and compliance with the statutory filing period.
8.1. Council of State, 10th Chamber, E.2024/3835, K.2026/324, February 4, 2026
Subject: Withdrawal of Turkish citizenship on national-security and public-order grounds.
The case concerned an individual who had acquired Turkish citizenship through an exceptional naturalisation procedure.
The administration subsequently relied on Article 40 of Law No. 5901 to withdraw the original citizenship decision, citing national-security and public-order concerns.
The Council of State examined whether the legal and factual circumstances necessary to justify withdrawal had been established through sufficient, specific and serious evidence.
The decision addressed the significance of circumstances existing when citizenship was originally acquired, rather than simply treating later allegations as conclusive proof that the earlier statutory conditions had been absent.
The court concluded that the factual and legal basis presented was insufficient to justify the contested withdrawal as applied to the claimant.
Accordingly, the relevant part of the Presidential withdrawal decision was annulled.
Legal significance: The state’s authority over nationality does not eliminate the requirement that an administrative withdrawal decision be supported by lawful and adequately established grounds.
This was not a property-valuation dispute. Nevertheless, the reasoning is important for the judicial assessment of the evidence and legal grounds relied upon in citizenship withdrawal cases.
8.2. Council of State, 10th Chamber, E.2024/405, K.2026/361, February 5, 2026
Subject: Investment citizenship, inaccurate foreign-exchange purchase documents and cancellation of the certificate of conformity.
The dispute involved a foreign national who had obtained Turkish citizenship through a property investment.
The claimant maintained that the investment payment had been made and that the competent authorities had accepted the application and issued the necessary documentation.
However, the authorities subsequently determined that documents concerning foreign-currency purchases had been inaccurately prepared.
The property’s investment certificate of conformity was cancelled, and the original citizenship decision was subsequently withdrawn under Article 40.
The Council of State examined whether the statutory requirements for acquisition through investment had actually been fulfilled.
The cancellation of the certificate of conformity, together with the absence of a successful legal challenge to that certificate decision, was significant in the court’s assessment.
The court found no illegality in the withdrawal of the citizenship decision and dismissed the action.
Legal significance: The previous issuance of an investment certificate does not necessarily prevent withdrawal where the required statutory conditions are subsequently established not to have existed.
Importantly, the case involved the historic investment requirements applicable to the investor’s original transaction. The current USD 400,000 property threshold should not be retroactively substituted for the threshold applicable at that earlier time.
8.3. Council of State, 10th Chamber, E.2025/6295, K.2025/7133, December 30, 2025
Subject: Notification to an authorised lawyer and expiry of the judicial filing deadline.
The case concerned a decision withdrawing Turkish citizenship.
The relevant notification was delivered to the claimant’s authorised lawyer on April 10, 2025.
The proceedings were not initiated until December 20, 2025.
The Council of State held that the applicable 60-day filing period had elapsed and dismissed the case as time-barred without examining the substantive legality of the contested withdrawal.
Legal significance: Even where a claimant believes the citizenship withdrawal is unlawful, judicial proceedings must comply with applicable procedural deadlines.
Notification to an attorney authorised to receive relevant documents may start the filing period. Appointing a different lawyer does not automatically restart that period.
8.4. Comparative Assessment of the Three Decisions
Decision
Principal Issue
Outcome
2026/324
Insufficient legal and factual grounds for withdrawal
Annulment
2026/361
Inaccurate investment documents and cancelled certificate
Action dismissed
2025/7133
Late filing following notification to authorised counsel
Time-bar dismissal
Read together, these decisions demonstrate that the outcome depends on the specific grounds for withdrawal, the underlying evidence, the prior administrative steps and the procedural history of the case.
The availability of subsequent appeals and the finality of these decisions must be verified individually. No general assumption concerning the exhaustion of all judicial remedies is made here.
9. Which Court Has Jurisdiction Over Turkish Citizenship Cancellation?
The competent judicial forum depends on the authority responsible for issuing the contested administrative act.
Under Article 24 of Council of State Law No. 2575, the Council of State has first-instance jurisdiction over annulment proceedings brought against Presidential decisions.
However, a separate decision cancelling a property investment certificate, or a decision issued by another administrative authority, may fall within the jurisdiction of a different administrative court.
It would therefore be incorrect to assume that all disputes concerning Turkish citizenship must necessarily be filed before the same court.
9.1. Suspension of Execution
Under Article 27 of Administrative Judicial Procedure Law No. 2577, filing an annulment action does not automatically suspend the execution of the challenged administrative decision.
A suspension-of-execution decision generally requires the cumulative evaluation of manifest unlawfulness and the risk of damage that would be difficult or impossible to remedy if the administrative act were implemented.
In citizenship cases, the consequences affecting passports, lawful residence, family relationships, professional activity and property may be relevant to that assessment.
However, serious consequences do not guarantee that a court will grant interim relief.
9.2. Multiple Administrative Acts
One factual dispute may involve several distinct administrative decisions: cancellation of a certificate of conformity, withdrawal of citizenship, modification of population records, invalidation of travel documents or subsequent immigration measures.
Each act must be identified and evaluated according to its own legal character and available procedural remedies.
10. What Happens to My Turkish Passport and Identity Card If My Citizenship Is Cancelled?
A Turkish passport and national identity card are official documents issued in connection with the individual’s Turkish citizenship status.
Article 36 of Law No. 5901 recognises their evidentiary significance for the proof of citizenship.
Nevertheless, if the underlying legal status is subsequently terminated, the continued validity of those documents must be examined independently.
10.1. A Passport’s Printed Expiry Date
The printed expiry date does not guarantee that the legal status supporting the passport’s issuance remains unchanged throughout its stated validity period.
Physical possession of the passport and its current legal usability are separate questions.
10.2. Collection or Invalidity of Documents
Where citizenship has legally ended, competent authorities may initiate separate procedures concerning the person’s Turkish identity and travel documents.
However, not every administrative decision necessarily produces identical passport-related action on the same date.
The actual decision and the applicable implementation measures should be identified.
10.3. Consular Appointments
Individuals living abroad may consider visiting a Turkish consulate to enquire about their legal status.
Where citizenship status is uncertain, the purpose of the consular visit and the potential treatment of existing documents should be evaluated beforehand.
There can be no general assurance that every passport will be retained by the holder, nor a general assertion that every document will necessarily be collected.
11. Can a Person Under Citizenship Review Enter Türkiye?
International travel is a central concern for people whose Turkish citizenship is subject to review.
The legal analysis requires consideration of nationality law, immigration legislation, passport requirements and criminal procedure.
11.1. If Turkish Citizenship Remains Legally Valid
Where the individual remains a Turkish citizen, entry into Türkiye is considered under the constitutional and statutory rules applicable to Turkish nationals.
Article 23 of the Constitution provides that a citizen cannot be deported or deprived of the right to enter the country.
However, separate criminal or judicial measures concerning the person may still require examination before travel.
11.2. If Turkish Citizenship Has Legally Ended
Where Turkish citizenship has been terminated, entry into Türkiye may become subject to the immigration rules applicable to foreign nationals.
Possession of a valid foreign passport, satisfaction of any visa requirements and the absence of applicable entry restrictions become relevant.
The loss of Turkish citizenship does not mean that possession of a foreign passport alone guarantees entry.
11.3. Should I Travel With My Turkish or Foreign Passport?
This question cannot responsibly be answered without examining the individual’s legal status and travel documents.
A person who previously acquired Turkish citizenship may no longer be entitled to rely on a Turkish passport if the underlying nationality decision has been legally withdrawn or cancelled.
Conversely, unverified rumours do not establish that Turkish citizenship has necessarily ended.
Before travel, the applicable citizenship status, lawful travel document, visa position and relevant judicial or administrative restrictions must be determined.
11.4. Possible Collection of Passports at Border Control
Passport invalidity, collection of a travel document, seizure under criminal procedure and immigration-related border measures may rest on different legal grounds.
If a person encounters such action, the identity of the authority, the stated legal grounds and the official record of the measure are important.
11.5. Residence Following Entry
A person entering Türkiye as a foreign national must consider the applicable period of lawful stay and any residence permit requirements.
Previous residence as a Turkish citizen does not necessarily create an automatic, unlimited right of residence following citizenship loss.
12. Does a Citizenship Review Mean That I Am Also Under Criminal Investigation?
Criminal investigations and administrative citizenship proceedings may rely on overlapping facts but constitute separate legal processes.
An investment file may be reviewed because evidence was obtained in a criminal investigation involving a developer or an intermediary.
That does not necessarily mean that the investor is personally classified as a criminal suspect.
12.1. Suspects, Witnesses and Victims
The person’s procedural status is essential.
A suspect is a person under investigation for allegedly committing a criminal offence. A witness may possess information relevant to the investigation. A victim or person harmed by a suspected offence may possess different procedural rights.
Confusing these statuses can lead to inaccurate assessments of legal risk.
12.2. Being Summoned for a Statement Is Not the Same as an Arrest Warrant
A summons to provide a statement to the police or prosecutor does not by itself establish that an arrest or detention warrant exists.
Nevertheless, questioning concerning an investment transaction may require careful legal preparation, review of financial evidence and the assistance of an interpreter where appropriate.
12.3. Confidentiality and Access to Investigation Files
Access to a criminal investigation file depends on the person’s procedural status, counsel’s authority and any applicable statutory restrictions.
The fact that a file is not visible to the individual through UYAP does not conclusively demonstrate that no investigation exists.
Likewise, the ability of an attorney to conduct an initial enquiry does not necessarily entail unrestricted access to every document in a confidential investigation.
12.4. Does Acquittal Automatically Restore Citizenship?
A decision not to prosecute, commonly called KYOK in Turkish practice, or a criminal acquittal does not automatically annul every separate administrative citizenship decision.
However, the outcome of criminal proceedings may provide significant evidence in subsequent or pending administrative litigation, depending on the factual and legal grounds relied upon by the administration.
13. If My Turkish Citizenship Is Cancelled, Will My Spouse and Children Also Lose Citizenship?
Family members may be affected by the cancellation or withdrawal of the principal investor’s citizenship.
However, it is not legally appropriate to assume that every member of the family necessarily holds citizenship on the same legal basis.
13.1. Spouses and Children Naturalised Through the Principal Investor
Article 32 of Turkish Citizenship Law No. 5901 expressly provides that a cancellation decision also applies to spouses and children who acquired Turkish citizenship dependently through the person concerned.
Accordingly, cancellation under Article 31 may directly affect family members whose citizenship was acquired through that relationship.
Nevertheless, the legal grounds and dates of each family member’s acquisition must be examined.
13.2. Children Born After Naturalisation
Children born after the initial citizenship acquisition may raise different legal questions.
Article 7 of Law No. 5901 governs acquisition of Turkish citizenship by descent.
A child who acquired citizenship by birth through a Turkish parent may have a different initial legal basis from a child naturalised together with the principal investor.
Where the parent’s citizenship is subsequently withdrawn with retrospective effect, additional questions arise concerning how the parent’s nationality at the date of the child’s birth should legally be assessed.
Such matters require specific legal analysis rather than an automatic conclusion.
13.3. A Spouse Who Acquired Citizenship Independently
If a spouse acquired Turkish citizenship through an independent statutory mechanism, the effect of the principal investor’s citizenship decision must be assessed separately.
Marriage alone does not establish that every independently acquired nationality status automatically terminates.
13.4. Children Holding Another Nationality
The existence of a second nationality may be relevant to the practical consequences of citizenship loss.
However, the child’s legal status must be examined under both Turkish nationality law and the nationality legislation of the other state.
13.5. Separate Representation and Litigation
Where separate administrative measures concern individual family members, distinct issues of notification, legal capacity, representation and judicial filing may arise.
This is particularly important where children have reached the age of majority.
14. Can I Recover My Former Nationality If Turkish Citizenship Is Withdrawn?
Not every foreign national who acquired Turkish citizenship retained a previous nationality.
Some states permit dual nationality, while others impose different conditions on acquiring a foreign citizenship or on retaining nationality after naturalisation abroad.
Some individuals may also have formally relinquished their previous nationality.
14.1. Individuals Holding Dual Nationality
Where a person remains a national of another state, the termination of Turkish citizenship does not automatically terminate that foreign nationality.
Nevertheless, the legal validity of foreign travel documents and the nationality rules of the other state should be checked.
14.2. Individuals Who Renounced Their Previous Nationality
Where the individual relinquished a previous nationality, the termination of Turkish citizenship may create a risk of statelessness.
It cannot be assumed that the former nationality will automatically be restored.
Reacquisition depends on the law of the relevant foreign state.
14.3. Statelessness Determination
Statelessness is generally concerned with a person who is not considered a national by any state under the operation of its law.
However, the loss of Turkish citizenship does not automatically mean that a person has been formally recognised as stateless for administrative purposes.
Applicable determination procedures and documentary requirements may need to be addressed separately.
15. What Happens to My Property, Bank Accounts or Company in Türkiye?
Termination of Turkish citizenship and termination of private property rights are distinct legal matters.
Ownership of immovable property, banking assets and corporate participation are regulated through different legal frameworks.
15.1. Ownership of Real Estate
The termination of Turkish citizenship does not mean that every property owned by the individual automatically becomes state property.
Article 33 of Law No. 5901 contains specific provisions concerning the liquidation of property in certain citizenship cancellation cases.
Where liquidation is legally required, the cancellation decision must address that issue and the statutory procedure must be followed.
Article 33 also addresses the postponement of liquidation where the cancellation decision is challenged before the courts.
Importantly, the historic legislative reference in Article 33 to Law No. 5683 must be considered together with the later repeal of that legislation and the current framework under Law No. 6458.
15.2. Foreign Ownership Restrictions
Foreign natural persons may own real estate in Türkiye subject to the applicable legislation, nationality-based conditions and property-related restrictions.
Accordingly, the situation of a former Turkish citizen must be assessed with reference to their current nationality, the type and location of the property and applicable foreign ownership rules.
15.3. Company Ownership
The loss of citizenship does not, by itself, automatically extinguish all private-law rights associated with company shares.
However, rules concerning foreign participation, company management, employment permissions and regulated sectors may become relevant.
15.4. Bank Accounts and Financial Assets
Bank accounts are additionally governed by banking regulations, customer identification requirements and any applicable judicial or administrative measures.
Citizenship loss, account restrictions and criminal seizure orders must not be treated as identical legal events.
16. Can I Continue Living in Türkiye After Losing Turkish Citizenship?
An individual whose Turkish citizenship has legally ended may need to regularise their position under immigration law.
Previous long-term residence, property ownership or family connections do not automatically confer an unrestricted right of residence after nationality has ended.
Nevertheless, family ties, employment, property ownership and other personal circumstances may be relevant to the availability of particular residence permit categories.
Residence permits, deportation decisions and administrative immigration detention are distinct legal measures.
Loss of citizenship does not automatically establish that the person must be immediately deported or placed in immigration detention.
These matters must be evaluated under Law No. 6458, including its separate judicial procedures and potentially different filing deadlines.
17. I Live Outside Türkiye. Can a Turkish Lawyer Investigate My Citizenship Status?
A properly executed power of attorney can be an important instrument for individuals residing abroad who need legal representation in Türkiye.
Article 37 of Law No. 5901 permits relevant citizenship applications through appropriately authorised representatives, subject to the statutory requirements.
The legal effectiveness of a particular power of attorney depends on its form, content and the authority required for the intended action.
17.1. Powers of Attorney Issued at Turkish Consulates
Turkish diplomatic and consular missions abroad may provide notarial services under the applicable conditions.
Individuals should verify appointment requirements, identification documents, interpreter arrangements and the requested authorisation wording before attending.
17.2. Powers of Attorney Issued by Foreign Notaries
A document executed before a foreign notary may require an apostille or another legally recognised method of authentication before it can be used in Türkiye.
The appropriate process depends on the foreign state’s treaty participation and the requirements of Turkish law.
Not every state participates in the Hague Apostille system. Therefore, consular or diplomatic legalisation may be necessary in some cases.
Turkish translation and domestic notarial formalities may also be required.
Depending on the circumstances, the power of attorney may need to authorise the representative to request information, inspect citizenship records, receive official notifications, submit administrative applications, institute proceedings and conduct related litigation.
Nevertheless, a broad power of attorney does not provide unrestricted access to confidential government information where access is limited by law.
17.4. Previously Appointed Lawyers
Where a former lawyer has acted on the individual’s behalf, the existing powers of attorney and prior proceedings should be examined.
In particular, an earlier notification to an authorised lawyer may already have triggered a statutory filing period.
Issuing a new power of attorney does not automatically invalidate the procedural effects of prior lawful notifications.
18. What Should I Do If I Suspect My Turkish Citizenship Has Been Cancelled?
A structured legal strategy begins with verification of the person’s official status, followed by consideration of the appropriate response to the particular administrative or judicial measures identified.
Step 1: Organise Existing Documents
Collect the original citizenship decision information, Turkish passport, identity card, population registration extracts, investment documents and any official correspondence.
Step 2: Verify the Official Citizenship Status
Examine accessible official records to determine whether an individual cancellation or withdrawal decision exists and identify its date, legal basis and administrative consequences.
Step 3: Check Notification and Filing Deadlines
Review personal notification records, notices delivered to former attorneys, consular correspondence and other lawful service methods.
Where an administrative decision exists, prompt evaluation of the applicable judicial deadline is essential.
Step 4: Examine Criminal Proceedings Separately
Where legally possible, determine whether a criminal investigation concerns the person or the relevant property transaction and identify the individual’s procedural status.
Step 5: Establish the Investment Evidence Chain
For real estate-based naturalisation, review title deeds, contracts, valuation reports, certificates of conformity, SWIFT records, foreign-exchange purchase documents and bank statements.
The objective is not merely to establish that documents exist, but to evaluate whether they prove a genuine transaction satisfying the requirements applicable at the time.
Step 6: Examine Family Members Separately
Identify when and under which legal provisions each spouse or child acquired citizenship.
Step 7: Assess Travel and Residence Consequences
Before travelling, review the legal validity of travel documents, the person’s current nationality, relevant immigration rules and any known judicial or administrative restrictions.
Step 8: Select the Appropriate Legal Remedy
Where no adverse decision has yet been issued, official enquiries, evidence organisation and examination of investment compliance may be priorities.
Where a decision has already been made and notified, protection of the applicable litigation deadline and consideration of judicial remedies may take precedence.
19. Common Misconceptions About Turkish Citizenship Cancellation
“My e-Devlet account works, so I am definitely still a Turkish citizen.”
Electronic access alone is not conclusive. The current official records and any subsequent legally operative administrative decisions must be examined.
“I still have my Turkish passport, so no cancellation decision can exist.”
Physical possession of a passport is not definitive evidence that no subsequent decision has been issued.
“I bought an apartment from an investigated company, so my citizenship was automatically cancelled.”
Buying property from a company under investigation does not by itself establish the termination of an individual’s citizenship.
“I live abroad, so a notification cannot affect my filing deadline.”
Lawful notification methods can apply to persons living abroad. Service upon an appropriately authorised attorney may also have procedural consequences.
“Appointing a new lawyer restarts the lawsuit deadline.”
A change of legal representation does not, by itself, restart a statutory filing period.
“If the prosecutor closes my criminal case, citizenship will automatically be restored.”
A criminal non-prosecution decision and an administrative citizenship decision belong to different legal proceedings. Their interaction requires separate analysis.
“Filing a lawsuit immediately makes my Turkish passport valid again.”
Filing an administrative action does not automatically suspend the challenged decision. Separate interim relief or a relevant judicial ruling may be required.
“If I lose citizenship, my house automatically belongs to the Turkish state.”
Nationality, property ownership and the exceptional statutory rules governing liquidation must be distinguished.
“The citizenship of every member of my family must have the same outcome.”
The legal basis and date of nationality acquisition may differ among family members.
“My original investment certificate makes citizenship withdrawal legally impossible.”
The Council of State’s decision K.2026/361 demonstrates that cancellation of a certificate and the failure of the underlying investment to meet statutory conditions may be decisive in a withdrawal dispute.
20. Conclusion: Turkish Citizenship Status Must Be Determined Through Official Records and Individual Legal Analysis
The developments of 2025 and 2026 have produced understandable uncertainty for individuals who acquired Turkish citizenship through investment or exceptional naturalisation procedures.
However, the question of whether a specific person’s Turkish citizenship has been cancelled or withdrawn cannot be answered solely by reference to press announcements, social-media lists or transactions involving a company under investigation.
Likewise, access to e-Devlet, possession of a passport or availability of historical population records cannot conclusively exclude the possibility of a subsequent administrative decision.
Turkish Citizenship Law No. 5901 establishes different regimes for cancellation, withdrawal and deprivation of nationality, each with different conditions and consequences.
The Council of State decisions examined in this article demonstrate the practical importance of these distinctions.
In one case, insufficient factual and legal grounds resulted in the annulment of a citizenship withdrawal decision. In another, inaccurate investment documents and cancellation of the underlying certificate supported the legality of withdrawal. In a third, the court dismissed proceedings without addressing the substance because the filing deadline had been missed.
The appropriate starting point for an affected individual is therefore a systematic investigation of official citizenship records, any existing administrative decision, the legal basis for that decision, the notification history, relevant criminal proceedings and the available judicial remedies.
Legal certainty in nationality law does not mean that citizenship decisions can never be reviewed. It means that the termination of nationality must rest on lawful grounds, established facts and effective judicial scrutiny.
21. Related Citizenship Law Publications by Dolğun Akademi
This article forms part of a five-part research series examining the Turkish citizenship investigations and legal developments of 2026.
Council of State, 10th Chamber, E.2024/3835, K.2026/324, February 4, 2026. Withdrawal of nationality, national security, evidentiary grounds and annulment. Full Decision.
Council of State, 10th Chamber, E.2024/405, K.2026/361, February 5, 2026. Investment certificate cancellation, foreign-currency purchase documents and withdrawal. Full Decision.
Council of State, 10th Chamber, E.2025/6295, K.2025/7133, December 30, 2025. Notification to legal counsel and judicial filing deadlines. Full Decision.
Military Service in Türkiye 2026: Types of Military Service, Paid Military Service Fees, Foreign Currency Military Service, Exemptions, and the Rights of Newly Naturalized Turkish Citizens
Author: Attorney Murat Can Dolğun Publication: Dolğun Akademi – TD Law Firm Practice Areas: Administrative Law, Constitutional Law, Military Service Law, Turkish Citizenship Law, Immigration Law, and Human Rights Law Last Updated: October 23, 2026
ABSTRACT
Military service in Türkiye is a constitutional public obligation governed primarily by Article 72 of the Constitution of the Republic of Türkiye and Military Recruitment Law No. 7179. However, the obligation to perform military service does not apply identically to every Turkish citizen. A person’s age, medical condition, educational background, nationality status, residence abroad, previous military service, and the legal method through which Turkish citizenship was acquired may substantially affect the existence, duration, and manner of fulfilling this obligation.
The year 2026 has been particularly significant for the Turkish military service system because of legislative amendments affecting paid military service fees. Through Law No. 7577, published in the Official Gazette on April 17, 2026, the statutory coefficient used to calculate the paid military service fee was increased from 240,000 to 300,000. Following the adjustment of the civil servant monthly salary coefficient in July 2026, the paid military service fee for the second half of the year was established at TRY 472,653.60.
Nevertheless, Turkish military service law encompasses far more than the payment of a fee. The existing legal framework provides for six months of compulsory service as a private or non-commissioned enlisted soldier, twelve months of service as a reserve officer or reserve non-commissioned officer, paid military service, foreign currency military service, educational and overseas deferments, medical exemptions, and various circumstances in which military service is legally considered to have been completed.
One of the most important subjects examined in this article concerns foreign nationals who subsequently acquire Turkish citizenship. In particular, male individuals who become Turkish citizens through real estate investment, exceptional naturalization, or ordinary naturalization procedures may benefit from specific exemptions or deferments under Article 43 of Military Recruitment Law No. 7179.
This study also addresses the legal position of dual nationals, recognition of military service performed in foreign countries, the consequences of annulment or loss of Turkish citizenship, military service obligations following reacquisition of citizenship, failure to undergo military registration, failure to report for military service, administrative fines, medical assessments, administrative appeals, judicial review, and the protection of fundamental rights.
The purpose of this article is not merely to explain military service procedures. It is to provide a comprehensive legal analysis of how military service obligations arise, how they may be postponed or discharged, and which legal remedies are available when administrative authorities incorrectly determine an individual’s military status.
I. CONSTITUTIONAL AND LEGAL FOUNDATIONS OF MILITARY SERVICE IN TÜRKİYE
Article 72 of the Constitution of the Republic of Türkiye establishes national service as both a right and a duty of every Turkish citizen. The same constitutional provision states that the manner in which national service shall be performed, or deemed to have been performed, either within the Armed Forces or in the public sector, shall be regulated by law.
This constitutional provision establishes three fundamental principles governing military service obligations.
First, military service is a public law obligation. Administrative decisions concerning military registration, classification, deferment, exemption, and deployment derive their legal authority from legislation rather than from private contractual relationships.
Second, the scope and conditions of military service must be determined by legislation. Although the Constitution establishes national service as a general constitutional duty, it does not directly identify every category of persons required to perform military service or every individual entitled to exemption.
Third, administrative decisions concerning military service remain subject to the rule of law and judicial review. Article 125 of the Constitution establishes the principle that administrative acts and decisions are subject to judicial review, subject to constitutionally recognized exceptions.
Under Article 2 of Military Recruitment Law No. 7179, the legislation applies to male citizens of the Republic of Türkiye. Therefore, the general constitutional concept of national service must be distinguished from the personal scope of compulsory military service under existing statutory law.
Women are not subject to the same general compulsory military service obligation applicable to men. However, women may serve in the Turkish Armed Forces as professional military personnel under the applicable recruitment and employment regulations.
The general statutory military service age also requires clarification. Under Law No. 7179, military age begins on January 1 of the calendar year in which a male citizen turns 20 and ends on January 1 of the year in which he turns 41.
Nevertheless, reaching the end of the statutory military service age does not necessarily eliminate every legal consequence arising from previous administrative violations or criminal proceedings.
II. WHAT TYPES OF MILITARY SERVICE EXIST IN TÜRKİYE IN 2026?
The modern Turkish military service framework was substantially reorganized through Military Recruitment Law No. 7179, which entered into force in 2019.
The duration and legal characteristics of military service depend on the individual’s classification and applicable statutory conditions.
Type of Service
Duration
Financial Conditions in 2026
Regular enlisted military service
6 months
No paid military service fee
Reserve officer service
12 months
Remuneration and benefits under applicable law
Reserve non-commissioned officer service
12 months
Remuneration and benefits under applicable law
Paid military service
1 month
TRY 472,653.60
Foreign currency military service
Distance education; no compulsory in-person basic training
Foreign currency equivalent of TRY 472,653.60
Voluntary additional six-month service
Additional 6 months
Allowance of at least the net minimum wage
The table identifies the principal methods of performing military service. Other legal mechanisms include exemptions based on medical conditions, military service deemed completed following naturalization, and special exemptions prescribed by law.
Such exemptions must not be confused with independent categories of military service. They concern circumstances in which the obligation does not arise, is discharged by operation of law, or is legally regarded as satisfied.
Professional military careers, including commissioned officers, non-commissioned officers, specialist enlisted personnel, and contracted military personnel, are subject to separate rules concerning recruitment, employment, contractual obligations, and service benefits.
III. HOW MUCH IS THE PAID MILITARY SERVICE FEE IN TÜRKİYE IN 2026?
The paid military service fee applicable between July 1 and December 31, 2026, is TRY 472,653.60.
This amount was officially announced by the Turkish Ministry of National Defence on July 7, 2026.
3.1. How is the paid military service fee calculated?
Under Article 9 of Military Recruitment Law No. 7179, the fee is calculated by multiplying the statutory indicator by the civil servant monthly salary coefficient applicable on the date of payment.
For the second half of 2026, the calculation is as follows:
300,000 × 1.575512 = TRY 472,653.60
The Ministry of Treasury and Finance established the relevant monthly coefficient as 1.575512 through its circular dated July 3, 2026.
3.2. What changed in April 2026?
Law No. 7577, adopted on April 2, 2026, and published in Official Gazette No. 33227 on April 17, 2026, amended the statutory calculation method.
Article 12 of that legislation increased the indicator used to determine the paid military service fee from 240,000 to 300,000.
This constituted a 25% increase in the statutory indicator.
Following the amendment, the Ministry of National Defence announced the April 2026 fee as TRY 416,361.30. The amount subsequently increased to TRY 472,653.60 in July following the adjustment of the civil servant salary coefficient.
The legislative amendment also addressed the allocation of revenues collected through paid military service, including arrangements concerning the central budget and the Defence Industry Support Fund.
Accordingly, the increase in paid military service fees during 2026 should not be attributed exclusively to ordinary salary coefficient adjustments. It resulted from the combination of a statutory legislative amendment and a subsequent coefficient adjustment.
3.3. How much will paid military service cost in 2027?
As of October 23, 2026, this study does not adopt any definitive paid military service amount for 2027.
Under the existing legal framework, the amount is linked to the applicable civil servant monthly salary coefficient and is therefore subject to further adjustment.
Any exact prediction concerning future fees must be distinguished from an officially determined amount.
Applicants should also understand that the amount payable is linked to the legally applicable rate on the date of payment, rather than merely the date of submitting an application.
IV. WHO CAN APPLY FOR PAID MILITARY SERVICE?
Paid military service, commonly referred to in Turkish as bedelli askerlik, is available to eligible male Turkish citizens who satisfy the requirements established by Law No. 7179 and the Military Recruitment Regulation.
Applicants must generally have entered military service age, must not have commenced actual military service, and must meet the applicable administrative and medical conditions.
There is no general upper age limit for paid military service. However, the individual’s status as a person legally subject to military service must first be established.
Applicants who have not completed their military registration and medical examination procedures must complete the necessary formalities before their applications can be properly processed.
Individuals legally determined to be medically unfit for military service should not be required to pay a fee merely to obtain an exemption to which they are already entitled.
4.1. Where can an application be submitted?
Depending on the applicant’s circumstances, applications may be submitted through the Turkish e-Government system or at a military recruitment office.
However, persons classified as draft evaders, unregistered military-age persons, or individuals who have failed to report for military service may be subject to a different procedure and may be required to apply directly to a military recruitment office.
4.2. What is the payment deadline?
As a general rule, the applicable paid military service fee must be paid within two months following the application date.
Payment is made in a single installment. The statutory paid military service system does not provide an ordinary installment payment arrangement.
Particular caution is required where an applicant has previously been classified as a draft evader or has failed to report for service.
Failure to pay within the prescribed period may affect the person’s ability to benefit from paid military service in the future, depending on the relevant statutory restrictions and the applicant’s history.
4.3. Is attendance at a military training facility compulsory?
Yes. Payment of the fee alone does not ordinarily complete paid military service.
Applicants must generally participate in one month of basic military training.
Therefore, payment of the fee and the legal completion of military service are distinct stages.
4.4. Can an applicant withdraw from paid military service?
Withdrawal may be possible at certain stages of the application process.
However, withdrawal after obtaining a place through classification or selection procedures may have consequences for the individual’s ability to apply again.
For this reason, applicants should assess the refund rules, classification timetable, training dates, and possible consequences of withdrawal before making a final decision.
V. FOREIGN CURRENCY MILITARY SERVICE: REQUIREMENTS, FEES, AND THE 1,095-DAY RULE
Foreign currency military service, known in Turkish as dövizle askerlik, is a special mechanism available to certain Turkish citizens residing abroad.
Although the financial calculation is connected to paid military service, the two systems are legally distinct.
They differ in eligibility requirements, residence and employment conditions, and obligations concerning military training.
5.1. Foreign currency military service fee in 2026
For the second half of 2026, the underlying Turkish lira amount is TRY 472,653.60.
The foreign currency equivalent is calculated using the applicable foreign exchange buying rate of the Central Bank of the Republic of Türkiye on the payment date.
Consequently, there is no single fixed euro amount applicable throughout the entire year.
For illustration only, if the applicable buying rate were TRY 50 per euro, the corresponding amount would be approximately EUR 9,453.07.
This figure is an illustrative calculation and must not be interpreted as the actual exchange rate or an officially announced euro-denominated fee.
5.2. The 1,095-day residence or employment requirement
Eligible applicants generally must demonstrate at least three years, equivalent to 1,095 days, of qualifying residence or employment abroad under the statutory conditions.
For individuals working abroad as employees, employers, or members of a profession or trade, employment and residence authorizations, contracts, and actual periods of work may be relevant.
Different provisions may apply to persons working as seafarers aboard foreign-flagged vessels.
For certain multiple nationals and individuals born and residing abroad who hold indefinite residence permits, the legislation may permit the relevant period of residence to be assessed without the ordinary employment requirement.
Periods physically spent in Türkiye may have to be deducted from the qualifying period.
In suitable circumstances, periods of employment in different countries may be combined, provided that the applicable legal conditions are satisfied and the relevant documentation is submitted.
5.3. Must applicants travel to Türkiye for military training?
No. Under the current foreign currency military service framework, eligible applicants are not generally required to travel to Türkiye to complete one month of physical basic military training.
Instead, they must complete the distance education program established by the Ministry of National Defence.
The official distance education portal is available at:
It is important to distinguish completion of the online training program from final approval of the foreign currency military service application.
Consular procedures, examination of supporting documents, confirmation of eligibility, and completion of payment obligations remain separate administrative stages.
5.4. Is there an age limit?
The former age limit of 38 for foreign currency military service has been abolished.
Nevertheless, removal of that restriction does not create an unconditional right to complete military service through payment alone.
Applicants must continue to satisfy the relevant statutory conditions.
5.5. Important considerations for Turkish citizens living abroad
Living outside Türkiye does not automatically establish eligibility for foreign currency military service.
Applicants must examine the legal basis of their residence, employment status, actual time spent abroad, travel history, and consular records.
Special restrictions may also apply to individuals who receive remuneration from Türkiye, work abroad in certain official capacities, or lack the relevant qualifying employment status.
VI. REGULAR MILITARY SERVICE, RESERVE OFFICERS, AND RESERVE NON-COMMISSIONED OFFICERS
6.1. Six-month military service
Under the present legal system, the standard period of compulsory military service for enlisted personnel is six months.
Not every individual subject to military service must choose the paid military service option.
Where the statutory requirements are satisfied, the military obligation may be discharged by completing ordinary military service.
6.2. Reserve officer service
Reserve officer service lasts twelve months.
Eligibility and classification depend on factors such as educational qualifications, personnel requirements of the Turkish Armed Forces, and the relevant military classification procedures.
An applicant’s personal preference to serve as a reserve officer does not automatically entitle the applicant to that classification.
6.3. Reserve non-commissioned officer service
Reserve non-commissioned officer service also lasts twelve months.
This category is particularly relevant to individuals holding qualifying higher education degrees.
However, the applicant’s degree alone does not conclusively determine military classification.
6.4. Comparing different military service categories
The legal and financial consequences of regular enlisted service, reserve officer service, and reserve non-commissioned officer service are not identical.
They differ in duration, duties, responsibilities, remuneration, and service conditions.
Accordingly, the choice or preference expressed by an eligible applicant should be assessed in light of educational qualifications, professional circumstances, and individual requirements.
VII. VOLUNTARY ADDITIONAL SIX-MONTH MILITARY SERVICE
Individuals who complete their initial six-month military service as enlisted personnel may, subject to the applicable conditions, apply to continue their service for an additional six months.
Approval depends on matters including the evaluation of the applicant by military superiors and the relevant personnel requirements.
When approved, the total military service period becomes twelve months.
Individuals serving during the voluntary additional period receive an allowance that must not be lower than the applicable net minimum wage, subject to the statutory framework.
Participation is not compulsory and must not be confused with an automatic entitlement to continued military employment.
The relevant legislation also provides certain benefits concerning subsequent military personnel recruitment and social security arrangements.
The scope and application of these benefits depend on the special rules governing each procedure.
VIII. MUST NEWLY NATURALIZED TURKISH CITIZENS PERFORM MILITARY SERVICE?
One of the most important questions in Turkish citizenship law is whether foreign men who acquire Turkish citizenship later in life become subject to compulsory military service.
The answer requires particular attention to Article 43 of Military Recruitment Law No. 7179.
The legislation does not subject all newly naturalized citizens to exactly the same military service obligations.
Instead, the individual’s age at naturalization, previous military service, and the legal method through which citizenship was acquired are decisive.
8.1. Naturalized citizens aged 22 or older
Under Article 43, persons who acquire Turkish citizenship in the calendar year in which they are 22 years of age or older are generally considered to have fulfilled their military service obligation.
This rule is subject to the statutory exception concerning persons who acquire Turkish citizenship through descent.
Importantly, the exemption does not necessarily require the individual to have completed military service in another country.
The statutory age requirement constitutes an independent legal basis for treating the military service obligation as fulfilled.
For example, a foreign man who acquires Turkish citizenship at the age of 30 and has never performed military service in any country may nevertheless be legally considered to have fulfilled his Turkish military service obligation, provided that the conditions of Article 43 are satisfied.
In such circumstances, the individual does not obtain exemption by paying the paid military service fee.
Instead, the relevant legislation treats the obligation itself as having been fulfilled.
8.2. Why does the legal method of acquiring citizenship matter?
Turkish citizenship may be acquired through birth, descent, ordinary naturalization, exceptional naturalization, or other procedures established by Turkish Citizenship Law No. 5901.
The legal basis of citizenship acquisition may directly affect whether the military service exemption under Article 43 is applicable.
In particular, individuals whose Turkish citizenship is established or registered through descent must not automatically be treated in the same manner as foreign nationals who subsequently acquire Turkish citizenship by a decision of the competent authorities.
Failure to distinguish these categories may lead to serious legal errors in military registration and exemption decisions.
IX. HOW IS THE AGE OF 22 CALCULATED FOR NEWLY NATURALIZED CITIZENS?
The calculation of age is a particularly important issue under Article 43 of Military Recruitment Law No. 7179 and Article 90 of the Military Recruitment Regulation.
According to the administrative rules explained by the Ministry of National Defence, the year of birth is taken into account rather than the precise day and month of birth.
In practical terms, the relevant age is calculated by subtracting the person’s year of birth from the calendar year in which Turkish citizenship was acquired.
Year of Birth
Naturalization Year
Calculated Age
General Legal Result
1990
2026
36
Military service deemed completed
2000
2026
26
Military service deemed completed
2004
2026
22
Military service deemed completed
2005
2026
21
Military obligation and deferment must be examined
2007
2026
19
Military service age and deferment rules must be examined
These examples concern individuals acquiring Turkish citizenship for the first time, outside the statutory exception applicable to citizenship through descent.
Different rules may apply to persons who lose and subsequently reacquire Turkish citizenship or who fall within the scope of special international agreements.
Consider an individual born on December 31, 2004, who acquires Turkish citizenship on January 1, 2026.
Although the individual has not yet reached his twenty-second birthday in the ordinary chronological sense, the difference between the naturalization year and birth year is 22.
Accordingly, the statutory age requirement may be satisfied.
This distinction may become particularly important when naturalization procedures are completed near the beginning or end of a calendar year.
X. WHAT OPTIONS ARE AVAILABLE TO NATURALIZED CITIZENS AGED 21 OR YOUNGER?
Men who acquire Turkish citizenship at an age that does not satisfy the statutory exemption under Article 43 may become subject to military service unless another legally recognized exemption or completed-service provision applies.
However, Article 43 also provides an important deferment mechanism.
Eligible individuals may request deferment of military service for two years from the date on which Turkish citizenship was acquired.
This deferment should not be assumed to have been automatically entered into every individual’s military records.
The applicant should verify the administrative status of the deferment and obtain confirmation from the relevant military recruitment office.
10.1. What happens when the two-year deferment expires?
Following expiry of the deferment period, the person may become subject to the applicable military registration and classification procedures.
If the individual remains entitled to educational deferment or another statutory postponement, those possibilities must be separately examined.
10.2. Newly naturalized university students
University enrollment may provide an additional statutory basis for military service deferment.
However, the two-year deferment associated with naturalization and a deferment based on educational status arise from different legal provisions.
It should not be assumed that separate deferment periods can always be automatically added together.
The date of university enrollment, age limits, earlier military registration history, and any draft evasion or failure-to-report status must be examined.
XI. DOES MILITARY SERVICE COMPLETED IN ANOTHER COUNTRY COUNT IN TÜRKİYE?
Article 43 of Law No. 7179 recognizes certain circumstances in which a person who subsequently acquires Turkish citizenship may be deemed to have fulfilled military service because of previous military service in the country of origin.
Individuals who properly document that they completed military service, or were legally considered to have completed it, before acquiring Turkish citizenship may qualify under this provision.
This rule is especially relevant to persons naturalized before reaching the age of 22.
For example, a foreign national who acquires Turkish citizenship at the age of 21, having previously completed compulsory military service in his country of origin, should not automatically be classified as required to perform military service in Türkiye merely because he does not satisfy the age-based exemption.
The recognition of previous military service must be assessed separately.
11.1. What documents are required?
According to the Ministry of National Defence’s explanations concerning naturalized citizens, documents establishing previous military service must be submitted in their original form, accompanied by Turkish translations prepared by a sworn translator and notarized as required.
Depending on the country issuing the documents and the relevant international agreements, an apostille certificate or consular legalization may also be required.
For persons whose previous foreign military service was legally regarded as completed without ordinary active duty, the relevant foreign authority’s decision and its legal basis should be examined.
11.2. Foreign medical exemptions
Some individuals may have commenced military service abroad but subsequently been discharged or exempted because of medical conditions.
Under the relevant rules, such circumstances may qualify for recognition in Türkiye where the prescribed requirements are met.
However, a foreign medical exemption certificate does not necessarily produce an identical exemption in Türkiye in every case.
The previous military service history, the nature of the foreign decision, and the statutory recognition conditions remain important.
XII. DUAL CITIZENSHIP, CITIZENSHIP BY DESCENT, AND TURKISH CYPRIOT NATIONALS
12.1. Are all dual nationals exempt from Turkish military service?
No. Dual nationality alone does not create an automatic exemption from compulsory military service in Türkiye.
The decisive considerations include when Turkish citizenship was acquired, how it was acquired, when the other nationality was obtained, and whether an applicable bilateral agreement exists.
12.2. Turkish citizens by birth
A male individual who has been a Turkish citizen since birth and also possesses a foreign nationality generally remains subject to the ordinary Turkish military service rules.
The age-based exemption under Article 43 cannot be applied merely because the individual holds more than one nationality.
12.3. Citizenship acquired through descent
Article 43 contains a specific exception regarding individuals who subsequently acquire Turkish citizenship through descent.
Consequently, delayed registration of Turkish citizenship acquired through family lineage must be distinguished from naturalization by a decision of the competent Turkish authorities.
The date on which citizenship was entered into the population register does not necessarily establish that citizenship was first acquired on that date.
12.4. Dual nationals who completed military service abroad
Following the entry into force of the new military recruitment framework in June 2019, military service performed in a foreign state by dual nationals is no longer recognized under an unrestricted general rule.
Nevertheless, applicable bilateral agreements concerning mutual recognition of military service and legally protected transitional arrangements may remain relevant.
The Ministry of National Defence has referred to arrangements involving Tunisia in its official explanations.
Therefore, a man who has held both Turkish and German nationality since birth cannot necessarily rely solely on military service completed in another country as proof that his Turkish military service obligation has been discharged.
12.5. Citizens of the Turkish Republic of Northern Cyprus
The legal situation of persons who acquire Turkish citizenship while holding citizenship of the Turkish Republic of Northern Cyprus requires separate analysis.
Article 42 of Turkish Citizenship Law No. 5901 and the applicable military service provisions must be considered together.
Any special rules relating to the recognition of military service or the acquisition of Turkish citizenship must be assessed in the context of the particular individual’s circumstances.
XIII. MILITARY SERVICE OBLIGATIONS OF TURKISH CITIZENS NATURALIZED THROUGH REAL ESTATE INVESTMENT
Foreign nationals may acquire Turkish citizenship through qualifying investment under the exceptional naturalization provisions of Article 12 of Turkish Citizenship Law No. 5901 and the relevant implementing legislation.
However, obtaining Turkish citizenship through real estate investment does not itself constitute a special military service exemption.
The applicant’s age and legal method of citizenship acquisition must be assessed under Article 43 of Law No. 7179.
For example, a male investor who acquires Turkish citizenship through a qualifying real estate investment at the age of 40 in 2026 will generally be regarded as having fulfilled his military service obligation, provided that the relevant statutory conditions apply.
The legal position of the investor’s family members may be different.
Suppose the same investor has a 19-year-old son who also acquires Turkish citizenship.
The son’s military status cannot automatically be assumed to be identical to that of his father.
The relevant questions include the son’s citizenship acquisition procedure, the date of the naturalization decision, his age, previous military service, and any applicable deferment or exemption.
For this reason, citizenship-by-investment applications should address the military service status of male family members as part of the overall legal planning process.
The conditions and legal risks associated with Turkish citizenship by investment are examined in our related publication:
XIV. HOW DO ANNULMENT, LOSS, OR REACQUISITION OF TURKISH CITIZENSHIP AFFECT MILITARY SERVICE?
The annulment, loss, withdrawal, and reacquisition of Turkish citizenship may create substantial legal consequences concerning military service.
However, these legal concepts must be distinguished carefully.
Annulment of a citizenship acquisition decision, deprivation of citizenship, permitted renunciation, and the various statutory mechanisms for loss of nationality do not necessarily have identical legal grounds or effects.
14.1. What happens to military records when citizenship is annulled?
When a person’s Turkish citizenship status changes, the relevant population and citizenship records may need to be reflected in the military recruitment system.
The Ministry of National Defence’s administrative explanations refer to the electronic transfer of relevant citizenship information from the Directorate General of Population and Citizenship Affairs to the Directorate General of Recruitment.
Nevertheless, it would be legally unsafe to conclude that the entire issue has been conclusively resolved merely because a particular status appears in an e-Government record.
The legal basis of the citizenship decision, its effective date, any pending judicial challenge, population records, and military recruitment records should be examined together.
14.2. Does loss of citizenship eliminate previous military liabilities?
There is no universally applicable answer.
The legal consequences depend on the statutory basis for loss of citizenship, the temporal effect of the relevant decision, and the previous military history of the individual.
For example, determining whether an obligation to perform future military service continues after loss of citizenship is legally distinct from determining the validity of an administrative fine imposed during an earlier period.
It should therefore not be assumed that every previously issued administrative decision or penalty automatically disappears when citizenship is lost.
14.3. Reacquisition of Turkish citizenship
Article 43(2) of Military Recruitment Law No. 7179 provides a special rule concerning persons who lose Turkish citizenship and subsequently reacquire it.
Their military recruitment procedures are carried out by taking their previous military service history into account.
This rule is particularly important for individuals whose citizenship previously ended through renunciation or another legally recognized mechanism and who later become Turkish citizens again.
Consider a person who was subject to military service during an earlier period of Turkish citizenship, subsequently lost Turkish citizenship, and reacquired it many years later.
The fact that the individual is older than 22 when citizenship is reacquired does not necessarily create a new exemption under the first paragraph of Article 43.
Instead, the individual’s previous military record must be examined under the provision governing reacquisition.
14.4. Judicial protection in citizenship and military service disputes
Where a citizenship annulment or withdrawal decision is challenged before an administrative court, military registration and classification issues may also arise.
The outcome of the citizenship proceedings may have consequences for the individual’s underlying military status.
However, filing a citizenship lawsuit does not automatically suspend every related military service decision.
Separate administrative applications, annulment proceedings, and requests for suspension of execution may be necessary depending on the nature of the contested military decision.
Further analysis concerning citizenship withdrawal, investment valuation disputes, and judicial remedies can be found in our related article:
Military service deferment is legally distinct from exemption.
An exemption generally removes or discharges the relevant obligation under applicable law, whereas deferment postpones the date on which the obligation must be fulfilled.
Article 20 of Military Recruitment Law No. 7179 and the relevant regulations provide deferment mechanisms for qualifying educational circumstances.
Educational Category
General Maximum Age
High school or equivalent education
22
University or higher education
28
Master’s degree and qualifying postgraduate education
32
Doctoral studies, qualifying specialization, or proficiency in arts
35
These ages represent general upper limits. The existence of educational enrollment does not necessarily establish an unconditional right to deferment until the relevant age.
The actual legal assessment must also take into account enrollment dates, previous educational qualifications, graduation, termination of studies, and any earlier military registration violations.
Additional deferment opportunities may be available following graduation or termination of certain educational programs.
For example, graduates of university programs lasting four years or longer may qualify for a two-year post-graduation deferment, subject to the applicable age limits and other statutory conditions.
For newly naturalized citizens, the interaction between the naturalization-related deferment and education-based deferment requires careful examination.
XVI. MEDICAL EXEMPTIONS FROM MILITARY SERVICE
Individuals who are medically unfit for military service may qualify for exemption under the relevant legislation.
However, an individual cannot obtain a final military exemption merely by declaring himself medically unfit or submitting an ordinary medical opinion from an unauthorized healthcare institution.
The relevant statutory provisions include Articles 15, 16, and 17 of Military Recruitment Law No. 7179 and the Regulation on the Health Competence of the Turkish Armed Forces, Gendarmerie General Command, and Coast Guard Command.
16.1. How does the medical examination process work?
The initial medical assessment may be carried out by a family physician or another authorized healthcare institution as part of the military registration process.
Where necessary, the individual is referred to an authorized medical board.
A final medical determination that a person is unfit for military service is subject to the procedures governing the relevant medical board report and its official approval.
16.2. Can a medical decision be challenged?
Yes. The relevant legislation provides a procedure for challenging military medical determinations.
According to the Ministry of National Defence’s published guidance, an objection to an approved medical report may be submitted through the military recruitment office within 30 days following notification or delivery of the report.
The administrative medical objection procedure must be distinguished from possible judicial review of an administrative decision based on the medical findings.
16.3. Psychiatric conditions and chronic illnesses
Chronic diseases, physical disabilities, psychiatric disorders, and other medical conditions may be relevant to determining eligibility for military service.
Nevertheless, the mere existence of a medical diagnosis does not automatically establish an exemption.
The relevant legal assessment depends on the nature and severity of the condition, its functional consequences, and the applicable medical classification rules.
Obtaining or submitting fraudulent medical documentation may also give rise to separate legal and criminal liability.
XVII. DRAFT EVASION, FAILURE TO REPORT FOR SERVICE, AND ADMINISTRATIVE FINES IN 2026
Turkish military service law distinguishes among several forms of non-compliance, including failure to undergo military registration, remaining unregistered, and failure to report for service after being called up.
The Turkish legal terms yoklama kaçağı, saklı, and bakaya refer to different administrative situations.
A person classified as yoklama kaçağı has failed to complete the required military registration procedures within the applicable period.
A person classified as bakaya has failed to report for military service despite being subject to a call-up or deployment obligation.
These classifications may result in administrative penalties and, under the conditions prescribed by law, criminal consequences.
17.1. Administrative fines in 2026
The Ministry of National Defence has published the following daily administrative fine amounts for 2026:
Circumstance
Daily Administrative Fine
Voluntary reporting
TRY 58.13
Apprehension by the authorities
TRY 116.27
These administrative fines must not be confused with the additional fee imposed on certain applicants seeking paid military service after periods of draft evasion or failure to report.
The two financial obligations arise from different statutory provisions.
17.2. Additional paid military service fee
For the second half of 2026, the applicable additional monthly fee is TRY 5,514.29.
The amount is calculated by reference to qualifying periods during which the person remained a draft evader, unregistered, or absent after call-up, subject to legally recognized excuses.
Under the relevant calculation method, a period of between one and thirty days may count as one calculation month.
For example, four applicable calculation months would produce an additional fee of TRY 22,057.16 at the second-half 2026 rate.
Combined with the standard paid military service fee, the illustrative total would be TRY 494,710.76.
This is an example only. The actual calculation must take into account the individual’s complete record, relevant periods, legal excuses, and the rate applicable when payment is made.
17.3. Does payment of an administrative fine complete military service?
No.
Payment of an administrative fine does not constitute performance of compulsory military service.
The individual’s substantive military obligation must still be resolved under the relevant legislation.
Likewise, payment of an additional fee required for paid military service does not necessarily cancel a previously imposed administrative fine.
17.4. Administrative penalties incorrectly imposed on naturalized citizens
Incorrect military records may create particularly serious difficulties for newly naturalized Turkish citizens.
For example, a male individual who acquires Turkish citizenship at the age of 30 may incorrectly appear in the military recruitment system as having failed to complete registration.
Before determining whether the individual has violated military service legislation, it is necessary to establish whether he was legally subject to the relevant obligation at all.
If Article 43 applies and the person should be considered to have fulfilled military service, the administrative and legal basis of any penalty must be reconsidered.
The Ministry of National Defence’s guidance also addresses circumstances in which administrative fines may be cancelled following the determination that a person was legally exempt or entitled to a relevant deferment.
XVIII. LEGAL REMEDIES AGAINST TURKISH MILITARY SERVICE DECISIONS
Disputes concerning military service may involve administrative registration, exemption refusals, medical decisions, classification, deployment, administrative fines, or criminal proceedings.
These matters are not necessarily subject to the same appeal procedure or judicial deadline.
18.1. Administrative application to the military recruitment office
Where a military record contains incorrect citizenship information, an incorrect birth year, missing exemption information, or another administrative error, the individual may submit a written application to the competent military recruitment office.
The application should identify the relevant legal basis and include supporting documents such as:
Turkish identification and civil registry records;
Naturalization decisions and supporting citizenship records;
Documents establishing the date and method of citizenship acquisition;
Previous military service certificates;
Medical decisions or educational records where relevant;
Copies of disputed administrative decisions.
18.2. Objections to administrative fines
Under Article 27 of Misdemeanours Law No. 5326, an administrative fine may generally be challenged before the competent Criminal Judgeship of Peace within fifteen days following notification or pronouncement of the decision.
Depending on the facts, the objection may address the absence of a legal military service obligation, an applicable exemption, a valid deferment, procedural irregularities, or the absence of the alleged violation.
The deadline for challenging an administrative fine must not be confused with the ordinary deadline for bringing an administrative annulment action against a different military service decision.
18.3. Annulment proceedings before administrative courts
Where an administrative authority unlawfully refuses an exemption, incorrectly determines military service status, or adopts an unlawful deployment decision, judicial review before an administrative court may be available.
Under Article 7 of Administrative Judicial Procedure Law No. 2577, the ordinary period for filing an annulment action before an administrative court is sixty days.
However, the legal nature of the administrative decision, notification requirements, and any special statutory deadline must be examined in each case.
The effect of an administrative application on the limitation period must also be assessed under the relevant provisions of Law No. 2577.
18.4. Suspension of execution
An unlawful military service decision may expose the affected individual to consequences that are difficult or impossible to remedy.
For example, a person who is legally entitled to exemption but is nevertheless ordered to report for military service may require urgent judicial protection.
Under Article 27 of Law No. 2577, the court may order suspension of execution where the applicable statutory conditions are satisfied, including manifest unlawfulness and the risk of irreparable or difficult-to-compensate harm.
However, filing an administrative lawsuit or an application to the authorities does not automatically suspend the challenged decision.
The existence and effect of an actual suspension order are decisive.
18.5. Criminal investigations concerning military service violations
In certain circumstances, violations involving draft evasion or failure to report may give rise to criminal proceedings following the administrative sanction process or under special statutory provisions.
Different rules may also apply during mobilization or wartime.
Criminal liability must be distinguished from the legality of the underlying administrative military service decision.
The existence of a criminal investigation does not, by itself, establish that the administrative determination of military status was lawful.
XIX. CONSCIENTIOUS OBJECTION, CONSTITUTIONAL RIGHTS, AND THE EUROPEAN CONVENTION ON HUMAN RIGHTS
Compulsory military service is not merely a matter of administrative regulation. It also raises significant constitutional and international human rights questions.
Conscientious objection refers to an individual’s refusal to perform military service because of genuinely held religious, ethical, moral, or philosophical convictions.
As of October 23, 2026, Turkish legislation does not establish a general and independent statutory exemption from compulsory military service based exclusively on conscientious objection.
Nevertheless, the European Court of Human Rights has addressed conscientious objection under Article 9 of the European Convention on Human Rights, which protects freedom of thought, conscience, and religion.
The Court’s judgment in Bayatyan v. Armenia is particularly important because it recognized that opposition to military service arising from sufficiently serious and compelling convictions may fall within the protection of Article 9.
Other judgments, including Ülke v. Türkiye, demonstrate the importance of assessing repeated penalties and the wider legal consequences experienced by conscientious objectors.
The judgment in Kanatlı v. Türkiye also raises significant questions concerning conscientious objection in the context of reserve military obligations.
However, developments in international human rights jurisprudence must not be confused with the existence of an unconditional administrative exemption under current Turkish domestic legislation.
An individual who refuses to comply with military service requirements solely on the basis of conscientious objection may still face administrative or criminal consequences under domestic law.
The fundamental legal question concerns the balance between the state’s authority to regulate national service and the individual’s protected freedom of conscience.
XX. LATEST DEVELOPMENTS IN TURKISH MILITARY SERVICE LAW IN 2026
20.1. April 17, 2026: Legislative increase in paid military service fees
Following publication of Law No. 7577 in the Official Gazette, the statutory indicator used to calculate the paid military service fee increased.
The Ministry of National Defence subsequently announced a fee of TRY 416,361.30 for the relevant April 2026 period.
20.2. June 5, 2026: Warning concerning the July fee adjustment
The Ministry of National Defence announced that the paid military service amount would change on July 1, 2026, following adjustment of the civil servant monthly salary coefficient.
Applicants wishing to benefit from the earlier fee were advised to complete the necessary application and payment procedures before the adjustment.
20.3. July 7, 2026: New paid military service amount announced
The paid military service fee for the second half of 2026 was announced as TRY 472,653.60.
The additional monthly fee applicable to certain applicants with previous periods of draft evasion or failure to report was announced as TRY 5,514.29.
Application procedures were resumed in accordance with the official announcement.
20.4. July 27, 2026: November 2026 military classification period
The Ministry of National Defence published an announcement concerning the November 2026 classification period.
According to that announcement, relevant registration and service preference procedures were required to be completed by August 31, 2026.
As of the publication date of this article, classification results were scheduled to be announced on October 27, 2026.
20.5. Upcoming deployment dates
Military Service Category
Scheduled Deployment Date
Reserve officer and reserve NCO candidates; enlisted personnel Group 1
November 5, 2026
Enlisted personnel Group 2
December 3, 2026
Enlisted personnel Group 3
January 7, 2027
According to the relevant official announcement, deployment documents may be obtained through the e-Government system or military recruitment offices starting ten days before the relevant deployment date.
Individual classification and deployment information should always be checked through official records.
Case 1: Foreign investor naturalized at the age of 35
A foreign national born in 1988 acquires Turkish citizenship through qualifying real estate investment in 2026.
He has never performed military service in any country. Nevertheless, the authorities indicate that he may be required to perform military service in Türkiye.
Legal assessment: If this is the individual’s first acquisition of Turkish citizenship and the statutory exception concerning citizenship through descent does not apply, Article 43 of Law No. 7179 should be considered.
Because the individual was older than 22 in the year of naturalization, he may be legally deemed to have fulfilled his military service obligation.
Proposed legal solution: Submit the naturalization decision and supporting citizenship records to the competent military recruitment office and request correction of the military service record. If an unlawful refusal or penalty exists, consider the applicable administrative or judicial remedies.
Case 2: A 21-year-old newly naturalized university student
A male foreign national born in 2005 acquires Turkish citizenship in 2026 and is enrolled at a Turkish university.
Legal assessment: The individual does not satisfy the age-based exemption under Article 43. However, the two-year naturalization-related deferment and the education-based deferment rules may be relevant.
Proposed legal solution: Examine the naturalization decision, student enrollment records, and military registration data. Determine which deferment provisions may apply and ensure that the administrative record accurately reflects the individual’s legal status.
Case 3: An Afghan national who completed military service before naturalization
A 21-year-old Afghan national acquires Turkish citizenship after having completed military service in his country of origin.
Legal assessment: Although the individual does not satisfy the age-based exemption, previous military service may qualify for recognition under Article 43.
Proposed legal solution: Obtain the original foreign military service documents, arrange the required authentication and Turkish translations, and submit the application to the competent military recruitment authority.
Case 4: A dual Turkish-German citizen residing in Germany
A male individual has held Turkish citizenship since birth and also possesses German nationality.
He resides in Germany and has never completed military service in Türkiye.
Legal assessment: Dual nationality does not automatically activate the naturalization exemption under Article 43.
However, the individual may qualify for overseas deferment or foreign currency military service, depending on residence, employment, and other statutory requirements.
Proposed legal solution: Examine residence permits, employment records, entry and exit history, and the 1,095-day requirement. Determine the appropriate consular and military recruitment procedures.
Case 5: Reacquisition of Turkish citizenship following previous loss
An individual who was previously a Turkish citizen and subject to military service later loses Turkish citizenship. Several years afterward, he reacquires Turkish nationality.
Legal assessment: The individual cannot automatically be treated as someone acquiring Turkish citizenship for the first time.
His previous military service history must be taken into consideration under Article 43(2).
Proposed legal solution: Examine the earlier citizenship records, the military service status at the time citizenship was lost, and the subsequent reacquisition decision.
Case 6: An administrative fine imposed despite an existing exemption
A man acquires Turkish citizenship for the first time at the age of 28 in 2026.
His military records do not reflect an exemption, and an administrative fine for failure to complete military registration is imposed.
Legal assessment: Before assessing any alleged violation, it must be determined whether the individual was legally subject to military service.
If Article 43 applies, the legal basis of the administrative fine may be contested.
Proposed legal solution: Request correction of the military registration record and consider an objection against the administrative fine within the applicable fifteen-day period.
XXII. LEGAL ACTION PLAN FOR NEWLY NATURALIZED TURKISH CITIZENS
Before concluding whether a newly naturalized Turkish citizen is subject to compulsory military service, the following questions should be examined systematically:
Was Turkish citizenship acquired for the first time, or was it reacquired?
What is the precise date and legal basis of citizenship acquisition?
Was citizenship acquired by descent or through a decision of the competent authorities?
How old was the individual in the calendar year of naturalization?
Did the individual complete military service in the country of origin?
Can previous foreign military service be established through legally acceptable documents?
What military service status currently appears in Turkish official records?
Does the person qualify for exemption, deferment, or recognition of completed military service?
Are there any draft evasion records, deployment decisions, or administrative fines?
Is an administrative application, objection, or judicial proceeding necessary?
Only after these questions have been resolved should the individual determine whether payment for military service or actual military attendance is required.
This is particularly important for individuals who may already be considered to have fulfilled their military service obligation under Article 43.
Unnecessary payment made because of an incorrect administrative record may create subsequent disputes concerning reimbursement and the correction of military records.
The appropriate legal approach is therefore to establish the individual’s legal military status first and to evaluate financial or physical military service obligations only afterward.
XXIII. FREQUENTLY ASKED QUESTIONS ABOUT MILITARY SERVICE IN TÜRKİYE
1. What is the paid military service fee in Türkiye in 2026?
The fee for July 1–December 31, 2026, is TRY 472,653.60.
2. What is the additional fee for draft evaders applying for paid military service?
The additional calculation amount is TRY 5,514.29 per applicable month during the second half of 2026. The actual amount depends on the relevant period and legal circumstances.
3. How long is ordinary compulsory military service?
The standard enlisted military service period is six months.
4. How long is reserve officer service?
Twelve months.
5. Must applicants for foreign currency military service travel to Türkiye?
Qualifying applicants generally do not need to complete in-person basic military training in Türkiye. Completion of the prescribed distance education and other administrative requirements is necessary.
6. I acquired Turkish citizenship at the age of 30. Must I perform military service?
If you acquired Turkish citizenship for the first time through a qualifying procedure other than the excluded descent category, you may be considered to have fulfilled military service under Article 43.
7. Does my exact birthday matter for the 22-year rule?
Under the applicable administrative calculation, the relevant calendar years are used rather than the precise day and month of birth.
8. Are Turkish citizens naturalized through investment exempt from military service?
Investment alone does not create an exemption. Age at naturalization and the applicable statutory conditions must be examined.
9. Will an 18-year-old child who acquires Turkish citizenship later have to serve?
Potentially. The individual may not qualify for the age-based exemption, but the method of acquiring citizenship, previous military service, deferment opportunities, and other exemptions must be examined.
10. I already completed military service abroad. Must I serve again in Türkiye?
The answer depends on whether you acquired Turkish citizenship later in life or were a Turkish citizen from birth, as well as on the relevant legislation and any applicable international agreements.
11. Does dual nationality automatically exempt me?
No.
12. Can a newly naturalized 20-year-old obtain a military service deferment?
A two-year deferment may be requested under Article 43, subject to the statutory conditions. Other deferment possibilities should be considered separately.
13. Can paid military service fees be paid in installments?
The current ordinary system requires payment in full.
14. Is one month of military training compulsory for paid military service?
Generally, yes.
15. How long do I have to challenge a military administrative fine?
Generally, fifteen days following the legally effective notification or pronouncement of the decision.
16. Can I bring a lawsuit if my exemption application is rejected?
An administrative annulment action may be available depending on the nature of the decision. The ordinary period is sixty days, subject to applicable special rules.
17. Does the annulment of Turkish citizenship automatically cancel previous military fines?
Not necessarily. The legal basis and temporal effect of the citizenship decision, together with the relevant military and penalty records, must be examined.
18. If I reacquire Turkish citizenship after the age of 22, am I automatically exempt?
No. Previous military service history must be considered under the special rules governing reacquisition of citizenship.
19. Can a family doctor issue a final military service exemption?
A family physician may perform initial medical assessments and refer the individual to the appropriate institution. A final unfitness determination is subject to the authorized medical board and official procedures.
20. What is the exact foreign currency military service fee in euros?
The euro amount is not fixed throughout the year. It is calculated using the applicable exchange rate on the payment date.
XXIV. CONCLUSION AND COMPREHENSIVE LEGAL ASSESSMENT
Compulsory military service in Türkiye constitutes an important public law obligation rooted in the Constitution and implemented through a detailed statutory and administrative framework.
The system established by Military Recruitment Law No. 7179 provides several legally distinct methods of fulfilling military service, including six-month enlisted service, twelve-month reserve officer or reserve non-commissioned officer service, paid military service, and foreign currency military service.
It also recognizes exemptions, deferments, and legal circumstances in which military service is deemed to have been completed.
The most significant financial development of 2026 has been the increase in the statutory indicator used to calculate paid military service fees through Law No. 7577.
As a result, the paid military service fee reached TRY 472,653.60 for the second half of the year.
However, the most challenging legal issues in military service law are not necessarily financial.
For individuals acquiring Turkish citizenship later in life, the existence of any military obligation depends on the legal basis and date of naturalization, age, previous military service, earlier citizenship history, and the accuracy of administrative records.
Article 43 of Military Recruitment Law No. 7179 establishes an important legal safeguard for qualifying naturalized citizens who are at least 22 years old in the calendar year in which citizenship is acquired.
Yet this provision must be interpreted together with the statutory exceptions concerning citizenship by descent and the reacquisition of Turkish citizenship.
Incorrect military classification can result in consequences extending beyond an administrative error.
It may lead to deployment orders, draft evasion records, administrative fines, and potentially criminal proceedings.
Accordingly, the fundamental legal question should always be whether the individual was subject to the relevant military service obligation in the first place.
Only after that determination has been made should the authorities assess the duration, manner, and financial consequences of military service.
An individual who is legally deemed to have fulfilled military service should not be required to make an unnecessary payment or complete military training merely because of an incorrect administrative record.
Similarly, an individual who remains subject to compulsory military service should not assume that residence abroad, possession of another nationality, or participation in a naturalization procedure automatically eliminates the obligation.
The rule of law requires military obligations to be imposed and administered in accordance with clear statutory provisions, individual legal circumstances, and effective judicial safeguards.
From this perspective, military service law is not merely concerned with the question of how many months an individual must serve or how much money must be paid.
Its central legal question is the authority of the state to establish, modify, defer, enforce, and terminate compulsory military service obligations within the limits imposed by constitutional law, statutory legislation, and fundamental rights.
XXV. LEGISLATION, OFFICIAL SOURCES, AND ACADEMIC BIBLIOGRAPHY
Military Recruitment Law No. 7179, Official Gazette dated June 26, 2019, No. 30813; particularly Articles 2–9, 14–24, and 38–45.
Military Recruitment Regulation (Askeralma Yönetmeliği), July 22, 2020, including provisions concerning paid military service, foreign currency military service, deferments, exemptions, and naturalized citizens.
C. Academic Publications and International Human Rights Sources
Pala, Gülşah, “Osmanlı Asker Alma Sisteminde Bedel-i Şahsî: Askerlik Yükümlülüğüne Alternatif Bir Uygulama” [An Alternative to Military Service Obligations in the Ottoman Recruitment System], Marmara Türkiyat Araştırmaları Dergisi, Vol. 13, No. 1, 2026. DergiPark.
Fidan, Merve; Hasta, Derya, “Vicdani Redde Yönelik Tutumların Yordanması: Erkek Rolleri ve İnsan Haklarına Yönelik Tutumların Aracı Rolü Üzerine Bir Çalışma” [Predicting Attitudes Toward Conscientious Objection], Türk Psikoloji Dergisi, Vol. 41, No. 97, 2026. DergiPark.
“Vicdanın Yedeği Olabilir mi: Güncel Bir Avrupa İnsan Hakları Mahkemesi Kararının İncelemesi – Kanatlı/Türkiye” [Can Conscience Have a Reserve? An Analysis of Kanatlı v. Türkiye], Yaşar Hukuk Dergisi. DergiPark.
“Avrupa İnsan Hakları Mahkemesi Kararlarında Vicdani Ret” [Conscientious Objection in the Case Law of the European Court of Human Rights], Istanbul Medipol University Faculty of Law Journal. DergiPark.
Batıgün, Elif Selen, “5901 Sayılı Türk Vatandaşlığı Kanunu’na Göre Vatandaşlığın Kaybettirilmesi” [Deprivation of Citizenship under Turkish Citizenship Law No. 5901], İnönü University Faculty of Law Journal, Vol. 17, No. 1, 2026. DergiPark.
European Court of Human Rights, Bayatyan v. Armenia, Application No. 23459/03, July 7, 2011.
European Court of Human Rights, Ülke v. Türkiye, Application No. 39437/98, January 24, 2006.
European Court of Human Rights, Kanatlı v. Türkiye, Application No. 18382/15, March 12, 2024.
Statutory provisions, official administrative guidance, historical legal scholarship, and international human rights jurisprudence have been considered separately throughout this study.
Academic publications are cited as scholarly contributions to legal analysis rather than as substitutes for binding legislation or judicial decisions.
XXVI. RELATED LEGAL PUBLICATIONS BY DOLĞUN AKADEMİ
Readers interested in the relationship between military service, Turkish nationality, citizenship by investment, and administrative litigation may consult the following related publications:
Attorney Murat Can Dolğun
Member of the Istanbul Bar Association
Law Lecturer at Istanbul University-Cerrahpaşa
TD Law Firm
Dolğun Akademi
Areas of Practice: Turkish Citizenship Law, Immigration and Foreigners Law, Administrative Law, Criminal Law, Constitutional Law, and Private International Law.
Office Address:
Istanbul World Trade Center
Block A2, Office 206
Yeşilköy, Bakırköy, Istanbul, Türkiye
Legal Disclaimer: This publication has been prepared for general legal and academic information purposes and reflects the legislative framework, official announcements, and academic materials considered as of October 23, 2026. Military service fees, administrative practices, exchange rates, classification schedules, and statutory provisions may change. Individual cases involving naturalization, military service exemptions, administrative penalties, or loss of citizenship require separate examination of the relevant legal documents and official records. This article does not constitute individualized legal advice or a guarantee of any particular legal outcome.
Author: Attorney Murat Can Dolğun – Istanbul Bar Association
Legal Analysis | Turkish Citizenship Law | Citizenship by Investment | Criminal Investigations | Administrative Litigation
Turkish Citizenship Revocation and Cancellation in 2026: Latest Developments, the 1,070-Person Investigation, 6,134 Citizenship Decisions, and Legal Remedies
Turkish citizenship acquired through real estate investment is facing an unprecedented level of administrative and criminal scrutiny. Following major investigations initiated in 2025, Turkish authorities announced additional operations in August and September 2026 concerning allegedly fraudulent property valuations, sham real estate transactions, artificial banking arrangements, and irregularities in investment eligibility certificates.
On September 21, 2026, Turkish authorities announced that an investigation involving 1,070 people, including investors and their family members, had been identified in connection with allegedly irregular citizenship acquisitions. On the same day, the Ministry of Interior reported that citizenship acquisition decisions concerning a total of 6,134 individuals had previously been annulled or withdrawn through various administrative procedures. These figures concern different categories of proceedings and must not be confused. [N4][N7]
The most important legal distinction is this: being mentioned in a criminal investigation does not establish that an individual’s Turkish citizenship has been cancelled or withdrawn. Equally, the absence of a notification does not conclusively prove that no administrative decision has been issued.
For each investor, the legal position must be determined through a separate examination of citizenship records, the acquisition date, historical property valuations, the genuine source and movement of funds, investment eligibility certificates, relevant administrative decisions, criminal proceedings, and the citizenship status of family members.
This article examines the developments reported up to October 8, 2026. It is based on publicly accessible official statements, Turkish legislation, decisions of the Council of State (Danıştay), academic scholarship, and anonymised observations concerning legal practice.
Verified official information is expressly distinguished from verbal reports that have not been independently confirmed. No unverified information is presented as an established court decision or a definitive determination concerning an individual investor.
Table of Contents
1. What Happened in the Turkish Citizenship Investigations During 2025 and 2026?
The investigations into Turkish citizenship acquired through real estate investment did not begin in September 2026. They form part of a series of investigations concerning allegedly irregular citizenship acquisitions, suspicious real estate transactions, financial arrangements, and property valuation practices.
September 2025: An Earlier Major Citizenship Investigation
On September 24, 2025, Turkish authorities conducted an operation across 19 provinces, coordinated from Istanbul, concerning allegations that Turkish citizenship had been obtained through sham property sales and fraudulent financial arrangements.
Subsequent news reporting referred to 451 foreign investors and 1,198 citizenship acquisitions when family members were included. The allegations concerned the absence of genuine foreign currency inflows, artificial financial transactions, and property sales allegedly structured to satisfy citizenship requirements without a genuine underlying investment. [N1][N2]
It is important to distinguish the findings and allegations of investigating authorities from criminal responsibility established by a final court judgment.
August 4, 2026: Investigation Involving 687 Citizenship Acquisitions
On August 4, 2026, the Turkish Ministry of Justice announced an investigation involving allegations that properties of relatively low actual value had been presented as more valuable through inaccurate valuation reports and that sham transactions had been used to facilitate citizenship acquisitions.
The authorities announced that legal procedures had been initiated concerning the possible cancellation of citizenship for 687 people. They also referred to an alleged failure to achieve approximately TRY 2.5 billion in genuine foreign currency inflows and the application of measures affecting various assets. [N3]
The announcement of a legal process for cancelling citizenship is not identical to proof that a separate, final and duly notified cancellation decision already exists for every person concerned.
On August 7, 2026, Anadolu Ajansı reported that 32 suspects had been placed in pre-trial detention and 48 others were subject to judicial-control measures. These are measures within criminal procedure, not findings of guilt. [N5]
September 21, 2026: Second-Wave Operation Involving 1,070 People
On September 21, 2026, another operation was announced concerning property transactions involving Gül İnşaat AŞ, Beyaz İnşaat and LİV İnşaat.
According to the official statements, transactions involving 734 foreign purchasers had been examined and 274 sales were identified by the authorities as allegedly sham transactions. The investigation was said to involve 1,070 people, including investors and family members. [N4]
September 25, 2026: Further Judicial Measures
On September 25, 2026, Anadolu Ajansı reported that 33 suspects had been detained pending trial, 20 were subjected to house-arrest-type judicial control, and 21 were subjected to other judicial-control measures. [N6]
As of October 8, 2026, these are among the latest material procedural developments that can be verified through the public sources examined for this article.
However, the absence of a more recent public announcement does not establish that criminal prosecutors, administrative authorities or the relevant government institutions have ceased processing individual files.
2. Have 6,134 People Already Lost Their Turkish Citizenship?
The Ministry of Interior statement reported on September 21, 2026 provided cumulative figures concerning administrative decisions affecting citizenship acquired through investment and other exceptional citizenship procedures.
Category of administrative action
Principal investors
Total including family members
Annulments associated with cancelled investment eligibility certificates
1,150
5,391
Withdrawal decisions involving public-order or national-security considerations
263
743
Total reported by the Ministry
1,413
6,134
Investors whose eligibility certificates were cancelled from February 11, 2026 onwards
458
1,393
Sources: Ministry of Interior statement reported by Anadolu Ajansı and TRT Haber, September 21, 2026. The 1,393-person figure in the final row must not be added separately to the cumulative total without establishing the relevant overlap. [N4][N7]
These figures demonstrate that the Turkish authorities have publicly reported the adoption of substantial numbers of citizenship annulment and withdrawal decisions.
Nevertheless, the figures should not be interpreted as establishing that every one of the 1,070 people identified in the latest investigation had already received a definitive administrative decision on September 21, 2026.
It is also necessary to distinguish an administrative decision being issued from that decision being notified to the person concerned, becoming the subject of judicial review, or being upheld by a final judgment.
The number of people identified in an investigation, the number of administrative decisions issued, and the number of decisions that have become final are legally different matters.
3. What Exactly Is the 1,070-Person Turkish Citizenship Investigation?
The investigation announced on September 21, 2026 concerns alleged irregularities in real estate transactions used to obtain Turkish citizenship through investment.
The authorities referred to analyses of land registry records, banking information, financial investigation reports, and expert assessments.
Investigation category
Reported figure
Property sales examined
734
Sales alleged by the authorities to be sham transactions
274
People identified as having acquired citizenship
1,070
Principal investors
263
Family members
807
People who acquired citizenship at the date of the principal decision
1,015
Children who reportedly acquired citizenship after that decision
55
Additional people associated with citizenship application processes
11
Source: Ministry of Interior statement of September 21, 2026, reported by Anadolu Ajansı. [N4]
The investigation reportedly concerns allegations that the foreign currency needed for citizenship was not genuinely introduced into Türkiye, that transaction flows were artificially created through seller-related financing or intermediary companies, and that certain valuation reports overstated property values.
These matters are highly relevant to the statutory requirements for citizenship by investment. However, allegations about an investment scheme must not be treated as conclusive evidence that every individual investor knowingly participated in wrongdoing.
Of particular importance is the fact that only 274 of the 734 examined transactions were described as sham sales in the official announcement.
The fact that a purchaser acquired property from a company under investigation does not, by itself, prove that the purchaser’s particular property transaction was sham, fraudulent or legally insufficient.
4. Which Construction Companies Are Mentioned in the Citizenship Investigations?
According to the September 21, 2026 statement reported by Anadolu Ajansı, the first wave of the 2026 investigation concerned transactions associated with Babacan İnşaat.
The second wave concerned selected real estate transactions associated with Gül İnşaat AŞ, Beyaz İnşaat and LİV İnşaat. [N4]
The mention of these companies in an official investigation must not be understood as proof that every property sold by these companies, every development project, or every independent residential unit was involved in an unlawful transaction.
Each relevant property must be assessed by reference to its land registry information, individual unit identification, actual purchase price, historical valuation, payment records and the applicable citizenship requirements.
Furthermore, lists of construction projects, apartment numbers or investors circulating on social media require particular caution. Unless independently verified through reliable official documents, such lists should not be presented as complete or authoritative records of affected citizenship cases.
This article does not treat unverified project lists as established facts.
5. Unconfirmed Verbal Information Concerning Investigation Procedures in October 2026
Beyond official public announcements, various observations may arise during legal research, enquiries with relevant public authorities, and discussions concerning the practical administration of individual citizenship and criminal investigation files.
Such information can be useful in identifying issues that require further investigation. However, statements received verbally are not equivalent to formal instructions, written administrative decisions, or judicial rulings.
Important notice: The following observations concern information reportedly communicated verbally during the first days of October 2026. They have not been independently confirmed as general official policies applicable to every investigation. They are subject to change at any time.
5.1. Reports of Temporary Suspension of Certain Police Interviews
According to certain verbal accounts obtained in connection with the practical administration of investigation files, some planned police interviews were reportedly suspended or postponed pending further instructions.
There have also been accounts of individuals attending law enforcement offices but not having their statements formally taken.
These accounts must not be interpreted as evidence that all interviews in all citizenship-related investigations have been suspended or that the prosecutor’s office has issued a general nationwide order preventing further statements from being taken.
Nor should they be understood as removing any individual’s obligation to comply with a lawful summons or other applicable criminal procedure requirements.
The current position must be verified individually, taking account of the specific investigation, any new prosecutor’s instructions, the person’s legal status, and any outstanding summons or judicial measures.
5.2. Reports Concerning the Separation of Investigation Files
Another issue referred to in practical accounts is the possibility that matters connected to a broad citizenship investigation may be separated into different criminal files.
Under Turkish criminal procedure, connected investigations may be separated or combined where the relevant legal requirements are satisfied.
However, reports that a particular investor has been transferred to a different investigation, or that a new file has been created, cannot be accepted as established facts without examination of the relevant official records.
In practice, the existence of a criminal investigation must be established for the particular individual rather than inferred solely from a developer’s name or the existence of another related proceeding.
5.3. Different Stages of Administrative Citizenship Proceedings
Investors connected to the same construction company or development project may be subject to different administrative stages.
For one individual, the only available information may concern a criminal investigation into a seller or intermediary. Another person’s investment eligibility certificate may have been placed under review. A third person may already be subject to an administrative annulment or withdrawal decision.
The fact that these processes may progress at different times does not permit a general conclusion concerning every investor in the same development.
Continuous verification: All verbally reported observations in this section must be reassessed whenever reliable written information becomes available. These observations do not constitute an assurance that interviews will not be conducted, that an investigation has ended, or that citizenship will be retained.
6. Are All Citizenship Investigations Being Conducted Under a Single Criminal File?
No general assumption should be made that all citizenship investigations announced during 2025 and 2026 are being conducted under one prosecutor’s investigation number or one criminal court case.
Different operations have involved different dates, companies, property transactions, suspects and alleged offences.
A criminal investigation may remain at the preliminary evidence-gathering stage, while a connected or earlier matter may already have resulted in an indictment or court proceedings.
Similarly, an investigation may involve the owners or managers of a construction company without every purchaser being formally designated as a suspect.
For an accurate assessment, the relevant questions include whether an individual investigation exists, the identity of the investigating prosecutor’s office, the person’s procedural status, whether an interview has been requested, whether any judicial measure has been imposed, whether files have been separated or combined, and whether an indictment has been filed.
The confidentiality of an ongoing criminal investigation can limit public access to detailed information. Therefore, the absence of a new press report is not proof that a particular investigation has been closed.
7. Annulment of Turkish Citizenship Under Article 31 and Withdrawal Under Article 40
A proper legal assessment of Turkish citizenship proceedings requires a clear distinction between Article 31 and Article 40 of Turkish Citizenship Law No. 5901.
These mechanisms are sometimes discussed together under the broad expression “Turkish citizenship revocation”. However, they involve different legal grounds and must not be treated as interchangeable.
7.1. Annulment of Citizenship – Article 31
Article 31 provides for the annulment of a decision granting Turkish citizenship where that decision resulted from the individual’s false declaration or concealment of important matters relevant to the acquisition of citizenship.
Accordingly, the individual’s conduct, the nature of the alleged false declaration or concealment, and its relationship to the citizenship acquisition decision are central to the legal analysis.
Alleged wrongdoing by a property developer, broker or valuation expert does not automatically establish that the investor personally made a false declaration or knowingly concealed a material fact.
7.2. Withdrawal of Citizenship Acquisition Decisions – Article 40
Article 40 concerns the withdrawal of decisions relating to the acquisition or loss of Turkish citizenship where it is subsequently established that the necessary legal conditions were not satisfied or that the decision was issued more than once.
Unlike Article 31, this provision is not confined to cases involving an applicant’s false statement or concealment.
An investor may therefore face an administrative argument that the objective legal conditions for citizenship were never satisfied, even where the investor denies fraud and maintains that the property was genuinely purchased.
However, the administration must still act within the law and establish the factual and legal grounds supporting the withdrawal decision. The existence and sufficiency of the evidence are matters capable of judicial review. [J1][A1]
Legal issue
Article 31 – Annulment
Article 40 – Withdrawal
Primary legal ground
False declaration or concealment of material facts by the individual
Acquisition without the required legal conditions, or a duplicate decision
Applicant’s conduct
Relevant to the statutory ground
Objective non-compliance may be decisive independently of personal fraud
Legal effect
Article 32 provides retrospective effect from the original decision date
Article 66 of the implementing Regulation provides invalidity from the original decision date
Family members
Linked citizenship acquisitions may be affected under Article 32
The legal foundation of related citizenship decisions requires separate assessment
Principal legal argument
Absence of the required false declaration, concealment or causal connection
Existence of all legally required conditions at the relevant acquisition date
Recent academic scholarship has also examined the relationship between investment conditions and the appropriate legal basis for subsequent administrative intervention. [A2]
8. How Can I Find Out Whether My Turkish Citizenship Has Been Cancelled or Withdrawn?
An accurate determination of Turkish citizenship status requires an examination of current official records and any administrative decisions issued in the individual’s case.
Being named in news reports, owning property in a development under investigation or being associated with a company mentioned by the authorities does not establish that a person’s Turkish citizenship has been withdrawn.
Equally, continued physical possession of a Turkish identity card or passport, access to an e-Devlet account, or the absence of a notification does not necessarily provide conclusive proof of current legal citizenship status.
Situation
Legal significance
The developer is under criminal investigation
This alone does not establish cancellation of the investor’s citizenship
The investor’s name appears in an investigation
Criminal status and administrative citizenship status must be examined separately
The investment eligibility certificate has been cancelled
This may create a serious administrative risk, but the citizenship decision must also be reviewed
A citizenship annulment or withdrawal decision has been issued
The date, legal ground, scope and notification must be established
The decision has been formally notified
Judicial time limits and urgent legal remedies must be assessed
No official information has yet been obtained
Neither continuation nor termination of citizenship can be concluded with certainty
The relevant assessment may require enquiries with the Directorate General of Civil Registration and Citizenship Affairs (Nüfus ve Vatandaşlık İşleri Genel Müdürlüğü), the authorities responsible for investment eligibility, and other competent institutions.
It is particularly important to distinguish the date on which an administrative decision was made from the date on which that decision was legally notified.
This distinction may affect the calculation of judicial deadlines and the availability of procedural remedies.
9. I Made a Genuine Investment and Committed No Fraud. Can My Turkish Citizenship Still Be Withdrawn?
A recurring concern among affected investors is that they genuinely purchased their properties, transferred the required funds through their own bank accounts, received registered ownership and never received any refund from the seller or developer.
Such facts may be extremely important to a legal defence.
Banking records showing genuine payment, evidence that the seller received the purchase price, the absence of a circular movement of funds, and the continuation of property ownership may support the position that a real investment took place.
Nevertheless, the existence of a genuine property transaction and compliance with every legal condition for citizenship are not necessarily identical questions.
For example, an investor may have genuinely paid for an apartment while the authorities subsequently allege that its actual value at the relevant acquisition date was below the statutory citizenship threshold.
Three separate matters must therefore be examined:
Whether the property purchase and payment transactions were genuine.
Whether the investment satisfied the legal requirements applicable at the relevant date.
Whether the investor knowingly participated in any false declaration, concealment or fraudulent transaction.
Good faith is legally relevant, but it does not guarantee that every citizenship withdrawal decision can be successfully challenged. Equally, an allegation of misconduct against a developer does not establish personal criminal liability on the part of every purchaser.
Under Turkish criminal law, individual responsibility must be assessed by reference to the elements of the alleged offence and the conduct attributable to the particular person.
Under administrative law, the relevant citizenship decision must be evaluated by reference to its statutory basis, factual grounds and applicable legal safeguards.
10. Can an Old Property Valuation Report Be Re-examined? What If a New Valuation Is Lower?
Retrospective property valuation has become a central issue in the 2026 investigations.
The authorities may examine valuation reports prepared when citizenship was originally acquired and may obtain new expert evidence concerning the property’s value at that earlier date.
However, a property’s market value in 2026 is not necessarily the same as its market value at the time of the investment.
The relevant question is whether the original investment satisfied the applicable requirements at the legally relevant time.
10.1. The USD 250,000 and USD 400,000 Thresholds
The property investment threshold for Turkish citizenship was reduced to USD 250,000 on September 19, 2018. It was subsequently increased to USD 400,000 with effect from June 13, 2022, subject to the applicable transitional provisions.
Consequently, a qualifying property investment made in 2021 should not simply be assessed by applying the later USD 400,000 requirement retrospectively. The relevant dates of the investment, contractual undertaking, application and eligibility documentation must be assessed under the law and transitional provisions applicable to the particular transaction. [L2]
10.2. Does a Valuation of an Entire Project Establish the Value of Every Apartment?
Not necessarily.
An expert report concerning an entire development, parent parcel or construction project does not automatically establish the historical value of every independent residential unit.
Relevant factors may include the unit’s location, block, floor, net and gross area, orientation, legal status, construction stage, view, property characteristics and comparable transactions at the relevant date.
Special attention may be required where apartment numbers used during the construction stage differ from the unit numbers subsequently registered following the establishment of condominium ownership.
Any discrepancy between project documentation and land registry descriptions should be investigated before conclusions are drawn from a general valuation report.
10.3. Could Obtaining a New Expert Report Create Legal Risks?
A new technical report may assist an investor in challenging a disputed valuation. However, its scope, methodology, evidential limitations and potential findings should be considered before commissioning the work.
If an independent report concludes that a property’s historical value was below the threshold applicable at the relevant time, that conclusion may become a significant issue in an administrative dispute under Article 40.
A properly designed legal strategy should therefore begin with an assessment of existing evidence, including the original valuation report, banking records, expert conclusions, development records and comparable historical transactions.
Where justified, an independent expert opinion, judicial preservation of evidence or court-appointed expert examination may be considered.
The purpose of expert evidence must be to establish the property’s actual historical value through a transparent and verifiable methodology, rather than to manufacture a preferred valuation result.
11. What Do the Important 2026 Council of State Decisions Mean for Citizenship Revocation Cases?
Two decisions of the Turkish Council of State (Danıştay), Tenth Chamber, issued in February 2026 provide important guidance concerning the judicial review of administrative decisions withdrawing Turkish citizenship.
The decisions concern different factual circumstances and should not be treated as producing a single automatic outcome for all investment-based citizenship disputes.
11.1. Council of State, Tenth Chamber, February 5, 2026, E.2024/405, K.2026/361
This case concerned a person who acquired Turkish citizenship through investment. The administration subsequently cancelled the investment eligibility certificate after identifying irregularities concerning foreign currency purchase documents.
The Council of State examined the withdrawal of citizenship under Article 40 of Law No. 5901 and found no illegality in the administrative withdrawal decision, having regard to the failure to satisfy the necessary legal requirements. [J1]
The decision is important because the original approval of a citizenship application does not necessarily prevent the administration from subsequently withdrawing the decision where it is legally established that the necessary conditions were absent from the outset.
It also demonstrates the significance of examining the investment eligibility certificate, the underlying financial documents and any available challenge to the cancellation of that certificate.
11.2. Council of State, Tenth Chamber, February 4, 2026, E.2024/3835, K.2026/324
This case concerned a citizenship withdrawal decision based on public-order and national-security considerations.
Having examined the reasons and supporting material relied upon by the administration, the Council of State concluded that the grounds necessary to justify withdrawal had not been sufficiently established and annulled the relevant part of the administrative decision. [J2]
This was not a property valuation dispute. Its significance lies in the requirement that an administrative decision affecting citizenship must have a legally sustainable and sufficiently substantiated basis.
11.3. What Can Be Learned from These Two Judgments?
These decisions should be read together.
The first demonstrates that a withdrawal decision may be upheld where the statutory conditions for citizenship were not satisfied and the relevant facts have been established.
The second demonstrates that the administration’s asserted grounds may be subjected to meaningful judicial scrutiny and that a withdrawal decision may be annulled where the necessary basis is not sufficiently established.
Accordingly, neither the proposition that all citizenship withdrawal decisions are unlawful nor the proposition that all such decisions are immune from judicial challenge is legally sustainable.
The decisive issues are the applicable legal provision, the factual position at the time of acquisition, the evidence relied upon by the authorities, and the legality of the particular administrative decision.
12. What Happens to My Wife, Husband and Children If My Turkish Citizenship Is Cancelled?
Article 32 of Turkish Citizenship Law No. 5901 addresses the consequences of an annulment decision for spouses and children who acquired Turkish citizenship in connection with the principal person’s acquisition.
However, it would be legally inaccurate to assume that every family member must necessarily have exactly the same legal position.
The manner and date of citizenship acquisition, whether citizenship was acquired derivatively or independently, and the relevant provisions of Turkish nationality law must be examined for each individual.
The September 21, 2026 official statement identified 807 family members among the 1,070 persons concerned and separately referred to 55 children who acquired Turkish citizenship after the original citizenship decision. [N4]
This distinction illustrates why family members should not be assessed solely by reference to the principal investor’s file.
Particular care is required in cases involving children who acquired Turkish citizenship by birth, children whose nationality was connected to a parent’s subsequent naturalisation, or family members who may have acquired citizenship on a separate legal basis.
The potential retrospective legal effects of withdrawal and annulment decisions must also be examined in light of the applicable legislation.
13. Does a Seizure Order on My Property Mean My Turkish Citizenship Has Been Revoked?
No. A seizure or freezing measure recorded against a property in TAKBİS or the land registry does not, by itself, establish that the owner’s Turkish citizenship has been annulled or withdrawn.
A criminal-procedure measure concerning property and an administrative decision concerning citizenship are distinct legal acts.
When a seizure measure is identified, the legal assessment should determine which judicial authority ordered it, the offences or facts relied upon, the specific property affected, the statutory basis of the measure, and the applicable objection procedures.
The rights and safeguards provided under the Turkish Code of Criminal Procedure must be considered.
Article 33 of Turkish Citizenship Law No. 5901 also contains special provisions concerning the liquidation of assets in certain cases involving annulled citizenship.
However, the annulment of citizenship should not be treated as automatically transferring ownership of every property to the state or as producing identical asset consequences in every case.
Whether asset liquidation is legally required must be assessed in accordance with the applicable statutory provisions and the relevant administrative decision.
In addition, the legal effect of judicial proceedings against an annulment decision on the liquidation process requires separate examination.
Continued registration of a property in the investor’s name, the existence of a criminal seizure measure, and the investor’s citizenship status are three legally different questions.
14. What Criminal Charges Could Arise from a Turkish Citizenship by Investment Investigation?
The investigations publicly announced in 2025 and 2026 have referred to several categories of alleged criminal conduct.
Depending on the relevant facts, allegations may concern establishing, managing or participating in a criminal organisation, migrant smuggling, document forgery, false statements in the preparation of official documents, or aggravated fraud involving public institutions. [N4][N6]
However, the offences listed in a prosecutor’s public statement do not necessarily apply to every foreign investor whose property transaction is being examined.
Criminal responsibility must be determined individually, having regard to the elements of the alleged offence, the person’s conduct, intent, knowledge, participation and the available evidence.
For example, an allegation that a valuation expert knowingly prepared a false report does not independently establish that the purchaser knew of the falsity or participated in its preparation.
Relevant defence materials may include purchase contracts, bank records, foreign exchange documentation, evidence concerning the source of funds, correspondence with the seller, real estate valuation reports, and documents submitted in the original citizenship application.
Criminal proceedings and citizenship proceedings may influence each other, but they remain legally distinct.
A criminal investigation being discontinued does not automatically eliminate every possible administrative issue concerning the original citizenship conditions.
Conversely, an administrative decision withdrawing citizenship does not establish that the person has committed a criminal offence.
15. I Live Outside Türkiye. What Should I Do Before Travelling to Istanbul?
Many investors who acquired Turkish citizenship through real estate investment have subsequently continued living in other countries.
Some may first learn about an investigation through public news reports, social media, or information concerning the developer from whom they purchased an apartment.
Before travelling to Türkiye, individuals facing a concrete concern may consider obtaining an appropriate legal assessment of their current citizenship status and any known judicial measures affecting them.
Relevant enquiries may concern the existence of an investigation, the person’s procedural status, any summons, arrest or compulsory appearance order, and the current validity of citizenship and identity documents.
Where citizenship has already been annulled or withdrawn, immigration-law considerations may become important, including the person’s other nationality, legal residence position, possible statelessness concerns, and any deportation or administrative detention measures.
Depending on the nature of the required legal acts, it may be possible to authorise a Turkish lawyer through a power of attorney executed before a Turkish diplomatic or consular authority abroad.
However, the applicable identification and documentary requirements should be confirmed with the relevant consular authority.
There is no reliable universal answer to the question of which passport an individual should use when travelling to Türkiye while a citizenship-related dispute is pending.
The person must act consistently with their lawful current status and provide accurate information to the competent authorities.
16. Which Documents Are Necessary to Assess the Risk of Turkish Citizenship Revocation?
A comprehensive assessment should not rely exclusively on a title deed or a single bank receipt.
Investment-based citizenship cases may require a coordinated examination of the administrative acquisition process, financial transactions, real estate records, valuation evidence, and any related criminal proceedings.
Document category
Purpose of the examination
Original citizenship acquisition decision and records
Establish the date, legal basis and family relationships
Title deeds and historical land registry records
Verify ownership, transaction history and the property unit
Property purchase contracts and receipts
Determine the actual contractual price and payment arrangements
Foreign and Turkish bank statements
Trace the source and movement of funds
Foreign currency purchase certificates
Examine compliance with the currency requirements applicable at the time
Original and subsequent valuation reports
Assess the property’s historical value and possible discrepancies
Investment eligibility certificate
Determine the basis and current status of the administrative eligibility assessment
Developer and intermediary correspondence
Identify the investor’s knowledge, instructions and communications
Family members’ citizenship documents
Establish derivative or independent citizenship acquisition
Administrative notifications and institutional correspondence
Identify decisions, notification dates and judicial deadlines
Criminal investigation and judicial documents
Establish the scope of any allegations or protective measures
Articles 2 and 46 of the Turkish Attorneyship Law No. 1136 provide a framework for lawyers’ access to certain files and documents.
Nevertheless, access without a power of attorney, obtaining copies, access to confidential investigation records and disclosure of personal civil registry information may be subject to statutory restrictions and institutional requirements.
These rights should not be interpreted as giving unrestricted access to every confidential document or every individual’s personal records without appropriate legal authority.
17. A Legal Roadmap for Investors Facing Turkish Citizenship Annulment or Withdrawal
An effective legal response requires more than submitting a single petition or waiting for a notification from the authorities.
The administrative, criminal, financial, real estate and, where necessary, immigration-law aspects of the case should be assessed as part of a coherent legal strategy.
Step 1: Establish the Current Citizenship Status
The first stage is to determine the date and legal basis of citizenship acquisition, the status of the investment eligibility certificate, and whether any annulment or withdrawal decision has been issued.
If such a decision exists, its date, legal basis, notification and present procedural status must be established.
Step 2: Identify the Criminal Investigation and Its Scope
Enquiries should determine whether the investor is personally involved in a criminal investigation, whether the person is identified as a suspect, whether an interview has been requested, and whether any judicial protective measure exists.
Any related or separated files should be considered where relevant and lawfully accessible.
Step 3: Reconstruct the Investment Transaction
The original acquisition process should be documented chronologically, beginning with the purchase agreement and continuing through payment, valuation, registration, eligibility assessment and the citizenship decision.
This allows the legal requirements applicable at each stage to be assessed accurately.
Step 4: Verify the Source and Movement of Funds
A financial review should examine where the funds originated, which accounts were used, whether the required payments were made, whether the seller actually received the money, and whether any direct or indirect refund occurred.
Where appropriate, documentary evidence may be sought from banks or other competent institutions through lawful procedures.
Step 5: Examine the Property’s Historical Value
If the case concerns an allegation of insufficient investment or inflated valuation, technical analysis should focus on the relevant historical valuation date.
Comparable transactions, the property’s characteristics, the original expert report and any subsequent findings should be evaluated together.
Step 6: Coordinate Administrative and Criminal Defence
Statements and documents used in criminal proceedings should be considered alongside submissions made to administrative authorities.
The objective is to avoid factual inconsistency while respecting the different legal standards, procedural rights and evidential requirements of each proceeding.
Step 7: Pursue Appropriate Administrative and Judicial Remedies
Where an annulment or withdrawal decision has already been issued, the appropriate court, filing deadline and possible request for suspension of execution must be determined.
If the investment eligibility certificate has been separately cancelled, it may be necessary to assess whether that decision requires an independent challenge.
Any seizure or other criminal-procedure measure should be considered under the relevant procedural rules and objection mechanisms.
Step 8: Continue Reviewing Material Developments
Citizenship and criminal files can evolve over time.
An investigation initially concerning a construction company may subsequently produce evidence concerning specific transactions. An eligibility review may result in a separate administrative decision, and an existing decision may later be notified or challenged.
For this reason, cases involving a concrete ongoing risk should be reassessed when material new information becomes available.
18. How Can a Turkish Citizenship Revocation Decision Be Challenged in Court?
Decisions annulling or withdrawing Turkish citizenship are administrative acts capable of judicial review.
However, the competent court depends on the authority issuing the challenged decision and the legal nature of the specific administrative act.
Certain decisions concerning exceptional acquisition or withdrawal of citizenship made by the President of the Republic may fall within the Council of State’s first-instance jurisdiction.
Other administrative decisions, including certain investment eligibility decisions, may require a separate determination of the competent administrative court.
18.1. Time Limits for Judicial Review
Under the general framework of Administrative Procedure Law No. 2577, where no special period applies, the time limit for bringing an action before the Council of State or an administrative court is generally 60 days.
Nevertheless, the precise time limit must be calculated by reference to the specific act, the lawful notification date, any applicable special rules, and the legal consequences of any administrative application.
The Council of State’s decision dated December 30, 2025, E.2025/6295, K.2025/7133, illustrates the importance of complying with the applicable judicial filing period. The action considered in that case was rejected because it had not been filed within the relevant time limit. [J3]
18.2. Can the Court Suspend the Citizenship Decision?
A claimant may request a suspension of execution where the statutory conditions are satisfied.
However, filing an annulment action does not automatically suspend the implementation of every administrative decision.
Article 27 of Law No. 2577 governs the requirements for suspension of execution, including the relevant tests concerning unlawfulness and the consequences of implementation.
The availability of interim judicial protection must therefore be evaluated on the circumstances of the particular case.
Where a citizenship withdrawal or annulment decision has been notified, establishing the filing deadline and the need for urgent interim relief should be among the first legal priorities.
19. Frequently Asked Questions About Turkish Citizenship Revocation in 2026
1. Has Turkish citizenship been definitively cancelled for all 1,070 people?
No such general conclusion can be drawn from the September 21, 2026 announcement. The authorities reported identifying the individuals concerned and initiating administrative procedures. This does not establish that separate decisions have been issued, notified or finally upheld for every individual.
2. Is it true that 6,134 people have had their Turkish citizenship annulled or withdrawn?
The Ministry of Interior publicly reported that citizenship decisions concerning 5,391 people had been annulled and decisions concerning 743 people had been withdrawn, producing a cumulative total of 6,134 individuals. These figures must be distinguished from the newer 1,070-person investigation.
3. If my property developer is under investigation, will my citizenship automatically be revoked?
No. An investigation into the developer does not automatically establish that the purchaser’s citizenship has been revoked or that the purchaser’s transaction was unlawful. The individual’s investment and administrative records require separate examination.
4. Can my citizenship be withdrawn even though I genuinely paid for the property?
Yes, a legal risk may still arise if the authorities allege that the objective conditions for citizenship were not satisfied. Genuine payment is an important factor, but the applicable investment requirements must also be examined.
5. I acquired Turkish citizenship in 2021 through a USD 250,000 investment. Does the USD 400,000 threshold now apply to me?
Past investments must be evaluated under the law applicable at the legally relevant time, taking account of transitional provisions. The later USD 400,000 threshold should not simply be applied retrospectively to every earlier investment.
6. I did not prepare the valuation report. Can I still face citizenship withdrawal?
The fact that the investor did not prepare or knowingly falsify the report may be important under Article 31. However, an allegation that the original objective citizenship conditions were absent may require a separate assessment under Article 40.
7. Can a new expert report invalidate the original valuation report?
Not automatically. The dates, methods, comparable sales and characteristics of the property must be assessed before determining the evidential weight of each report.
8. Can I enter Türkiye if I am mentioned in a criminal citizenship investigation?
The existence of an investigation is not the same as the existence of an arrest or compulsory appearance order. An informed assessment requires examination of the individual’s current legal status and any relevant judicial measures.
9. Does possession of a Turkish passport prove that I am still a Turkish citizen?
Possession of a physical passport alone is not conclusive proof that no subsequent administrative citizenship decision has been made. Current official records should be examined.
10. If I can access e-Devlet, does that mean my citizenship has not been revoked?
Access to an electronic government account is not, by itself, a definitive legal determination of citizenship status. The relevant administrative records and decisions must be checked.
11. Will my spouse and children lose Turkish citizenship if my citizenship is cancelled?
Linked citizenship acquisitions may be affected under Turkish nationality law. However, the legal basis and date of each family member’s acquisition must be examined individually.
12. If my apartment is subject to a seizure order, will I lose ownership?
A criminal seizure measure and the termination of ownership are different legal matters. The order’s grounds, scope, duration and available objection procedures must be assessed, together with any separately applicable citizenship-related asset provisions.
13. Can I file a lawsuit against a Turkish citizenship revocation decision?
Yes. Citizenship annulment and withdrawal decisions are subject to judicial review. The appropriate court, legal grounds, filing deadline and possible interim remedies must be determined according to the particular administrative act.
14. Does filing a lawsuit automatically restore or preserve my Turkish citizenship?
No automatic result should be assumed. Filing an action does not necessarily suspend the administrative decision. Any suspension of execution or final judgment must be assessed in accordance with Turkish administrative procedure.
15. Can a Turkish lawyer investigate my citizenship status without a power of attorney?
Turkish lawyers have certain statutory rights to examine documents and files, but these rights are subject to legal restrictions. Access to confidential material, personal civil registry records, certified copies or the receipt of notifications may require appropriate authorisation or a power of attorney.
16. I have not received any official notification. Should I simply wait?
Where there is a concrete risk, waiting for notification may not be sufficient. It may be appropriate to establish the current status through lawful enquiries, preserve relevant evidence and monitor applicable legal deadlines.
17. If the criminal investigation is closed, will the citizenship problem also disappear?
Not necessarily. The criminal and administrative processes operate under different legal rules. The outcome of a criminal investigation may be relevant, but it does not automatically dispose of every administrative question concerning citizenship acquisition.
18. What if my property is still registered in my name?
Continued ownership may be relevant to the reality of the investment. However, registration of ownership alone does not establish that every citizenship requirement was originally satisfied or that no administrative decision exists.
19. Can I challenge an inaccurate retrospective property valuation?
The methodology, factual assumptions, property identification, historical comparable sales and other technical aspects of a valuation may be examined and challenged through legally appropriate evidential procedures.
20. What is the most important first step?
The first priority is usually to establish the individual’s actual legal position rather than rely on news reports or unverified information. This includes identifying any existing citizenship decision, relevant criminal proceedings and time-sensitive legal remedies.
20. Conclusion: What Is the Correct Legal Approach to Turkish Citizenship Revocation in 2026?
The Turkish citizenship investigations announced in 2025 and 2026 have raised substantial questions for foreign investors who acquired citizenship through real estate.
Official statements confirm that significant numbers of citizenship acquisition decisions have been annulled or withdrawn. However, they do not justify the assumption that every investor associated with the latest criminal investigations has already lost Turkish citizenship.
Nor is it correct to assume that every genuine investor must necessarily retain citizenship regardless of whether the statutory acquisition conditions were satisfied.
The legality of an administrative decision depends on the applicable statutory ground, the individual facts and the available evidence.
A purchaser who genuinely transferred money, acquired real property and did not participate in fraudulent arrangements may possess important evidence supporting a defence. Yet the historical value of the property, the applicable investment threshold, eligibility documentation and other statutory conditions must also be examined.
The law requires careful distinction between personal criminal wrongdoing, alleged defects in an investment transaction, and administrative deficiencies affecting citizenship acquisition.
An effective legal response begins by establishing the investor’s current citizenship status, identifying any relevant criminal and administrative proceedings, and developing a document-based strategy that addresses the actual legal issues in the individual’s case.
At dolgun.av.tr, research concerning Turkish citizenship law, investment-based naturalisation, administrative annulment and withdrawal decisions, and related judicial developments is reviewed as new reliable information becomes available.
However, the availability of publicly reported or verbally communicated information does not establish unrestricted access to every confidential investigation or the definitive status of every individual citizenship file.
Legal Assessment of Turkish Citizenship and Investment Investigations
Individuals concerned about the possible annulment or withdrawal of Turkish citizenship acquired through real estate investment may seek an individual legal assessment based on their citizenship acquisition documents, land registry records, bank statements, property valuation reports, investment eligibility certificate and any relevant judicial or administrative decisions.
When requesting an initial assessment, it may be useful to provide the year of citizenship acquisition, the name and location of the development project, available title deed information, evidence of payment and information about whether the investor currently resides in Türkiye or abroad.
Legal disclaimer: This article is intended for general legal information and academic discussion. It does not constitute an individual legal opinion or a guarantee of any administrative or judicial outcome. Every case must be examined in light of its specific facts and the applicable law.
21. Legislation, Academic Literature, Council of State Decisions and News Sources
A. Legislation and Official Regulations
[L1] Turkish Citizenship Law No. 5901, Official Gazette, June 12, 2009, No. 27256; particularly Articles 12, 31, 32, 33, 36, 37, 40 and 41. Official legislation (Turkish).
[L2] General Directorate of Land Registry and Cadastre (Tapu ve Kadastro Genel Müdürlüğü), administrative guidance and applicable regulations regarding the transition from the USD 250,000 property investment threshold to the USD 400,000 threshold in 2022. Official institution website.
[L3] Administrative Procedure Law No. 2577 (İdari Yargılama Usulü Kanunu), particularly Articles 7, 8 and 27.
[L4] Attorneyship Law No. 1136 (Avukatlık Kanunu), particularly Articles 2 and 46.
B. Academic Publications
[A1] Güner, Cemil. “Türk Vatandaşlığının Kazanılması ve Kaybı Kararlarının Geri Alınması” [Withdrawal of Decisions Concerning the Acquisition and Loss of Turkish Citizenship]. Milletlerarası Hukuk ve Milletlerarası Özel Hukuk Bülteni, Vol. 37, No. 2, 2017. DergiPark academic article.
[A2] Özgür, Çiçek. “Yatırım Yoluyla Kazanılan Türk Vatandaşlığının İptali ve Geri Alınması” [Annulment and Withdrawal of Turkish Citizenship Acquired Through Investment]. Ankara Üniversitesi Hukuk Fakültesi Dergisi, Vol. 75, No. 1, 2026, pp. 741–779. DOI: 10.33629/auhfd.1710185. DergiPark academic article.
[A3] Erden, Hümeyra Zeynep. “Türk Vatandaşlığına Alınma Kararının İptalinde Süre” [Time Limits in the Annulment of Decisions Granting Turkish Citizenship]. Milletlerarası Hukuk ve Milletlerarası Özel Hukuk Bülteni, Vol. 36, No. 1, 2016. DergiPark academic article.
C. Decisions of the Council of State (Danıştay)
[J1] Council of State (Danıştay), Tenth Chamber, February 5, 2026, E.2024/405, K.2026/361. Withdrawal of investment-based Turkish citizenship following irregularities in foreign currency purchase documents and cancellation of the investment eligibility certificate. Official judgment (Turkish).
[J2] Council of State (Danıştay), Tenth Chamber, February 4, 2026, E.2024/3835, K.2026/324. Judicial review of a withdrawal decision based on national-security and public-order considerations; legal grounds and supporting evidence. Official judgment (Turkish).
[J3] Council of State (Danıştay), Tenth Chamber, December 30, 2025, E.2025/6295, K.2025/7133. Notification and time limits in citizenship-related administrative litigation. Official judgment (Turkish).
D. Official Statements and News Reports
[N1] Candan, Fatma Nur. “Muvazaalı gayrimenkul satışıyla vatandaşlık sağlayan suç örgütü çökertildi.” Anadolu Ajansı, September 24, 2025. Original report (Turkish).
[N2] Anadolu Ajansı. “Yabancılara usulsüz vatandaşlık kazandıran suç örgütüne yönelik operasyonda yakalanan 113 şüpheli adliyede.” September 2025. Original report (Turkish).
[N3] Republic of Türkiye, Ministry of Justice. “Bakan Gürlek: 687 Kişinin Vatandaşlığının İptali İçin Yasal Süreç Başlatıldı.” Official statement, August 4, 2026. Official statement (Turkish).
[N4] Yeşildal, Zeynep; Gökmen, Emrah; Yıldız, Dilhan Türker; Eser, Zehra Tekeci. “İstanbul merkezli usulsüz vatandaşlık operasyonunda 73 zanlı yakalandı.” Anadolu Ajansı, September 21, 2026. The report includes statements from the Istanbul Chief Public Prosecutor’s Office, the Ministry of Justice and the Ministry of Interior. Original report (Turkish).
[N5] Demir, İrem. “Haksız yollarla Türk vatandaşlığı kazandırdığı belirlenen suç örgütü operasyonunda 32 zanlı tutuklandı.” Anadolu Ajansı, August 7, 2026. Original report (Turkish).
[N6] Yeşildal, Zeynep; Gökmen, Emrah. “İstanbul merkezli usulsüz vatandaşlık operasyonunda yakalanan 33 şüpheli tutuklandı.” Anadolu Ajansı, September 25, 2026. Original report (Turkish).
[N7] TRT Haber / Anadolu Ajansı. “İçişleri Bakanlığı’ndan İstanbul’daki usulsüz vatandaşlık operasyonuna ilişkin açıklama.” September 21, 2026. Original report (Turkish).
[N8] Gürel, Ayşe. “İstanbul merkezli 13 ilde sahte belgelerle vatandaşlık operasyonu: 73 gözaltı.” Demirören Haber Ajansı, September 21, 2026. Original report (Turkish).
[N9] Habertürk Yerel Haberler / Anadolu Ajansı. “İçişleri Bakanlığından İstanbul’daki usulsüz vatandaşlık operasyonuna ilişkin açıklama.” September 21, 2026. Original report (Turkish).
[N10] Haber Global / Anadolu Ajansı. “İçişleri Bakanlığı duyurdu: Binlerce yabancının vatandaşlığı iptal.” September 21, 2026. Original report (Turkish).
Source methodology: Certain news outlets reproduced or summarised the same official statements originally reported by Anadolu Ajansı. Such publications are listed as reporting sources, not as separate independent confirmations of the underlying criminal allegations. Anonymous practice-based observations and unconfirmed verbal information are expressly distinguished from official records, judicial decisions and verified public announcements.
22. Previously Published Research on Turkish Citizenship Law – Dolgun Akademi
September 26, 2026:The 1,070-Person Turkish Citizenship Investigation in 2026. Analysis of the September investigation, 263 principal investors, 807 family members and allegedly sham property transactions. Original article in Turkish.
In recent months, the questions most frequently raised by foreign nationals who acquired Turkish citizenship through real estate investment have changed significantly.
Investors are no longer asking only:
“Can my Turkish citizenship be revoked?”
They are now asking:
“Has my Turkish citizenship already been cancelled?”
“Am I involved in a criminal investigation?”
“Could I be detained if I enter Türkiye?”
“My e-devlet account still works. Does that mean I am still a Turkish citizen?”
“I did not prepare the valuation report. Can I still face consequences?”
“Can a Turkish lawyer investigate my case before I issue a power of attorney?”
“I live abroad and have received no notice at all. How can I find out what has happened to my citizenship?”
These questions have become particularly important because of the criminal investigations and administrative reviews concerning citizenship-by-investment files that began attracting significant public attention in 2025 and expanded considerably during 2026.
We previously examined the legal framework in detail in our article dated 19 September 2026, titled:
“Revocation and Withdrawal of Turkish Citizenship Acquired Through Investment: False Valuation Reports, Sham Transactions, Good-Faith Investors and Judicial Protection.”
In that article, we addressed in particular the distinction between revocation under Article 31 of Turkish Citizenship Law No. 5901 and withdrawal under Article 40, as well as property valuation reports, good faith of the investor, genuine financial transfers and relevant Council of State case law.
Following the second major investigation announced on 21 September 2026, we also published a separate article on 26 September 2026 titled:
“The 2026 Turkish Citizenship Cancellation Process Affecting 1,070 Persons.”
That article examined the investigation concerning 263 principal investors and 807 family members in greater detail.
This article complements those two studies and provides an updated guide to the questions that should be asked immediately by any person whose Turkish citizenship has been revoked, whose investment is under investigation, or who suspects that his or her citizenship may be at risk.
WHAT CHANGED IN 2026 AND WHY ARE SO MANY CITIZENSHIP FILES BEING REVIEWED?
Large-scale reviews of Turkish citizenship acquired through investment began receiving significant public attention in 2025.
In an investigation announced on 24 September 2025, transactions involving 451 foreign investors and citizenship acquisitions covering 1,198 persons together with their family members were examined.
Authorities alleged, among other matters, that the required foreign currency had not actually entered Türkiye, fictitious financial transactions had been created, certain real estate sales were sham transactions and some properties had been shown at values exceeding their actual market value.
Publicly announced allegations in that investigation included offences such as establishing an organisation for the purpose of committing crimes, migrant smuggling, laundering of assets derived from crime, aggravated fraud and forgery of private documents.
A further investigation was announced on 4 August 2026 under the coordination of the Organised Crime Investigation Bureau of the Istanbul Chief Public Prosecutor’s Office.
The Ministry of Justice stated that legal proceedings had been initiated concerning the citizenship status of 687 persons in connection with allegations that low-value properties had been shown at substantially higher values through false valuation reports and that Turkish citizenship had been obtained through sham real estate transactions.
Authorities also alleged that approximately TRY 2.5 billion that should have entered Türkiye in connection with these investment transactions had not in fact entered the country.
A second major operation was announced on 21 September 2026.
Authorities stated that real estate sales to 734 foreign nationals had been examined, that 274 sales were considered to be sham transactions, and that 1,070 persons had acquired citizenship when family members were included.
Of these individuals, 263 were principal investors and 807 were family members.
It was also reported that 1,015 persons acquired citizenship at the time of the principal citizenship decisions, while 55 children acquired Turkish citizenship subsequently.
According to the investigating authorities, transactions amounting to USD 72.25 million were considered to involve sham arrangements.
By 25 September 2026, 33 suspects detained in connection with this second investigation had been remanded in custody, while 20 persons were reportedly subjected to judicial control measures requiring them to remain at their residences.
During the same period, the Ministry of Interior announced considerably broader figures.
According to the Ministry, investment eligibility certificates of 1,150 investors had been cancelled in connection with false or irregular valuation reports, and the citizenship decisions concerning those investors and their family members, totalling 5,391 persons, had been cancelled.
In addition, citizenship decisions concerning 263 investors and their family members, totalling 743 persons, were reportedly withdrawn following assessments relating to public order and national security.
The total number announced was therefore 6,134 persons.
It is essential to understand that these figures do not necessarily relate to one investigation, one legal ground, one developer or one group of investors.
Each investor’s individual file must be examined separately.
1. CAN TURKISH CITIZENSHIP BE REVOKED AFTER IT HAS BEEN GRANTED?
Yes.
The fact that Turkish citizenship has already been acquired does not mean that the citizenship decision can never subsequently be reviewed.
Article 31 of Turkish Citizenship Law No. 5901 provides for revocation where citizenship was acquired as a result of a false declaration by the person concerned or the concealment of important matters affecting the acquisition of citizenship.
Article 40 regulates withdrawal of a citizenship decision where it is subsequently established that the legal requirements for acquisition were not actually satisfied or that the decision was issued repetitively.
Revocation and withdrawal are not the same legal mechanism.
One of the first matters that must therefore be determined in a citizenship case is the precise legal basis relied upon by the administration.
2. WHAT IS THE DIFFERENCE BETWEEN REVOCATION OF CITIZENSHIP AND WITHDRAWAL OF THE CITIZENSHIP DECISION?
This distinction is central to the case.
Under Article 31, the principal question is:
Was Turkish citizenship acquired because of the investor’s own false declaration or concealment of an important fact?
Under Article 40, a different question arises:
Were the objective legal conditions for the acquisition of citizenship actually satisfied at the time the citizenship decision was issued?
Accordingly, the absence of fraudulent conduct by the investor does not necessarily resolve every issue that may arise under Article 40.
Conversely, the fact that the objective investment criteria appear to have been satisfied does not necessarily eliminate an Article 31 issue where the investor knowingly relied upon false documentation or misleading declarations.
We discussed this distinction in greater detail in our previous article dated 19 September 2026.
3. HAVE THE CITIZENSHIPS OF ALL 1,070 PERSONS ALREADY BEEN CANCELLED?
The publicly available information should not be interpreted in that manner.
The announcement made on 21 September 2026 stated that 1,070 persons had been identified within the scope of the investigation and that the necessary administrative process concerning their citizenship status had been initiated.
Several stages must therefore be distinguished.
Identification of a person or transaction in a criminal investigation is one stage.
Cancellation of the investment eligibility certificate is another administrative measure.
Revocation or withdrawal of the citizenship decision is a separate administrative act.
Notification of that act to the person concerned is another stage.
Judicial proceedings challenging the administrative measure constitute a further stage.
Therefore, merely learning that an investor may be included among the group of 1,070 persons is not sufficient to determine his or her current legal status.
4. WHAT DOES THE ANNOUNCEMENT CONCERNING 6,134 PERSONS MEAN?
The Ministry of Interior announced that citizenship acquisition decisions concerning a total of 6,134 persons, including investors and their family members, had been cancelled or withdrawn.
Different legal grounds were involved within that overall figure.
According to the publicly announced information, 5,391 persons were affected by cancellation measures associated with investment eligibility certificates and irregularities in the investment process.
A further 743 persons were affected by withdrawal decisions connected with assessments relating to public order and national security.
The figure of 6,134 therefore does not represent one criminal investigation or the customers of one developer.
5. DOES THE EXISTENCE OF A CRIMINAL INVESTIGATION MEAN THAT MY CITIZENSHIP HAS ALREADY BEEN REVOKED?
No.
A criminal investigation and an administrative decision concerning Turkish citizenship are legally separate processes.
However, given the structure of the investigations conducted in 2025 and 2026, learning that an investor or the transaction through which citizenship was obtained is being investigated may be a significant indication that the citizenship file is also being reviewed.
For example, where investigating authorities allege that a particular sale was fictitious, that the investment amount was never genuinely paid, or that the valuation report was inaccurate, those same facts may also become relevant to an administrative citizenship review.
Nevertheless, the existence of a criminal investigation and the existence of an individual administrative decision terminating citizenship must not be treated as the same thing.
Both files should be checked separately.
6. I LIVE ABROAD AND KNOW NOTHING ABOUT THE CASE. COULD THE EXISTENCE OF AN INVESTIGATION INDICATE THAT MY CITIZENSHIP MAY ALREADY HAVE BEEN CANCELLED?
Yes. In the current environment, that possibility should be taken seriously.
A person who has lived abroad for several years, no longer communicates with the former developer or real estate company in Türkiye, and does not actively monitor his or her Turkish address records may remain unaware of administrative and criminal proceedings for a considerable period.
This is particularly relevant where the property, developer, intermediary company or valuation report used in the citizenship application is connected with one of the investigations currently being conducted.
The existence of such a criminal investigation may indicate that an administrative review, revocation procedure or withdrawal procedure has also been initiated in relation to the citizenship file.
However, a possible risk must be distinguished from an actual citizenship decision already issued against the individual.
For a person living abroad, it may therefore be necessary to examine separately:
whether a criminal investigation exists;
the person’s procedural status in that investigation;
the current status of the citizenship file;
the status of the investment eligibility certificate;
whether an individual revocation or withdrawal decision has been issued;
whether such a decision has been served;
and whether there is any arrest warrant, summons, judicial control measure or other restriction relevant to entry into Türkiye.
These checks may be particularly important before booking travel to Türkiye.
7. COULD I BE DETAINED AT THE AIRPORT IF I RETURN TO TÜRKİYE?
The answer cannot be determined from citizenship status alone.
If a criminal investigation exists, it is also necessary to determine whether there is an arrest warrant, detention order, instruction to obtain a statement, judicial control measure, travel restriction or another criminal procedural measure.
If Turkish citizenship has already ceased, the conditions applicable to the individual’s entry into Türkiye as a foreign national may also need to be examined.
Accordingly, at least three separate matters should be reviewed before travel:
the person’s citizenship status;
the criminal investigation and any procedural measures;
and the conditions applicable to entry into Türkiye as a foreign national.
A person living abroad should not rely solely on the fact that a Turkish passport remains physically in his or her possession.
8. WHY CAN A CITIZENSHIP FILE LEAD TO A CRIMINAL INVESTIGATION?
Because the allegations raised in the current investigations are not limited to whether the administrative requirements for citizenship were satisfied.
Investigating authorities have alleged in various files that fictitious financial movements were created, real estate transactions were structured as sham transactions, property values were misrepresented and false or misleading documents were used.
Where authorities allege that a person knowingly participated in such conduct, a criminal investigation may arise independently of the citizenship proceedings.
9. WHICH CRIMINAL OFFENCES MAY BE INVESTIGATED IN CONNECTION WITH CITIZENSHIP-BY-INVESTMENT CASES?
Different criminal allegations have appeared in publicly announced investigations conducted during 2025 and 2026.
Depending on the facts of the individual file, the offences under investigation may include:
establishing, managing or participating in a criminal organisation;
migrant smuggling;
fraud or aggravated fraud, including allegations involving public authorities;
forgery of official documents;
forgery of private documents;
false declaration in the preparation of an official document;
and laundering of assets derived from criminal activity.
The fact that such offences appear in a criminal investigation does not mean that every foreign investor is suspected of all or any of these offences.
Criminal responsibility is personal.
A person who merely purchased a property from a particular developer is not in the same legal position as a person alleged to have knowingly participated in the preparation of false valuation reports or fictitious financial transfers.
The precise conduct attributed to the individual investor must therefore be identified.
10. IF THE DEVELOPER IS UNDER CRIMINAL INVESTIGATION, AM I ALSO A SUSPECT?
That conclusion cannot be drawn merely from the commercial relationship.
A company may have sold properties to hundreds of foreign nationals.
Certain transactions may be alleged to have been irregular while other investors may have genuinely paid the full investment amount.
Indeed, in the second investigation announced on 21 September 2026, authorities stated that 734 foreign purchasers had been examined but referred to 274 sales as allegedly involving sham transactions.
This itself demonstrates that each transaction must be assessed individually.
11. I DID NOT PREPARE THE VALUATION REPORT. CAN MY CITIZENSHIP STILL BE AFFECTED?
The distinction between Articles 31 and 40 is again important.
For Article 31 purposes, the investor’s own false declaration or concealment of important information is highly relevant.
If a valuation report was prepared by an authorised valuation professional and the investor had no knowledge that the report was inaccurate, this may be significant when assessing the investor’s personal conduct.
However, under Article 40, the administration may argue that the objective investment criteria were never actually satisfied when citizenship was granted.
Accordingly, “I did not prepare the valuation report” may be an important part of the defence, but it should not be treated as the entire defence.
The actual historical value of the property must also be examined.
12. CAN THE ACTUAL VALUE OF THE PROPERTY HELP PROTECT MY CITIZENSHIP?
Depending on the facts, it may be extremely important.
Assume, for example, that the applicable citizenship threshold at the time of investment was USD 250,000.
An old valuation report may have stated that the property was worth USD 400,000, but authorities may now allege that the report was inaccurate.
The relevant economic question is then:
What was the real market value of the property on the relevant historical date?
Was it USD 150,000?
USD 280,000?
USD 400,000?
If the genuine historical value exceeded the legal investment threshold applicable at the time, that fact may be important to the legal defence.
For this reason, an independent retrospective valuation may be appropriate in certain cases.
13. DOES TODAY’S USD 400,000 INVESTMENT REQUIREMENT APPLY TO MY OLD CITIZENSHIP APPLICATION?
An old investment file must be examined under the legislation applicable at the time of the investment.
The required investment amount has changed over the years.
A person who acquired citizenship during a period in which the applicable threshold was USD 250,000 should not have the historical investment tested against the present USD 400,000 threshold.
The investment date, title deed date, eligibility certificate date, citizenship application date and citizenship decision date must all be identified.
14. I REALLY SENT THE MONEY THROUGH THE BANK. DOES THIS PROTECT ME?
A genuine bank transfer may be one of the most important pieces of evidence in the investor’s file.
However, one payment receipt may not be sufficient.
The current investigations frequently focus on the economic reality of the entire money flow.
It may therefore be necessary to examine:
the source of the funds;
the transfer from the investor’s account;
the entry of the funds into Türkiye;
payment to the seller;
the date and currency of the transfer;
and whether any part of the funds was subsequently returned directly or indirectly to the investor or a related person.
The legal position of an investor who genuinely paid the investment amount is materially different from that of a person alleged to have knowingly participated in a merely apparent transfer.
15. WHAT IF PART OF THE PURCHASE PRICE WAS LATER RETURNED TO ME?
This may constitute one of the most sensitive issues in the case.
If authorities allege that the required investment amount was transferred only for appearance and that a significant part of the money was subsequently returned pursuant to a prior arrangement, the genuine economic nature of the investment may be questioned.
However, not every repayment has the same legal significance.
The date, amount, purpose, contractual basis and parties involved in any repayment must be examined carefully.
Investors should therefore retain complete bank statements and supporting documentation.
16. I ACTED IN GOOD FAITH. IS THAT ENOUGH?
Good faith may be highly significant, particularly under Article 31.
An investor may have genuinely paid the full investment amount, received no concealed refund, completed the official title deed transaction, relied on a valuation report prepared within the authorised system, obtained an investment eligibility certificate and submitted no false document or false declaration.
That investor is not in the same legal position as a person alleged to have knowingly participated in an artificial citizenship scheme.
Nevertheless, where authorities argue that the objective statutory requirements were never satisfied, Article 40 must also be considered.
17. DOES THE FACT THAT I RECEIVED AN INVESTMENT ELIGIBILITY CERTIFICATE PROTECT ME?
The investment eligibility certificate is an important administrative document.
A foreign investor does not obtain citizenship simply on the basis of his or her own statement.
The investment is examined through official administrative procedures and an eligibility certificate is issued if the competent authority concludes that the statutory investment conditions have been satisfied.
The fact that the investor relied upon an official state-supervised process may therefore be relevant to legal certainty, administrative stability and good faith.
However, the previous issuance of an eligibility certificate does not prevent later administrative review.
It is therefore important to determine whether the eligibility certificate has subsequently been cancelled.
18. IF MY INVESTMENT ELIGIBILITY CERTIFICATE WAS CANCELLED, DOES THAT MEAN MY CITIZENSHIP HAS ALSO BEEN CANCELLED?
The cancellation of an investment eligibility certificate and the revocation or withdrawal of a citizenship decision are legally separate administrative acts.
They may be closely connected, but they are not identical.
The precise sequence of the administrative measures must therefore be established.
19. MY E-GOVERNMENT ACCOUNT STILL WORKS. DOES THAT PROVE THAT I AM STILL A TURKISH CITIZEN?
Not by itself.
Different government databases may not necessarily be updated at precisely the same time.
Access to an e-Government account should therefore not be treated as the sole method of determining current citizenship status.
A person who becomes aware that his or her investment project or developer is involved in a current investigation should consider having the official citizenship status checked separately.
20. I STILL PHYSICALLY HAVE MY TURKISH PASSPORT. DOES THAT MEAN I AM STILL A TURKISH CITIZEN?
The physical possession of a Turkish passport is not, by itself, conclusive evidence of current citizenship status.
This is especially important for investors living abroad.
Before travelling, it may be appropriate to verify both current citizenship status and the status of the passport.
21. WHAT HAPPENS TO MY SPOUSE AND CHILDREN IF MY CITIZENSHIP IS REVOKED?
Article 32 of Turkish Citizenship Law provides that a revocation decision may also affect a spouse and children who acquired Turkish citizenship in connection with the person concerned.
However, the legal basis and date on which each family member acquired citizenship should be examined separately.
The investigation announced on 21 September 2026 involved 263 principal investors and 807 family members.
It was also reported that 55 children acquired citizenship after the original citizenship decisions had already been issued.
The legal position of children born or registered subsequently may therefore require separate analysis.
22. IF MY CITIZENSHIP IS REVOKED, WILL I LOSE MY PROPERTY IN TÜRKİYE?
Loss of citizenship and loss of ownership of real estate are not the same legal event.
Article 33 of Turkish Citizenship Law contains special provisions concerning the liquidation of property belonging to persons whose citizenship has been revoked.
Where liquidation of assets is considered necessary, this is required to be stated in the relevant decision.
The law also provides that where the person challenges the revocation decision before the courts, liquidation of the assets is postponed until the conclusion of the proceedings.
Accordingly, no reliable conclusion concerning the property should be reached without examining the full wording of the administrative decision.
23. CAN I FILE A LAWSUIT AGAINST THE REVOCATION OR WITHDRAWAL OF MY TURKISH CITIZENSHIP?
Yes.
A decision revoking citizenship or withdrawing the citizenship acquisition decision is an administrative act and is subject to judicial review.
The competent court depends on the authority that issued the challenged decision.
Certain citizenship decisions issued by the President may fall within the jurisdiction of the Council of State acting as the court of first instance.
It should also be remembered that cancellation of an investment eligibility certificate and termination of citizenship may constitute separate administrative measures.
In some cases, more than one administrative act therefore needs to be examined.
24. HOW LONG DO I HAVE TO FILE A CITIZENSHIP CANCELLATION CASE?
Where no special period is prescribed, the general time limit for administrative proceedings before administrative courts and the Council of State is ordinarily 60 days.
The period generally begins on the day following written notification.
However, the method of service, the authority issuing the decision, any prior administrative application and the specific administrative act being challenged may affect the calculation.
A person who has received a citizenship decision should therefore not calculate the litigation deadline on assumptions.
25. CAN I REQUEST A STAY OF EXECUTION IN A CITIZENSHIP CASE?
Yes, where the statutory requirements are satisfied.
Loss of citizenship may affect the person’s passport, ability to enter Türkiye, family life, companies, bank relationships, real estate and other legal interests.
For that reason, an application for a stay of execution should identify the concrete consequences that the administrative act creates for the individual concerned.
Filing a lawsuit does not by itself suspend the implementation of the administrative decision.
26. CAN A LAWYER CHECK WHETHER THERE IS A CRIMINAL INVESTIGATION AGAINST ME?
Yes, although the criminal investigation and the citizenship file must be examined through different channels.
In relation to the criminal file, it may first be necessary to determine:
the competent Chief Public Prosecutor’s Office;
the investigation number;
the person’s procedural status;
the offences under investigation;
and whether any criminal procedural measure exists.
The citizenship file should separately be examined through the Directorate General of Population and Citizenship Affairs and other relevant administrative records.
Information found in one file does not necessarily establish the status of the other.
27. CAN A LAWYER INSPECT A CRIMINAL INVESTIGATION FILE WITHOUT A POWER OF ATTORNEY?
This question is particularly important for persons living abroad who have not yet issued a Turkish power of attorney.
Article 2 of the Attorneys’ Act No. 1136 provides that judicial authorities, law-enforcement authorities and other public institutions are, subject to specific statutory restrictions, required to make available to lawyers the information and documents needed for the performance of their professional duties.
Obtaining copies of documents may require presentation of a power of attorney.
Article 46 of the Attorneys’ Act also provides that a lawyer or trainee lawyer may inspect court and enforcement files without submitting a power of attorney, while copies of documents are not provided to a lawyer who has not produced the relevant authority.
In the context of criminal investigations, the Union of Turkish Bar Associations published Notice No. 2019/32 dated 10 April 2019 referring to a judicial decision confirming that a lawyer may inspect an investigation file without a power of attorney, formal appointment document or written or oral consent from a party to the investigation.
An earlier Notice No. 2019/23 also addressed procedures applicable where a lawyer does not yet have a power of attorney or UYAP registration and seeks to inspect an investigation file after identifying the party concerned and presenting professional identification.
Accordingly, the fact that a person living abroad has not yet issued a power of attorney does not necessarily mean that no preliminary investigation of the criminal file can be undertaken.
However, full and continuing access to the file, obtaining copies, making applications on behalf of the person, accessing the file continuously through UYAP and performing comprehensive defence work may require the establishment of a formal attorney-client representation.
28. IF THERE IS A RESTRICTION ORDER IN THE CRIMINAL FILE, DOES THAT MEAN THE LAWYER CANNOT SEE ANYTHING?
No.
Under Article 153 of the Turkish Code of Criminal Procedure, where access to the investigation file would jeopardise the purpose of the investigation, a judge may restrict file inspection upon the request of the public prosecutor in cases permitted by law.
However, even where such a restriction exists, certain materials remain outside the restriction, including the statement of the arrested person or suspect, expert reports and records of judicial acts at which the suspect is entitled to be present.
This distinction may be particularly important in citizenship-related investigations because expert reports may contain key findings concerning property valuations and financial transactions.
29. CAN A LAWYER INSPECT MY CITIZENSHIP FILE WITHOUT A POWER OF ATTORNEY?
The criminal investigation and the administrative citizenship file must again be distinguished.
Article 2 of the Attorneys’ Act provides a general basis for lawyers to request access to information and documents needed for professional duties, subject to special statutory restrictions.
Obtaining copies generally requires presentation of authority.
Citizenship files, however, may contain personal data, security assessments and information specific to the individual.
For this reason, special legislation and the practice of the relevant administrative authority must also be considered.
In practice, certain information may potentially be reviewed or preliminary enquiries may be made without a power of attorney.
However, obtaining complete copies of the individual’s citizenship file, making formal applications on behalf of the person, requesting official records or performing transactions concerning population registers may require a valid power of attorney.
Accordingly, a power of attorney becomes particularly important where an official confirmation of citizenship status or formal action before the Population and Citizenship authorities is required.
30. I AM ABROAD. WHAT CAN A LAWYER CHECK BEFORE I ISSUE A POWER OF ATTORNEY?
The answer depends on the type of case.
In relation to a criminal investigation, it may be possible to identify the relevant investigation and inspect accessible portions of the file within the limits of Turkish law.
Under Article 2 of the Attorneys’ Act, access to information and documents held by public institutions may also be requested where legally permissible.
Existing court or enforcement files may be physically inspected without a power of attorney.
Publicly available information concerning investigations, companies and projects may be examined.
It may also be possible to determine whether the person’s transaction appears to be connected with a publicly announced investigation.
However, making formal applications on behalf of the client, obtaining official copies, filing an administrative case, conducting formal transactions before population authorities or undertaking comprehensive defence work in a criminal investigation may require a power of attorney.
For a client living abroad, the work may therefore proceed in two stages:
first, preliminary identification of the investigation and the immediate legal risks;
second, full representation under a power of attorney where required.
31. CAN A STATEMENT TO THE PROSECUTOR OR POLICE BE ARRANGED BEFORE I TRAVEL TO TÜRKİYE?
Depending on the stage of the investigation, contact may be established with the public prosecutor or the law-enforcement unit conducting the investigation in order to clarify or plan the taking of a statement.
However, the position is different where an arrest warrant or another coercive measure has already been issued.
The current procedural status should therefore be checked before travel arrangements are finalised.
32. CAN I FIND OUT IN ADVANCE WHETHER THERE IS AN ARREST WARRANT AGAINST ME?
Depending on the accessible portions of the investigation file and the nature of the proceedings, relevant information may be investigated.
However, the confidentiality of criminal investigations, access restrictions and the nature of law-enforcement measures may mean that not every piece of information is available at every stage.
For this reason, reliance solely on an e-Government screen may be insufficient.
The criminal investigation should be examined separately by a lawyer.
33. WHAT IF MY CITIZENSHIP WAS CANCELLED BUT I NEVER RECEIVED ANY NOTIFICATION?
The first issue is to determine whether an individual decision actually exists.
If a decision has been issued, the following questions become important:
when was it issued;
to which address was it sent;
how was service attempted;
what procedure was followed for a person living abroad;
and when did the person actually become aware of the decision?
These issues may directly affect the calculation of the litigation period.
In such cases, the service documents may be as important as the citizenship decision itself.
34. WHAT SHOULD I DO IF THE AUTHORITIES SAY MY CITIZENSHIP HAS BEEN CANCELLED BUT E-GOVERNMENT STILL SHOWS ME AS A TURKISH CITIZEN?
Where there is a conflict between different sources of information, the formal administrative decision and official population records should be examined together.
A person should not rely solely upon a digital screenshot before undertaking important legal actions such as international travel, passport renewal, title deed transactions or entry into Türkiye.
35. I GAVE UP MY PREVIOUS NATIONALITY. COULD I BECOME STATELESS IF TURKISH CITIZENSHIP IS REVOKED?
This question must be examined not only under Turkish citizenship law but also under the nationality law of the person’s former country.
Some investors relinquished their previous citizenship after acquiring Turkish citizenship, while others may have lost their former citizenship under the law of their country of origin.
If Turkish citizenship is subsequently terminated, it is necessary to determine whether the person currently possesses another nationality.
The possibility of statelessness may make the case more complex from the perspective of both immigration law and international law.
36. IF MY TURKISH CITIZENSHIP IS TERMINATED, CAN I REMAIN IN TÜRKİYE?
If citizenship ceases, the legal basis for the person’s continued presence in Türkiye must be examined separately.
Relevant factors may include the person’s previous nationality, passport status, residence rights, family connections, employment, property ownership and other legal ties with Türkiye.
The citizenship proceedings and immigration-law consequences should therefore be assessed together.
37. CAN I SUE THE DEVELOPER OR INTERMEDIARY IF MY CITIZENSHIP IS CANCELLED?
Depending on the circumstances, yes.
If the seller, developer or intermediary expressly represented that the property qualified for Turkish citizenship, the investor relied upon that representation, and it later emerges that the property or supporting documents did not satisfy the relevant requirements, contractual and compensation claims may arise.
A citizenship cancellation case and a private-law claim against the developer, seller, intermediary or other responsible party are separate proceedings.
38. WHAT ARE THE MOST IMPORTANT DOCUMENTS IN A CITIZENSHIP REVOCATION CASE?
A citizenship case should not be analysed solely by looking at the citizenship decision.
The initial review may require, among other documents:
citizenship acquisition documents and subsequent administrative decisions;
Turkish identity and passport records;
title deeds;
real estate sale agreements;
property valuation reports;
the investment eligibility certificate;
bank payment receipts;
SWIFT records and account statements;
foreign currency purchase or transfer documents;
communications with the seller, developer or intermediaries;
invoices and payment receipts;
citizenship application documents;
citizenship records of the spouse and children;
and any document received from the police, public prosecutor or court.
In many cases, a complete legal assessment cannot be made by examining only the title deed or only the valuation report.
39. MY CITIZENSHIP HAS NOT BEEN CANCELLED, BUT MY PROJECT IS UNDER INVESTIGATION. WHAT SHOULD I DO NOW?
Evidence should be preserved before any decision is issued.
Old bank statements, SWIFT records, valuation reports, sale agreements, eligibility certificates and communications with the developer may become more difficult to obtain as time passes.
A person who believes that a genuine investment was made should therefore consider creating a complete personal citizenship file in advance.
Where appropriate, the historical market value of the property may also be examined before any litigation begins.
40. I SAW MY NAME ON A SOCIAL-MEDIA LIST. DOES THAT MEAN MY CITIZENSHIP HAS BEEN CANCELLED?
A social-media list does not, by itself, establish the person’s legal status.
There is no publicly released official list containing the names of all 1,070 persons referred to in the investigation announced on 21 September 2026.
A person should therefore not rely upon an unofficial internet list.
The individual citizenship file and any criminal investigation should be checked through official channels.
41. CAN I WIN A TURKISH CITIZENSHIP REVOCATION CASE?
A reliable legal assessment cannot be made without reviewing the individual file.
However, there can be substantial differences between cases.
An investor who genuinely paid the full investment amount from his or her own funds, received no concealed refund, acquired the property through a real transaction, purchased a property whose actual value met the investment threshold applicable at the time, relied on the official valuation system, obtained an eligibility certificate, submitted no false documents and made no false declarations is not in the same legal position as a person alleged to have knowingly participated in a sham arrangement.
The purpose of the legal defence should therefore not be limited to making a general statement of “good faith.”
The investor’s own transaction, own money flow, own property and own conduct should be documented and analysed individually.
42. HOW DO WE REVIEW A TURKISH CITIZENSHIP REVOCATION CASE?
A proper citizenship review requires more than examining a single administrative decision.
First, the date and legal basis on which citizenship was acquired must be established.
The legislation applicable at the time of investment must then be identified.
The title deed, sale agreement, valuation report, eligibility certificate and citizenship application documents should be examined.
The genuine money flow from the investor’s source account to the seller should be reconstructed.
It should be determined whether any part of the money returned directly or indirectly to the investor after the sale.
Where necessary, the actual historical value of the property should be reassessed.
If the developer, seller, valuation company or intermediary is involved in a criminal investigation, the investor’s individual position in that investigation should be determined.
If the investor personally appears in a criminal investigation, the alleged offence and the evidence relating specifically to that investor should be examined.
The status of the investment eligibility certificate and citizenship decision should then be established.
Where a revocation or withdrawal decision exists, its legal basis, date, service and litigation deadline should be checked.
For clients living abroad, possible risks relating to entry into Türkiye, criminal procedure and immigration law should also be assessed.
Until this analysis has been completed, it is difficult to provide a reliable legal opinion on the appropriate litigation strategy or the legal position of the individual investor.
CRIMINAL INVESTIGATION AND CITIZENSHIP PROCEEDINGS MAY NEED TO BE REVIEWED TOGETHER
The files emerging in 2026 should no longer be viewed solely as conventional citizenship-law disputes.
Current investigations may involve expert reports, MASAK financial analyses, banking records, title deed records, valuation reports and corporate relationships.
For some investors, two separate questions therefore need to be answered:
First:
Does the person’s Turkish citizenship legally continue, and what administrative action has been taken in the citizenship file?
Second:
In the criminal investigation, is the person merely an investor whose transaction is being reviewed, a witness or person with information, an alleged victim, or a suspect?
These are separate questions and neither can replace the other.
SPECIAL WARNING FOR INVESTORS LIVING OUTSIDE TÜRKİYE
The position may be particularly sensitive for investors who live abroad and have not travelled to Türkiye for several years.
The individual may never have seen a notification.
The Turkish telephone number previously used may no longer be active.
The registered address may be outdated.
The person may not have communicated with the developer or intermediary company for years.
The person may have no knowledge of a criminal investigation.
The person may not know that the citizenship file has been reopened for administrative review.
In such circumstances, it may be appropriate to examine both the citizenship status and the criminal investigation before travelling to Türkiye.
This is particularly important for persons who purchased real estate from projects, companies or intermediaries now appearing in current investigations.
TD LAW FIRM – TURKISH CITIZENSHIP REVOCATION AND CRIMINAL INVESTIGATION FILE REVIEW
TD Law Firm advises on matters involving revocation and withdrawal of Turkish citizenship acquired through investment, cancellation of investment eligibility certificates, allegations concerning false or inaccurate valuation reports, sham transactions and financial transfers, criminal investigations involving foreign investors and legal risks associated with entry into Türkiye.
For clients living abroad, where legally possible, an initial review may be conducted to identify the relevant investigation and the immediate legal position before determining which documents or formal power of attorney arrangements are required for the next stage.
For an initial assessment, it is useful to provide:
the year in which Turkish citizenship was acquired;
the project or company through which the investment was made;
property information;
any available citizenship documents;
the valuation report;
the investment eligibility certificate;
and bank payment records.
Av. Murat Can Dolğun Istanbul Bar Association – Registration No. 75860 TD Law Firm
Address: Istanbul World Trade Center (IDTM), A2 Block, Floor 5, No. 206, Yeşilköy Mah., Atatürk Cad., Bakırköy / Istanbul, Türkiye
OUR PREVIOUS ARTICLES
19 September 2026
“Revocation and Withdrawal of Turkish Citizenship Acquired Through Investment: False Valuation Reports, Sham Transactions, Good-Faith Investors and Judicial Protection.”
This article examines in detail the distinction between Articles 31 and 40 of Turkish Citizenship Law, good-faith investors, retrospective property valuation, administrative stability, legal certainty and relevant Council of State case law.
Available on dolgun.av.tr.
26 September 2026
“The 2026 Turkish Citizenship Cancellation Process Affecting 1,070 Persons.”
This article examines the investigation announced on 21 September 2026, including 263 investors, 807 family members, 274 allegedly sham property sales, valuation issues and financial transactions.
Available on dolgun.av.tr.
LEGAL NOTICE
This article has been prepared for general legal information purposes based on publicly available official announcements, legislation, accessible judicial decisions and publicly reported developments as of 28 September 2026.
References to “false valuation reports,” “sham transactions,” “irregular citizenship,” “criminal organisation,” “fraud,” “forgery” or similar expressions in relation to ongoing criminal investigations refer to allegations and assessments publicly attributed to the investigating authorities.
The existence of a criminal investigation, detention or remand decision does not constitute a final criminal conviction.
The presumption of innocence applies unless and until a final judgment of conviction is rendered.
The existence of a criminal investigation concerning a company, developer or valuation professional does not mean that every investor who dealt with that person or company is in the same legal position.
Similarly, the fact that an investor is not a criminal suspect does not by itself establish that all objective statutory requirements for the acquisition of Turkish citizenship were satisfied.
Every citizenship case should be examined individually by reference to the date of investment, the legislation applicable at that time, the genuine value of the property, financial transfers, the investor’s personal conduct, the investment eligibility certificate, the citizenship file, any related criminal investigation and the individual administrative decision issued in respect of the person concerned.
This article does not constitute a guarantee of outcome or an individual legal opinion concerning any particular person or dispute.
INTRODUCTION: WE HAD ALREADY WARNED ABOUT THE DEVELOPING CITIZENSHIP CANCELLATION ISSUE
On 19 September 2026, we published a detailed legal analysis concerning the cancellation and withdrawal of Turkish citizenship acquired through investment.
In that article, we examined false or allegedly inflated property valuation reports, sham real estate transactions, the legal position of good-faith investors, the distinction between cancellation under Article 31 of Turkish Citizenship Law No. 5901 and withdrawal under Article 40, and the judicial remedies available against citizenship-related administrative decisions.
Only two days after that publication, a major new development substantially expanded the scope of the issue.
On 21 September 2026, Turkish authorities announced a new investigation concerning real estate transactions through which 1,070 persons were stated to have acquired Turkish citizenship.
According to the Istanbul Chief Public Prosecutor’s Office, the investigation concerns allegations including sham property sales, financial transactions that did not reflect genuine investment payments, and property valuation reports allegedly showing values substantially higher than the actual value of the properties.
For investors potentially affected by this investigation, the most important question is now:
“If I am one of the 1,070 people identified in this investigation, has my Turkish citizenship already been cancelled?”
The answer requires a careful legal distinction.
The public announcement did not state that all 1,070 persons had already received final individual decisions cancelling their Turkish citizenship.
The Istanbul Chief Public Prosecutor’s Office stated that the necessary administrative process had been initiated for the cancellation of citizenship considered to have been acquired irregularly.
Being identified within a criminal investigation, being subjected to an administrative review, having an investment conformity determination reconsidered, receiving an individual administrative decision concerning citizenship, and challenging that decision before the administrative courts are separate legal stages.
Accordingly, an investor who has been told that he or she is “among the 1,070 people” should not determine his or her legal status solely from general news reports.
The individual citizenship file must be examined.
I. WHAT EXACTLY IS THE 1,070-PERSON TURKISH CITIZENSHIP INVESTIGATION?
The investigation is being conducted by the Istanbul Chief Public Prosecutor’s Office.
According to the official information reported by Anadolu Agency, the authorities evaluated Land Registry and Cadastre records, expert reports, MASAK financial analyses and other documents together.
The Prosecutor’s Office stated that, in certain transactions:
the foreign currency required for Turkish citizenship had allegedly not genuinely entered Türkiye;
purchase and sale transactions had allegedly been structured using the financial resources of intermediary companies or sellers;
sham or collusive property transactions had allegedly been created;
and artificially high valuation reports had allegedly been prepared in relation to certain properties.
According to the same official statement, transactions totalling approximately USD 72.25 million were considered to have been carried out on a sham or collusive basis.
The Minister of Justice also referred to transactions exceeding TRY 3.5 billion in the second phase of the investigation.
The current investigation is not limited to the question of whether a valuation report was accurate.
For an affected investor, the legal review may require examination of:
the title deed,
the purchase agreement,
the valuation report,
the Certificate of Conformity,
bank statements,
SWIFT records,
the source of the investment funds,
the amount actually received by the seller,
any subsequent repayment of funds,
and the complete citizenship application file.
The real economic and legal substance of each individual investment is therefore critical.
II. THE 1,070 PEOPLE ARE NOT 1,070 PRINCIPAL INVESTORS
One of the most important facts disclosed by the authorities concerns the composition of the 1,070-person group.
According to the information released by the Ministry of Interior and reported by Anadolu Agency:
263 persons are principal investors.
807 persons are family members.
This gives a total of 1,070 persons.
The authorities further stated that 1,015 persons acquired Turkish citizenship at the time of the original citizenship decision, while 55 children acquired Turkish citizenship after that decision.
Accordingly, it would be inaccurate to describe the matter as involving “1,070 investors”.
It concerns 263 principal investors together with 807 family members.
This distinction has substantial legal importance because the status of the principal investor and the citizenship status of a spouse or child may require separate examination.
III. HAS THE TURKISH CITIZENSHIP OF ALL 1,070 PEOPLE ALREADY BEEN CANCELLED?
Based on the official information currently available, it would not be accurate to state that all 1,070 persons have already received final individual cancellation decisions.
The wording publicly used by the authorities is that:
the necessary administrative process for the cancellation of citizenship has been initiated.
This distinction should not be treated as a technicality.
There may be several separate stages:
Identification in the investigation.
Administrative examination of the investment.
Examination of the Certificate of Conformity.
Examination of the citizenship file.
Issuance of an individual administrative decision.
Notification of that decision.
Judicial review before the competent administrative court.
Accordingly, a person who believes that he or she falls within the 1,070-person group should first determine the exact current stage of the individual file.
IV. IS THERE AN OFFICIAL PUBLIC LIST OF THE 1,070 PEOPLE?
This point requires particular caution.
Various lists are currently circulating on social media and through private messaging groups, and some of these documents are being presented as lists of persons allegedly included in the 1,070-person investigation.
However, in the official public statements referred to in this article, the authorities have not published a complete list containing the names of all 1,070 persons.
The official announcements disclose the number of affected persons, the number of principal investors and family members, and general information concerning the investigation.
They do not publish a complete official name list.
Accordingly, lists circulating on social media should NOT be treated as an official confirmation that a particular person is or is not included in the investigation.
The accuracy, completeness and source of such lists are not presently confirmed by the official announcements cited in this article.
They may contain incomplete information, outdated information, spelling differences, duplicated names or persons who are not actually subject to an individual citizenship measure.
For this reason, the existence of a person’s name on a social media list should be treated only as information requiring verification.
Likewise, the absence of a name from an unofficial list does not prove that the person is outside the scope of the administrative investigation.
The correct approach is to verify the individual’s position through official citizenship records, the relevant administrative file and, where necessary, the underlying investigation records.
In short:
A social media list is not an administrative decision.
It is not an official citizenship record.
It is not proof that citizenship has been cancelled.
Each case must be verified individually.
V. WHY THE ACTUAL BANK PAYMENT MAY BE ONE OF THE MOST IMPORTANT ISSUES
One of the central allegations in the investigation concerns the reality of the investment payments.
According to the Prosecutor’s Office, in certain transactions the required foreign currency allegedly did not genuinely enter Türkiye, and financial arrangements were allegedly created using resources belonging to sellers or intermediary entities.
This makes the actual movement of funds extremely important.
A genuine investor may have:
paid the full purchase price from his or her own bank account;
used genuine personal or commercial funds;
transferred the funds directly to the seller;
received no undisclosed refund;
genuinely acquired the property;
and had no knowledge of or involvement in any allegedly irregular structure.
That factual situation is materially different from a transaction in which the required investment capital was only made to appear to originate from the investor.
Therefore, the analysis should not normally stop with one bank transfer receipt.
The entire transaction may need to be reconstructed:
source of funds → investor’s bank account → transfer to seller → receipt by seller → subsequent movement of funds.
Complete bank statements, SWIFT documents and evidence of the source of funds may become highly important evidence.
VI. “I DID NOT PREPARE THE VALUATION REPORT”
This issue may be particularly important where Article 31 of Turkish Citizenship Law No. 5901 is relied upon.
Article 31 concerns cancellation of the decision granting Turkish citizenship where citizenship was acquired as a result of a false statement by the person concerned or the concealment of material matters forming the basis of the acquisition.
The Directorate General of Population and Citizenship Affairs similarly explains that an investigation is conducted and that citizenship may be cancelled where concealment of matters forming the basis of the acquisition is clearly established.
An allegation that a valuation expert prepared a false or inaccurate valuation report does not, by itself, establish that the investor knew the report was false.
Likewise, an allegation concerning acts by a seller, intermediary or third party does not, without further evidence, establish that every investor knowingly participated in those acts.
Where Article 31 is relied upon, the following questions may therefore become important:
What false statement did the investor personally make?
What material fact did the investor conceal?
Did the investor know that the valuation was allegedly inaccurate?
Did the investor request that the stated value be increased?
Did the investor receive any undisclosed return of the purchase price?
Did the investor submit any document knowing that it was false?
These questions concern the individual investor’s conduct.
VII. GOOD FAITH IS IMPORTANT — BUT IT MAY NOT ANSWER EVERY LEGAL QUESTION
A different legal issue arises under Article 40 of Turkish Citizenship Law No. 5901.
Article 31 and Article 40 should not be treated as interchangeable provisions.
Article 31 is primarily concerned with false statements or concealment attributable to the person concerned.
Article 40 concerns the withdrawal of a citizenship decision where it is subsequently determined that the legal conditions for the decision were not satisfied.
An investor may therefore have acted entirely in good faith.
The investor may never have met the valuation expert.
The investor may have relied upon the developer, advisers and official administrative documents.
There may nevertheless be a separate legal question:
Did the property genuinely satisfy the statutory investment requirement applicable at the relevant time?
Accordingly, a complete defence should generally address two separate questions:
Did the investor personally participate in any false statement, concealment or irregularity?
Were the objective legal conditions for the acquisition of Turkish citizenship actually satisfied?
We discussed the distinction between cancellation under Article 31 and withdrawal under Article 40 in greater detail in our previous article:
VIII. THE HISTORICAL VALUE OF THE PROPERTY MAY BE CRITICAL
Where the original valuation report is challenged, the relevant question is not necessarily:
“What is this property worth today?”
The relevant question may instead be:
“What was the true market value of this property on the relevant investment date?”
This distinction can be decisive.
An allegedly inaccurate valuation report does not necessarily mean that the property itself was below the statutory investment threshold.
A retrospective valuation may therefore become necessary.
Such an assessment may consider:
historical comparable sales;
other units sold in the same development;
floor area;
floor level;
location;
view;
state of completion;
historical exchange rates;
Land Registry data;
and market conditions prevailing on the relevant date.
The investment should be assessed under the factual conditions existing when it was made.
IX. THE CURRENT USD 400,000 THRESHOLD SHOULD NOT SIMPLY BE APPLIED TO HISTORICAL INVESTMENTS
The real estate investment threshold for Turkish citizenship has changed over time.
Accordingly, an investment made under an earlier legal regime must be assessed under the rules applicable to that investment at the relevant time.
The current USD 400,000 requirement should not simply be applied retrospectively to every historical citizenship file.
The following dates may therefore be important:
the property purchase date;
the payment date;
the valuation report date;
the Certificate of Conformity date;
the citizenship application date;
and the citizenship decision date.
The applicable legislation must then be determined according to the chronology of the individual case.
X. WHY THE CERTIFICATE OF CONFORMITY MATTERS
Citizenship by investment is not based solely upon a private declaration by the investor.
The investment must pass through administrative procedures and the relevant competent authority issues a Certificate of Conformity where the statutory investment requirements are considered satisfied.
The Directorate General of Population and Citizenship Affairs expressly regulates the role of the conformity determination in exceptional citizenship applications made by foreign investors.
Under Turkish citizenship legislation, cancellation of a citizenship acquisition decision may also have consequences for spouses and children who acquired citizenship in connection with the principal applicant.
The official guidance issued by the Directorate General of Population and Citizenship Affairs addresses the effects of cancellation upon persons who acquired citizenship through the person concerned.
However, each family member’s citizenship history should still be examined.
This is particularly important because the Ministry stated that 55 children within the relevant group acquired citizenship after the original citizenship decision.
Therefore, the precise date and legal basis on which each spouse or child became a Turkish citizen should be established individually.
XII. WHAT HAPPENED AFTER THE 21 SEPTEMBER OPERATION?
The criminal investigation remains active.
On 25 September 2026, Anadolu Agency reported that judicial procedures concerning 74 detained suspects had been completed.
Thirty-three suspects were remanded in custody.
Twenty suspects were subjected to a judicial-control measure requiring them not to leave their residence.
A remand decision is not a final criminal conviction.
Likewise, criminal proceedings involving sellers, intermediaries, valuation professionals or other suspects are legally distinct from an administrative determination concerning the citizenship status of an individual investor.
Evidence from the criminal investigation may be relevant to the citizenship proceedings.
However, the legal position of each investor must still be individually assessed.
XIII. ASSET MEASURES DO NOT MEAN THAT EVERY INVESTOR’S PROPERTY HAS BEEN SEIZED
They do not establish that the property of every person within the 1,070-person group has been seized.
Whether a particular investor’s property is subject to a restriction, seizure, annotation or another measure must be checked through that person’s own official records.
A criminal asset-protection measure and an administrative citizenship decision are separate legal matters.
XIV. WHAT SHOULD AN INVESTOR DO IF HE OR SHE MAY BE AMONG THE 1,070 PEOPLE?
The first task should be to establish the exact legal and administrative status of the individual case.
Questions to be answered include:
Am I actually included in the relevant investigation?
Is my citizenship file merely under examination?
Has any action been taken concerning my Certificate of Conformity?
Has an individual citizenship decision been issued?
If so, what is its legal basis?
Has the decision been formally notified to me?
What specific transaction or document is the administration relying upon?
Was my payment genuine and traceable?
Did my property satisfy the required investment value at the relevant historical date?
Was I personally involved in any alleged valuation or financial irregularity?
What is the separate citizenship status of my spouse and children?
XV. DOCUMENTS THAT SHOULD BE PRESERVED AND REVIEWED
Potentially affected investors should consider assembling the complete investment and citizenship record.
Important documents may include:
title deed records;
property sale contracts;
valuation reports;
Certificate of Conformity;
bank transfer receipts;
complete bank account statements;
SWIFT records;
foreign exchange documents;
invoices;
proof of source of funds;
communications with sellers or intermediaries;
citizenship application documents;
the citizenship decision;
and citizenship records relating to spouses and children.
Particular attention should be given to historical banking records because such documents can become more difficult to obtain with the passage of time.
XVI. WHAT IF THE INVESTOR IS CURRENTLY OUTSIDE TÜRKİYE?
A citizenship review should not automatically be equated with a criminal restriction on travel.
Being identified within a citizenship-related investigation does not, by itself, establish the existence of:
an arrest warrant;
a detention order;
a judicial-control measure;
or another individual criminal restriction.
Accordingly, an investor abroad should not assess the risks of travelling to Türkiye solely on the basis of having been told that he or she is “one of the 1,070”.
The following matters should be separately verified:
current citizenship status;
any individual administrative citizenship decision;
any criminal investigation concerning the investor;
any arrest or judicial restriction;
and the immigration consequences if Turkish citizenship has already been affected.
XVII. CAN A CITIZENSHIP CANCELLATION OR WITHDRAWAL DECISION BE CHALLENGED?
Yes.
A citizenship cancellation or withdrawal decision constitutes an administrative act and is subject to judicial review under Turkish administrative law.
The precise legal remedy, competent court, time limit and any application for a stay of execution must be assessed according to the individual decision and the authority that issued it.
This is another reason why the legal basis of the decision must first be established.
A decision based on Article 31 and a decision based on Article 40 raise different legal questions.
They should not simply be described by the single English word “revocation” without identifying the Turkish-law mechanism actually being used.
XVIII. THE CENTRAL QUESTION FOR THE 1,070 PEOPLE
The central legal question is not merely:
“Was there irregularity somewhere within the wider transaction structure?”
The relevant questions are individual:
Was this investor’s payment genuine?
Where did the money originate?
Did the seller actually receive the money?
Was any amount returned?
What was the property’s true value at the relevant historical date?
Did the investor know about any alleged valuation irregularity?
Did the investor make a false statement?
Did the investor conceal any material fact?
Were the objective statutory investment conditions actually satisfied?
What did the competent public authorities determine when the Certificate of Conformity was originally issued?
What new evidence is now relied upon to alter the earlier administrative position?
CONCLUSION: “1,070 PEOPLE” DOES NOT MEAN 1,070 IDENTICAL CASES
The investigation announced on 21 September 2026 is one of the most significant recent developments concerning Turkish citizenship acquired through real estate investment.
According to the information released by the authorities, the relevant group consists of:
However, a large-scale investigation does not transform hundreds of separate investments into one single legal case.
Each investor’s position must be examined individually.
The analysis should include:
the legislation applicable on the investment date;
the genuine movement of funds;
the historical value of the property;
the valuation report;
the Certificate of Conformity;
the investor’s own declarations and conduct;
any alleged return or circular movement of funds;
the legal position of spouses and children;
and the precise factual and statutory grounds relied upon by the administration.
The existence of an investigation involving third parties does not, by itself, determine whether a particular investor acquired Turkish citizenship unlawfully.
Equally, good faith alone may not resolve every possible issue where the authorities allege that an objective statutory investment requirement was not satisfied.
The correct legal method is therefore to reconstruct the individual investment and citizenship file, determine the statutory basis relied upon by the administration and test the allegations against the investor’s actual documents.
For our earlier comprehensive legal analysis concerning Turkish citizenship acquired by investment, cancellation, withdrawal, alleged false valuation reports, sham transactions and good-faith investors, see:
TD Law Firm advises and represents foreign investors in matters concerning Turkish citizenship by investment, administrative review of citizenship files, cancellation and withdrawal proceedings, Certificate of Conformity disputes, real estate valuation issues, alleged sham transactions and related administrative litigation.
In cases potentially connected with the 1,070-person investigation announced on 21 September 2026, the legal assessment should be based on the investor’s individual citizenship, property, valuation and banking records rather than general media reports or unverified lists circulating on social media.
Av. Murat Can Dolğun Istanbul Bar Association – Registration No. 75860
Address: Istanbul World Trade Center (İDTM) A2 Block, No: 206 Bakırköy / Istanbul, Türkiye
LEGAL NOTICE
This article is provided for general legal information only and does not constitute individual legal advice or a guarantee of any particular outcome.
The legal position of each investor must be assessed by reference to the individual administrative file, investment documents, banking records, citizenship records and the legislation applicable at the relevant time.
In particular, names appearing on lists circulated through social media, messaging applications or other unofficial channels should not be regarded as official confirmation of inclusion in the 1,070-person investigation unless and until the individual position is verified through official records.
The acquisition of Turkish citizenship by investment is one of the exceptional methods of acquiring citizenship regulated under Article 12 of Turkish Citizenship Law No. 5901 (“TCL”) and Article 20 of the Regulation on the Implementation of the Turkish Citizenship Law (“Regulation”).
In particular, where citizenship is sought through the acquisition of real estate, the investment must satisfy the amount and other conditions prescribed by the legislation, the competent administrative authorities must determine that the relevant investment requirements have been fulfilled, and the competent authority must ultimately issue a decision granting Turkish citizenship.
Criminal investigations and administrative reviews that became public in 2025 and 2026 have resulted in renewed scrutiny of the legal status of a significant number of persons who previously acquired Turkish citizenship by investment. These investigations have primarily concerned allegations that low-value properties were presented as having substantially higher values through false or fraudulent valuation reports, that sham property transactions were conducted, that the legally required investment amount was presented as having been satisfied when it had not actually been paid, and that apparent financial transfers were subsequently reversed.
On 4 August 2026, the Turkish Ministry of Justice announced that, within an investigation concerning allegations that low-value properties had been presented as high-value properties through fraudulent valuation reports and sham sales transactions, legal proceedings had been initiated with a view to cancelling the citizenship of 687 persons stated to have acquired Turkish citizenship through this method.
However, the existence of a criminal investigation against a property developer, real estate company, intermediary or valuation expert and the conclusion that an investor dealing with that person or entity unlawfully acquired Turkish citizenship are distinct legal questions.
For each investor, it is necessary to examine separately the legislation in force at the date of the investment, the true economic substance of the investment, the historical value of the property, the movement of funds, whether the investor knew of any alleged irregularities committed by third parties, and the statutory basis upon which the citizenship decision is subsequently terminated.
In this context, a fundamental distinction must be drawn between cancellation of a citizenship acquisition decision under Article 31 TCL and withdrawal of a citizenship decision under Article 40 TCL.
I. LEGAL NATURE OF TURKISH CITIZENSHIP BY INVESTMENT
Citizenship by investment is not a form of citizenship that can be “sold” by private persons.
A developer or real estate company may sell property, and an intermediary or consultancy company may provide services in relation to the investment and application process. The authority to grant Turkish citizenship, however, belongs to the Turkish State.
Article 12 TCL regulates circumstances in which Turkish citizenship may be acquired exceptionally. The types and amounts of qualifying investments are principally regulated under Article 20(2) of the Regulation.
Under the current framework, the real estate route generally requires the acquisition of property with a value of at least USD 400,000 or its equivalent in foreign currency, together with the legally prescribed restriction preventing disposal for three years.
The current USD 400,000 threshold, however, cannot be applied indiscriminately to investments completed under earlier versions of the legislation. Investment thresholds and procedural requirements have changed over time.
Accordingly, a historical citizenship file must be examined by reference to the legal regime applicable when the relevant investment was made.
The legality of an earlier investment cannot therefore be assessed solely by reference to the investment requirements presently in force.
II. LEGAL SIGNIFICANCE OF VALUATION REPORTS AND THE CERTIFICATE OF CONFORMITY
In citizenship applications based on real estate investment, purchasing property alone is insufficient. The Turkish system includes an administrative process for determining whether the relevant property and investment satisfy the requirements prescribed by citizenship legislation.
Valuation reports, title deed records, determination of the qualifying investment amount and the Certificate of Conformity therefore assume considerable legal significance.
A Certificate of Conformity is not a document created merely by the investor’s unilateral declaration or by the seller’s representation. The competent public authority conducts an assessment as to whether the investment satisfies the applicable requirements.
Consequently, where a previously granted citizenship decision is subsequently reviewed, the analysis should not be confined to the investor’s relationship with the developer or other private parties. The administrative examination that preceded the citizenship decision must also be taken into account.
Nevertheless, the fact that a Certificate of Conformity was issued does not mean that the citizenship decision can never subsequently be withdrawn. Article 40 TCL expressly regulates the withdrawal of citizenship decisions where it is later established that the legal requirements had not been satisfied.
Two extreme approaches should therefore be avoided.
The prior issuance of a Certificate of Conformity does not place a citizenship decision entirely beyond subsequent legal review.
Conversely, an investigation concerning a valuation company or property developer does not, of itself, establish that every investor who dealt with that person or entity unlawfully acquired Turkish citizenship.
Each case must be examined on its own facts and legal circumstances.
III. THE 2025 INVESTIGATION INTO ALLEGED SHAM PROPERTY TRANSACTIONS
Large-scale investigations concerning citizenship by investment did not begin in 2026.
On 24 September 2025, an Istanbul-based investigation extending across 19 provinces became public. It concerned allegations that foreign investors had obtained Turkish citizenship through sham real estate transactions.
According to information released in connection with the investigation, it was alleged that 451 foreign investors, together with their family members, had acquired citizenship through the scheme; that the foreign capital required for citizenship had not genuinely entered Türkiye; that fictitious financial movements had been created; and that properties had been presented at values exceeding their true values.
Subsequent reports concerning the investigation also contained allegations that arrangements had been made enabling certain properties to be returned to previous owners or related persons after completion of the citizenship process.
If substantiated, such allegations may demonstrate a significant discrepancy between the actual economic substance of the transactions and their formal legal appearance.
It must nevertheless be emphasised that allegations made during a criminal investigation do not constitute final criminal convictions.
IV. THE 2026 INVESTIGATION CONCERNING 687 PERSONS
On 4 August 2026, the Ministry of Justice published details of a large-scale investigation coordinated by the Organised Crime Investigation Bureau of the Istanbul Chief Public Prosecutor’s Office.
The official announcement referred to allegations involving:
“low-value properties being presented as high-value properties through fraudulent valuation reports and Turkish citizenship being obtained through sham sales transactions.”
According to the announcement, approximately TRY 2.5 billion which should have entered Türkiye in connection with citizenship acquisitions allegedly did not enter the country, and fictitious money transfers were allegedly used instead.
The authorities further announced measures concerning seven companies and 1,045 properties and stated that legal proceedings had been initiated with a view to cancelling the citizenship of 687 persons said to have obtained citizenship through the method under investigation.
The investigation was also reported by Anadolu Agency:
Descriptions such as “fraudulent valuation” and “sham transaction” in this context refer to allegations made within the investigation. An investigation, detention or remand order does not constitute a final conviction. The presumption of innocence continues to apply unless and until a final conviction is entered.
V. ARTICLE 31 TCL: CANCELLATION FOR FALSE STATEMENTS OR CONCEALMENT OF MATERIAL MATTERS
Article 31 of Turkish Citizenship Law No. 5901 provides:
“Where a decision on the acquisition of Turkish citizenship has resulted from a false statement by the person concerned or from the concealment of material matters constituting the basis for the acquisition of citizenship, the decision shall be cancelled by the authority which issued it.”
The Law does not provide that every irregularity discovered in the citizenship acquisition process is, in itself, sufficient for cancellation under Article 31.
For Article 31 to apply, the acquisition of citizenship must have resulted from a “false statement by the person concerned” or from that person’s concealment of a material matter forming the basis of the acquisition of citizenship.
Accordingly, where an administrative decision is based on Article 31, it must be identified which statement made by the investor was false or which material matter was concealed.
There must also be a causal relationship between the false statement or concealment and the acquisition of citizenship. In other words, it is necessary to consider whether citizenship would have been granted had the true circumstances been known to the administration.
Article 31 should therefore not be treated as a general statutory mechanism for correcting every possible irregularity associated with an earlier citizenship decision.
VI. ACTS OF THIRD PARTIES CANNOT, OF THEMSELVES, BE ATTRIBUTED TO THE INVESTOR
One of the central legal issues in the current disputes is the extent to which acts allegedly committed by developers, real estate companies, intermediaries or valuation experts can produce consequences for individual investors.
Article 31 refers specifically to a false statement or concealment by “the person concerned”.
Accordingly, the fact that a valuation expert prepared a false report does not, without more, establish that the investor knew that the report was false.
Similarly, an allegation that a developer carried out sham transactions in certain sales is not, by itself, sufficient to establish that every investor who purchased property from that developer knowingly participated in those transactions.
An individualised examination is therefore necessary.
In particular, it may be necessary to determine:
whether the investor knew that the valuation report was inaccurate;
whether the investor gave any instruction or otherwise participated in increasing the stated value;
whether the investor knew that part of the purchase price would later be returned;
whether any part of the purchase price was in fact returned;
whether the investor made any false statement during the citizenship application; and
whether the investor knowingly concealed any matter material to the acquisition of citizenship.
Particularly in light of the express wording of Article 31, the conduct of a third party should not simply be equated with the conduct of the investor.
VII. ARTICLE 40 TCL: WITHDRAWAL WHERE THE LEGAL REQUIREMENTS WERE NOT SATISFIED
Article 40 TCL provides:
“Decisions concerning the acquisition or loss of Turkish citizenship shall be withdrawn where it is subsequently understood that they were issued without the legal requirements having been satisfied or were issued repetitively.”
Article 40 addresses a different legal issue from Article 31.
Article 31 focuses upon the false statement or concealment of the person concerned. Article 40 concerns whether the legal requirements for the citizenship decision objectively existed when the decision was made.
It is therefore possible, in principle, for an investor to have engaged in no fraudulent conduct whatsoever while one of the objective statutory conditions required for citizenship was nevertheless absent from the outset.
For example, an investor may have relied in good faith on the accuracy of a valuation report and may not have made any misleading statement. It might nevertheless subsequently be established through reliable evidence that the true value of the property at the relevant time was below the investment threshold prescribed by the legislation then in force.
In such circumstances, the question of false statement or concealment under Article 31 and the question of whether the objective legal requirements existed under Article 40 must be analysed separately.
VIII. WHY THE DISTINCTION BETWEEN ARTICLES 31 AND 40 IS CRITICAL
Articles 31 and 40 do not merely regulate the same legal consequence using different terminology.
The central question under Article 31 is:
Was citizenship acquired as a result of a false statement by the person concerned or the concealment of a material matter?
The central question under Article 40 is:
Did the legal requirements necessary for the acquisition of citizenship actually exist when the citizenship decision was issued?
The distinction is not merely theoretical or terminological.
It directly affects the statutory basis of the administrative measure, its factual grounds, the matters that the administration must establish and the legal arguments available to the person concerned.
An investor’s false representation and an erroneous administrative determination that the investment requirements had been fulfilled are not the same legal circumstance.
IX. ADMINISTRATIVE ERROR, LEGAL CERTAINTY AND WITHDRAWAL
A decision granting citizenship is an administrative act. The withdrawal of unlawful administrative acts is closely connected with the principles of legal certainty and administrative stability under Turkish administrative law.
Where the alleged illegality results not from fraud by the person concerned but from an error in the administration’s own examination or assessment, the limits applicable to the later withdrawal of an act conferring legal status become particularly significant.
The absence of an express time limit in Article 40 does not eliminate questions concerning legal certainty.
Citizenship is a fundamental component of an individual’s legal status and social identity. A person may have relied upon that status over a period of years when organising family life, economic activity, professional relationships and residence in Türkiye.
Depending on the circumstances of the individual case, these matters may therefore become relevant to legal certainty, administrative stability and proportionality.
At the same time, deliberate deception by an applicant and an error made by the administration in its own examination cannot simply be treated as legally identical situations.
X. THE PRINCIPLE OF LEGALITY IN MATTERS OF CITIZENSHIP
Article 66(3) of the Constitution of the Republic of Türkiye provides:
“Citizenship shall be acquired under the conditions stipulated by law and shall be lost only in the cases specified by law.”
This constitutional provision establishes the principle of legality in relation both to the acquisition and loss of citizenship.
The statutory basis for terminating citizenship status must therefore be identified, and the circumstances of the individual case must fall within the elements of the ground for loss prescribed by law.
Accordingly, subordinate regulations, administrative circulars or administrative procedural rules cannot be interpreted in a manner that expands the statutory scope of Articles 31 and 40 TCL.
Where an administrative measure has the serious consequence of terminating citizenship status, the administration should identify both the statutory basis for its decision and the factual circumstances that make that provision applicable.
XI. THE LEGISLATION IN FORCE AT THE DATE OF THE INVESTMENT MUST BE CONSIDERED
The current USD 400,000 threshold for the real estate route cannot be used as the sole benchmark for every historical investment.
The required investment amounts and other conditions have changed over time.
A historical file should therefore be examined by reference to, among other matters:
the date of the investment;
the investment threshold in force on that date;
the date on which the acquisition of the property was completed;
the date of the Certificate of Conformity;
the date of the citizenship application; and
the date of the citizenship decision.
The current investment threshold cannot simply be applied retrospectively when assessing the legality of an investment completed under an earlier legal regime.
XII. WHERE A FALSE VALUATION IS ALLEGED, THE HISTORICAL VALUE OF THE PROPERTY REMAINS CRITICAL
An allegation that a valuation report was fraudulent or inaccurate does not eliminate the separate question of what the property was actually worth.
On the contrary, one of the central factual questions becomes the true market value of the property at the date of the investment.
Assume, for example, that the applicable citizenship threshold was USD 250,000 and that the property was valued in the original report at USD 400,000.
If years later it is alleged that the valuation report was inaccurate, it remains necessary to establish whether the property’s true historical value was USD 150,000, USD 280,000 or approximately USD 400,000.
A retrospective independent valuation may therefore become important.
Comparable transactions from the relevant period, independent sales within the same development, bank valuation reports, title deed records, historical project price lists, the physical characteristics and location of the property, and contemporary market conditions may all be relevant.
If objective historical evidence establishes that the property itself already exceeded the statutory threshold applicable at the date of investment, alleged misconduct by the person who prepared the valuation report in other transactions does not, by itself, establish that the individual investor failed to satisfy the objective investment requirement.
XIII. THE ENTIRE FLOW OF FUNDS SHOULD BE EXAMINED
Another major issue emerging from the current investigations is whether the qualifying investment amount was genuinely paid in economic terms.
Examining a single bank receipt may therefore be insufficient.
The entire financial chain should be analysed.
Relevant questions may include the source of the investor’s funds, how and when the money entered Türkiye, the account to which it was transferred, whether the seller actually received the purchase price, and whether any part of the funds was subsequently returned directly or indirectly to the investor or a related person.
An investor who apparently transferred USD 400,000 but, pursuant to a prior arrangement, later received a substantial portion of that sum back presents a materially different case from an investor who genuinely paid the required investment amount and received no refund.
The financial substance of the transaction is therefore a central evidential issue.
XIV. LEGAL CONSEQUENCES OF AN INVESTIGATION AGAINST A DEVELOPER OR VALUATION COMPANY
The existence of a criminal investigation against a real estate company, developer, intermediary or valuation expert does not, of itself, establish that all investors who dealt with that person or entity unlawfully acquired Turkish citizenship.
A company may have sold hundreds of properties.
Some properties may have been overvalued, whereas the genuine market values of others may already have exceeded the relevant citizenship threshold.
Some investors may have received part of the purchase price back, whereas others may have received no refund whatsoever.
Some investors may be alleged to have known of an unlawful arrangement, while others may have invested in reliance upon official valuation documentation, title deed procedures and a Certificate of Conformity.
Citizenship status should therefore be examined through an individualised assessment of each file rather than through a generalised conclusion based solely upon the identity of the developer or valuation company.
XV. THE LEGAL POSITION OF A GOOD-FAITH INVESTOR
The concept of a “good-faith investor” must be used carefully in citizenship disputes.
Good faith does not, of itself, guarantee that citizenship status will be preserved in every circumstance.
It is, however, particularly important in an assessment under Article 31.
An investor may have:
genuinely paid the required investment amount;
received no refund;
acquired the property through an official title deed transaction;
relied upon a valuation report produced within the authorised system;
obtained a Certificate of Conformity;
complied with the applicable restriction on disposal;
submitted no false document;
made no false statement; and
had no knowledge of unlawful conduct allegedly committed by third parties.
Such an investor is not in the same legal position as a person who knowingly participated in a sham investment arrangement.
Nevertheless, even where the investor engaged in no fraudulent conduct, it may subsequently be alleged that an objective statutory investment requirement did not actually exist when citizenship was granted.
In such a case, the existence of a false statement or concealment attributable to the investor under Article 31 and the existence of the objective legal conditions under Article 40 must be examined separately.
XVI. AN INVESTOR WHO RELIED UPON THE ADMINISTRATION’S OWN SYSTEM
The citizenship-by-investment procedure involves several stages of administrative examination.
An investor may have completed an official title deed transaction, relied upon a valuation report produced through the authorised system, obtained a Certificate of Conformity and completed the citizenship application before the competent public authorities.
The existence of these steps does not absolutely prevent the application of Article 40.
However, an investor’s reliance upon a system established and supervised by the administration may, depending upon the individual circumstances, be relevant to the principles of legal certainty, administrative stability, legitimate expectations and proportionality.
These considerations may become particularly significant where the alleged illegality resulted not from deception by the investor but from errors in the examination or assessment undertaken by the competent authorities.
XVII. COUNCIL OF STATE, 10TH CHAMBER, E.2022/7637, K.2025/3313, 26 JUNE 2025
The judgment of the 10th Chamber of the Council of State in Case E.2022/7637, K.2025/3313, dated 26 June 2025, did not concern a fraudulent property valuation or real estate investment dispute.
It is nevertheless important in relation to the application of Article 40 TCL and judicial review of the withdrawal of citizenship decisions.
The judgment emphasises the importance of establishing factual grounds capable of demonstrating whether the relevant legal requirements actually existed at the time citizenship was acquired.
An adverse fact emerging at a later date and the absence of a legal requirement at the time the citizenship decision was issued are not the same thing.
This distinction is relevant to citizenship-by-investment disputes.
For example, the fact that an investigation is commenced against a developer or valuation company in 2026 does not, by itself, establish that an individual investor dealing with that company in an earlier year failed to satisfy the legal requirements applicable at the time citizenship was acquired.
The later information must be capable of demonstrating that a legal requirement was in fact absent at the relevant historical date.
XVIII. COUNCIL OF STATE, 10TH CHAMBER, E.2021/279, K.2025/3174, 23 JUNE 2025
The judgment of the 10th Chamber of the Council of State in Case E.2021/279, K.2025/3174, dated 23 June 2025, is also significant in relation to Article 40 TCL.
The judgment requires the circumstances relied upon to justify withdrawal of citizenship to be supported by “concrete, sufficient and serious information”.
In terms of the factual grounds of an administrative act, the administration is required to base its decision upon genuine and legally valid grounds.
Applied to citizenship-by-investment disputes, this approach indicates that the existence of an investigation into a particular company or valuation entity cannot, by itself, be treated as a general ground for withdrawing the citizenship of every investor who previously dealt with that entity.
The administration must establish, in relation to the individual investor, which legal requirement was absent when citizenship was acquired.
XIX. CRIMINAL INVESTIGATIONS AND JUDICIAL REVIEW OF CITIZENSHIP DECISIONS MUST BE DISTINGUISHED
A criminal investigation and administrative review of the legality of a citizenship decision are separate legal processes.
Bank records, valuation documents, communications, money transfers and other evidence obtained in a criminal investigation may be highly relevant to a citizenship dispute.
However, the fact that a developer, company director, intermediary or valuation expert is a suspect in a criminal investigation does not, of itself, establish that an investor made a false statement or concealed a material fact within the meaning of Article 31 TCL.
Conversely, the fact that an investor is not a suspect in the criminal investigation does not, of itself, establish that all objective statutory requirements for citizenship were satisfied.
Criminal liability and the validity of a citizenship decision under administrative law are governed by different legal tests.
Evidence obtained in criminal proceedings may be used in the administrative dispute, but the legality of a cancellation or withdrawal decision must still be assessed separately by reference to the elements of the applicable provision of Law No. 5901.
XX. JUDICIAL PROTECTION AGAINST CANCELLATION OR WITHDRAWAL OF CITIZENSHIP
Cancellation or withdrawal of a citizenship decision constitutes an administrative act and is subject to judicial review.
The competent court must be determined by reference to the authority that issued the challenged measure.
Under Article 24 of Law No. 2575 on the Council of State, actions challenging decisions of the President of the Republic are heard by the Council of State as the court of first instance.
A citizenship-by-investment file may, however, involve more than one administrative act.
Cancellation of the Certificate of Conformity and cancellation or withdrawal of the citizenship decision may constitute separate administrative measures.
It is therefore necessary to examine separately:
the authority issuing each measure;
the legal character of the measure;
its statutory basis;
the date of notification;
any earlier decision concerning the Certificate of Conformity; and
the final measure directly affecting citizenship status.
XXI. TIME LIMIT FOR BRINGING AN ADMINISTRATIVE ACTION
Article 7(1) of the Administrative Procedure Law No. 2577 provides, in substance, that unless a special statutory period applies, the general time limit for bringing an action before the Council of State and administrative courts is sixty days.
The precise commencement and calculation of the time limit must nevertheless be determined by reference to the individual case, including the date and manner of notification, the nature of the administrative measure and any relevant administrative application.
A cancellation or withdrawal decision should therefore be reviewed without delay following notification.
XXII. STAY OF EXECUTION
Bringing an action for annulment does not, of itself, suspend the operation of the challenged administrative measure.
Under Article 27 of Law No. 2577, a stay of execution may be granted where the implementation of the administrative act would cause damage that is difficult or impossible to remedy and the act is clearly unlawful. Both conditions must be satisfied.
Termination of citizenship status may have consequences extending considerably beyond identity documents and passports.
Depending upon the individual circumstances, it may affect residence and employment status, travel, corporate activities, banking relationships, family life and the private life established by the individual in Türkiye.
An application for a stay of execution should therefore address not only the alleged unlawfulness of the measure but also the specific and individual harm likely to arise from its implementation.
XXIII. PRIVATE-LAW CLAIMS AGAINST DEVELOPERS, SELLERS AND INTERMEDIARIES
Administrative proceedings concerning citizenship and private-law claims against a developer, seller, intermediary or other private party are distinct legal avenues.
A property may have been expressly marketed as an investment satisfying the conditions for Turkish citizenship, and the investor may have purchased the property in reliance upon that representation.
If the property did not in fact possess the characteristics promised or did not satisfy the investment conditions represented by the seller or intermediary, contractual liability may arise.
Article 112 of the Turkish Code of Obligations No. 6098 provides for liability for damage resulting from non-performance or improper performance of an obligation, subject to the applicable statutory conditions.
Depending upon the facts, the provisions concerning tort and unjust enrichment may also require consideration.
Sales contracts should therefore be preserved together with advertisements, brochures, project presentations, emails, WhatsApp communications and other representations that the property qualified for Turkish citizenship.
XXIV. PROVISIONAL ATTACHMENT AND INTERIM INJUNCTIONS
In high-value investment disputes, it may also be necessary to consider whether an eventual judgment can be effectively enforced.
Where the statutory conditions are satisfied, provisional attachment may be sought in relation to qualifying monetary claims under Article 257 et seq. of the Enforcement and Bankruptcy Law No. 2004.
Where preservation of a particular asset or right is required, an interim injunction may be considered under Article 389 et seq. of the Code of Civil Procedure No. 6100.
Provisional attachment and interim injunctions are distinct forms of interim judicial protection and the appropriate remedy must be determined by reference to the nature of the substantive claim.
XXV. CONSUMER LAW
Where an individual acquiring property did not act for commercial or professional purposes, the applicability of Consumer Protection Law No. 6502 may also require consideration depending upon the nature of the transaction.
The mere fact that property was acquired for citizenship purposes does not, by itself, determine whether the dispute is a consumer dispute.
The legal status of the parties, the purpose of the transaction and the nature of the contractual relationship must be considered together.
The central task in these disputes is frequently to reconstruct the factual and economic reality existing at the date of the investment.
Relevant evidence may therefore include:
the citizenship acquisition decision;
the cancellation or withdrawal decision;
documents evidencing notification;
the Certificate of Conformity;
any decision cancelling the Certificate of Conformity;
the title deed and official deed of sale;
records concerning the restriction on disposal;
the sale or preliminary sale agreement;
valuation reports;
the applicable investment amount determination documentation;
foreign currency purchase documents;
bank receipts;
SWIFT records;
complete bank account movements relating to the investment period;
invoices and receipts;
communications with the seller, developer and intermediaries;
emails and WhatsApp correspondence;
advertisements and marketing materials representing the property as citizenship-eligible;
banking evidence demonstrating that the investment amount was not returned to the investor;
comparable historical property values; and
available documents from any related criminal investigation.
The objective is not simply to accumulate documents, but to reconstruct, through reliable evidence, the economic substance of the transaction at the relevant historical date and the individual conduct of the investor.
XXVII. CONSTITUTIONAL COURT AND EUROPEAN COURT OF HUMAN RIGHTS
Following exhaustion of the ordinary domestic remedies, an individual application to the Turkish Constitutional Court may be considered where the circumstances disclose an alleged violation of a fundamental right falling within the common protection afforded by the Constitution and the European Convention on Human Rights.
The European Convention on Human Rights does not establish an independent right to acquire or retain the nationality of a particular State.
Nevertheless, the case law of the European Court of Human Rights recognises that nationality may form part of an individual’s social identity and private life, and that arbitrary deprivation of nationality may, in certain circumstances, raise issues under Article 8 of the Convention.
These remedies are not additional appellate instances for reconsidering ordinary questions of administrative law. The alleged interference with a Convention or constitutionally protected right must be identified and substantiated in the individual case.
CONCLUSION
The investigations that became public in 2025 and 2026 have resulted in renewed scrutiny of numerous historical Turkish citizenship-by-investment files.
Allegations involving fraudulent or inaccurate valuation reports, artificial inflation of property values, sham sales and fictitious financial movements are serious. Nevertheless, Turkish citizenship law requires individual legal assessment rather than generalised assumptions.
An investigation against a developer does not, of itself, establish that every person who purchased property from that developer unlawfully acquired Turkish citizenship.
Likewise, establishing that a valuation report was inaccurate does not, by itself, prove that the investor knew of the inaccuracy.
Turkish Citizenship Law No. 5901 provides two materially different mechanisms.
Article 31 concerns cancellation of a citizenship acquisition decision where citizenship resulted from a false statement by the person concerned or the concealment of a material matter forming the basis of citizenship.
Article 40 concerns withdrawal where it is subsequently established that the legal requirements for the citizenship decision had not been satisfied.
The scope and requirements of these provisions must be distinguished.
Particularly where unlawful acts are alleged to have been committed by third parties, the individual conduct of the investor requires separate examination.
An investor may have submitted no false document, made no false statement, had no knowledge that a valuation report was inaccurate and genuinely paid the qualifying investment amount. Where Article 31 is invoked in such circumstances, the false statement or concealment attributable to that investor must be identified and established.
Conversely, even in the absence of fraud by the investor, a separate issue may arise under Article 40 if an objective legal requirement for citizenship did not in fact exist when the citizenship decision was issued.
The 2025 judgments of the 10th Chamber of the Council of State further demonstrate the importance, in withdrawal cases, of concrete, sufficient and serious information and of examining whether the relevant legal requirements actually existed when citizenship was acquired.
Accordingly, each file should be examined by reference to:
the legislation applicable at the date of investment;
the investment threshold applicable at that time;
the true market value of the property at the relevant historical date;
the amount genuinely paid by the investor;
the source and subsequent movement of the funds;
whether any direct or indirect refund was made;
whether the investor participated in or knew of any manipulation of the valuation process;
whether the investor knew of unlawful conduct by third parties;
the factual basis upon which the Certificate of Conformity was issued;
the accuracy of the statements made in the citizenship application;
the concrete evidence relied upon by the administration; and
whether the measure terminating citizenship is based upon Article 31 or Article 40 TCL.
Disputes concerning the cancellation and withdrawal of Turkish citizenship acquired by investment therefore cannot be examined solely through citizenship law. They frequently require an integrated analysis of administrative law, administrative procedure, real estate law, the law of obligations, consumer law and, where relevant, criminal law.
TD LAW FIRM
TD Law Firm advises and represents investors in disputes concerning the cancellation and withdrawal of Turkish citizenship acquired by investment, cancellation of Certificates of Conformity, allegations concerning fraudulent or inaccurate property valuations, citizenship proceedings arising from investigations involving developers and real estate companies, and related private-law claims.
In these cases, examining the citizenship decision in isolation is frequently insufficient. The administrative measure should be assessed together with the legislation applicable at the date of investment, title deed records, valuation reports, the Certificate of Conformity, banking records, sale agreements, the historical value of the property and, where relevant, documents obtained from related criminal proceedings.
Çiçek Özgür, “Yatırım Yoluyla Kazanılan Türk Vatandaşlığının İptali ve Geri Alınması” [Cancellation and Withdrawal of Turkish Citizenship Acquired Through Investment], Ankara University Faculty of Law Journal, Vol. 75, No. 1, 2026, pp. 741–779: https://dergipark.org.tr/tr/pub/auhfd/article/1710185
Ahmet Dülger, “Taşınmaz Satın Alınmasıyla Türk Vatandaşlığının İstisnai Yoldan Kazanılmasında Değerleme Raporu ve Uygunluk Belgesi Alınması”, İnönü University Faculty of Law Review, Vol. 16, No. 1, 2025, pp. 167–180: https://dergipark.org.tr/tr/pub/inuhfd/article/1600688
Aslı Bayata Canyaş, “Hukuki Şartlar Oluşmadan Verilmiş Olan Türk Vatandaşlığını Kazanma Kararının Geri Alınmasında Süre Sorunu”, Turkish Bar Association Review, No. 114, 2014, pp. 347–360.
Esra Dardağan Kibar, “Türk Vatandaşlık Mevzuatı ve Güncel Gelişmeler Işığında Vatandaşlığın Kanuniliği İlkesi”, Milletlerarası Özel Hukukta Güncel Meseleler Sempozyumu, Savaş Yayınları, 2019, pp. 3–17.
This article has been prepared as of 19 September 2026 for general legal information purposes on the basis of legislation in force, published academic studies, accessible judicial decisions, official announcements and publicly available news sources.
Statements concerning criminal investigations reflect allegations and information made public by the relevant authorities and news sources. An investigation, detention or remand order does not constitute a final criminal conviction. The presumption of innocence applies unless and until a final conviction is entered.
The existence of an investigation concerning a developer, real estate company, intermediary or valuation expert does not, of itself, establish that every investor who dealt with those persons unlawfully acquired Turkish citizenship. Equally, an investor’s good faith does not necessarily preserve citizenship where an objective statutory requirement for acquisition was never satisfied.
Each case must be assessed individually by reference to the date of investment, the legislation then in force, the true economic substance of the investment, the individual conduct of the investor, the administration’s own examination process and the statutory basis of the measure terminating citizenship.
The legal regime governing the liquidation of assets following cancellation of citizenship under Article 33 TCL falls outside the scope of this article and will be examined separately.
This article does not constitute a legal opinion, a guarantee of outcome or individual legal advice in relation to any specific dispute.
One of the most common questions asked by foreign nationals who acquire Turkish citizenship is whether they will be required to perform compulsory military service in Türkiye.
This issue is particularly important for men who acquire Turkish citizenship through investment, marriage, long-term residence or a decision of the competent Turkish authorities.
The short answer is:
Men who acquire Turkish citizenship and are 22 years of age or older in the year in which they become Turkish citizens are, as a general rule, deemed to have completed their military service in Türkiye.
Men who are 21 or younger in the year they acquire Turkish citizenship, however, may become subject to Turkish military service unless another exemption applies.
The principal legal provision governing this issue is Article 43 of Military Recruitment Law No. 7179 (Askeralma Kanunu).
Does Everyone Who Acquires Turkish Citizenship Have to Perform Military Service?
No.
Under Article 43 of Military Recruitment Law No. 7179, the military service status of a person who subsequently acquires Turkish citizenship depends primarily on his age in the year citizenship is acquired and on other circumstances specified by law.
Two categories are particularly important.
A person may be deemed to have completed his military service if:
he is 22 years of age or older in the year in which he acquires Turkish citizenship, or
before acquiring Turkish citizenship, he completed military service in his country of origin or was legally deemed to have completed it and can provide the required evidence.
Accordingly, a person does not necessarily need to have previously served in another country’s military in order to benefit from the 22-year rule.
The Most Important Rule: How Is the Age of 22 Calculated?
This is one of the most important practical points.
For this purpose, the Turkish Ministry of National Defence does not calculate age according to whether the person’s birthday has already occurred on the exact date Turkish citizenship is acquired.
Instead, the year of birth is used.
According to the Ministry’s official guidance, the calculation is made by adding 22 to the person’s year of birth. The month and day of birth are not taken into consideration.
Example: A Man Born in 2004 Acquires Turkish Citizenship in 2026
2004 + 22 = 2026.
Therefore, a man born in 2004 who acquires Turkish citizenship at any time during 2026 falls within the 22-year rule.
Subject to the specific exceptions provided by law, he will therefore be deemed to have completed his military service.
It does not matter whether his actual birthday has occurred by the date on which Turkish citizenship is acquired.
Example: A Man Born in 2005 Acquires Turkish Citizenship in 2026
2005 + 22 = 2027.
A man born in 2005 who acquires Turkish citizenship during 2026 therefore does not yet fall within the 22-year rule.
Unless another exemption applies, he may consequently become subject to Turkish military service obligations.
Do Turkish Citizenship by Investment Applicants Have to Perform Military Service?
There is no separate military service regime specifically applicable to persons who acquire Turkish citizenship by investment.
Citizenship by investment is a form of subsequent acquisition of Turkish citizenship under the exceptional citizenship provisions of Turkish nationality legislation.
Therefore, Article 43 of Military Recruitment Law No. 7179 is also relevant to male foreign investors who acquire Turkish citizenship.
For example:
A man who acquires Turkish citizenship by investment at age 30: Generally deemed to have completed military service.
At age 25: Generally deemed to have completed military service.
At age 22: Generally deemed to have completed military service.
At age 20: May be subject to military service unless another exemption applies.
Whether citizenship was acquired through a qualifying real estate investment, bank deposit, investment fund or another qualifying investment route does not alter this basic military service rule.
Official information concerning the acquisition of Turkish citizenship is available from the Turkish Directorate General of Population and Citizenship Affairs:
Do I Need to Have Served in My Previous Country’s Military?
Not necessarily.
This is a frequent source of confusion.
Article 43 provides for different circumstances under which a person may be deemed to have completed military service.
A person who completed military service in his country of origin before becoming a Turkish citizen may rely on that service, subject to the documentary requirements.
Separately, however, a person who has never performed military service in any country may still be deemed to have completed his Turkish military service if he was 22 or older in the year he acquired Turkish citizenship.
The Turkish Ministry of National Defence provides an illustrative example in its official FAQ.
A person born in 1997 who acquired Turkish citizenship on 26 June 2019 and had not performed military service in his former country was nevertheless exempt because he was considered 22 years old in the year in which he became a Turkish citizen.
What Happens If Turkish Citizenship Is Acquired Before the Age of 22?
The position is different for men who are 21 or younger in the year they acquire Turkish citizenship.
If they cannot establish that they had already performed, or were deemed to have performed, military service in their country of origin, they may become subject to the Turkish military service system.
According to the Ministry of National Defence, their military service may, upon request, be deferred for two years from the date on which Turkish citizenship was acquired.
This two-year period should not be confused with a permanent exemption.
Once the deferment period expires, the person’s military status and recruitment procedures must be dealt with under the applicable legislation.
When Does the Two-Year Military Service Deferment Begin?
For persons who acquire Turkish citizenship subsequently and remain subject to military service, the special two-year deferment period runs from the date Turkish citizenship was acquired.
For example, if an eligible person acquires Turkish citizenship on 15 June 2026, his military service may, upon request and provided that the legal requirements are satisfied, be deferred for two years from that date.
At the end of the deferment period, the relevant military registration and examination procedures may become applicable.
Does Military Service Completed Abroad Count in Türkiye?
The timing of the foreign military service is important.
Military Service Completed Before Acquiring Turkish Citizenship
Under Article 43 of Law No. 7179, a person may be deemed to have completed his military service in Türkiye if, before acquiring Turkish citizenship, he performed military service in his country of origin or was legally deemed to have performed it and can provide the required documentation.
The Ministry of National Defence also specifies documentary requirements for foreign military service records.
Foreign-language documents may need to be translated into Turkish by a sworn translator and notarised.
Military Service Completed Abroad After Acquiring Turkish Citizenship
A different analysis applies if military service in another country is performed after Turkish citizenship has already been acquired.
Being a dual citizen and performing military service in the other country does not necessarily mean that the Turkish military service obligation is automatically discharged.
Applicable international agreements between Türkiye and the other state may also need to be examined.
Article 45 of Law No. 7179 contains provisions relevant to the recognition of military service performed in another country.
Therefore, the assumption that “I served in another country, so I am automatically exempt in Türkiye” should not be made without examining the individual’s circumstances.
What About Dual Citizens?
Dual citizenship does not, by itself, provide an exemption from Turkish military service.
The following matters may need to be considered:
when Turkish citizenship was acquired;
the person’s year of birth;
whether foreign military service was completed before or after Turkish citizenship was acquired;
the person’s country of residence;
whether an applicable international agreement exists; and
whether the individual qualifies for another deferment or military service procedure.
Turkish citizens residing abroad may also be eligible for specific deferment arrangements or foreign-currency military service (dövizle askerlik) if the statutory requirements are satisfied.
Can Someone Who Is Deemed to Have Completed Military Service Volunteer to Serve Later?
As a general rule, no.
The Ministry of National Defence states that persons who are deemed to have completed military service because they were 22 or older in the year in which they acquired Turkish citizenship are not subsequently enlisted merely because they request to serve.
This status is therefore not the same as paid military service or a temporary deferment. It is a statutory status under which the person is deemed to have completed military service.
Are Women Who Acquire Turkish Citizenship Subject to Compulsory Military Service?
No.
Law No. 7179 regulates compulsory military service for male Turkish citizens.
Accordingly, a woman who subsequently acquires Turkish citizenship does not become subject to compulsory military service merely as a consequence of acquiring Turkish citizenship.
Does the Same 22-Year Rule Apply to Citizenship Acquired Through Descent?
Not necessarily.
This is an important exception.
Article 43 of Military Recruitment Law No. 7179 specifically excludes certain persons who subsequently acquire Turkish citizenship on the basis of descent (soybağı) from the special rules contained in that provision.
Therefore, acquiring citizenship through investment, marriage or a decision of the competent authority should not automatically be treated in the same way as a citizenship case based on descent.
The legal basis on which Turkish citizenship was acquired should always be examined.
What If a Former Turkish Citizen Reacquires Turkish Citizenship?
This is another situation requiring separate analysis.
A person who was previously a Turkish citizen, lost Turkish citizenship and subsequently reacquires it should not automatically be treated in the same manner as a foreign national acquiring Turkish citizenship for the first time.
The person’s previous Turkish military service status may remain relevant.
Consequently, a former Turkish citizen who reacquires Turkish citizenship at the age of 30 cannot safely assume that he is exempt merely because he is now older than 22.
The previous citizenship and military service records should be examined.
What About the Children of a Person Who Acquires Turkish Citizenship?
The child’s date of birth and the legal basis on which the child acquired Turkish citizenship are important.
There may be a legal distinction between children who already existed when their foreign parent acquired Turkish citizenship and children born after the parent became a Turkish citizen.
Male children born after a parent has acquired Turkish citizenship may generally be treated, for military service purposes, in the same manner as Turkish citizens by birth, depending on the circumstances.
For family citizenship applications, the military status of male children should therefore be examined separately rather than assuming that the principal applicant’s exemption automatically extends to them.
How Can I Check My Military Service Status After Becoming a Turkish Citizen?
Once Turkish citizenship has been registered and a Turkish ID number has been issued, military service information can generally be checked through the Ministry of National Defence services available on e-Devlet (e-Government Gateway).
The Ministry of National Defence also allows various military recruitment procedures and document requests to be carried out electronically.
However, administrative or registration discrepancies can occur.
For example, a person may appear as subject to military service even though he should be deemed to have completed it under Article 43, or foreign military service documentation may not yet have been reflected in the relevant records.
In such cases, an application may need to be submitted to the competent military recruitment office for correction of the record.
Practical 2026 Age Table
For persons acquiring Turkish citizenship during 2026:
Born in 2004 or earlier: Generally within the 22-year rule and deemed to have completed military service, subject to the statutory exceptions.
Born in 2005: Considered below the 22-year threshold for this purpose in 2026. Military service obligations may arise unless another exemption applies.
Born in 2006: Below the 22-year threshold. Military service obligations may arise.
The critical point is that the year of birth, rather than the exact birthday, is used for this calculation.
Frequently Asked Questions
Do I have to perform military service after becoming a Turkish citizen?
If you are a man who subsequently acquires Turkish citizenship and you are 22 or older in the year citizenship is acquired, you will generally be deemed to have completed military service, subject to the exceptions provided by law.
I became a Turkish citizen at 30. Do I have to serve in the Turkish military?
If you acquired Turkish citizenship for the first time at age 30 and your case does not fall within one of the special categories, such as certain descent-based cases, you will generally be deemed to have completed military service under Article 43.
I am 22, but my birthday has not happened yet. Am I exempt?
The calculation is based on the year of birth rather than whether your birthday has occurred. The Ministry’s guidance calculates the relevant year by adding 22 to the year of birth.
I acquired Turkish citizenship by investment. Do I have to perform military service?
There is no separate military service rule for citizenship by investment. The general rules applicable to persons who subsequently acquire Turkish citizenship apply.
Can I obtain Turkish citizenship without completing military service first?
Yes. Performing Turkish military service is not a general prerequisite for acquiring Turkish citizenship. The person’s military status is determined separately following the acquisition of citizenship.
I completed military service in my home country. Do I have to serve again in Türkiye?
If you completed military service in your country of origin before acquiring Turkish citizenship, Article 43 may allow you to be deemed to have completed your military service in Türkiye, provided the relevant requirements and documentary conditions are satisfied.
Is there a two-year deferment after acquiring Turkish citizenship?
Eligible persons who remain subject to military service may request a two-year deferment calculated from the date Turkish citizenship was acquired.
I acquired citizenship after the age of 22, but e-Devlet still shows a military service obligation. What should I do?
The citizenship acquisition date, year of birth, legal basis for acquiring citizenship and existing military records should be reviewed. If the registration does not correspond with the person’s legal status, an application for correction may be required.
Conclusion
For foreign nationals who subsequently acquire Turkish citizenship, 22 is the key age for determining military service status.
However, the calculation is not based simply on the person’s exact age on the date citizenship is granted.
Under the Ministry of National Defence’s application of Article 43, the year of birth is decisive.
For example, a man born in 2004 who subsequently acquires Turkish citizenship at any time in 2026 will generally fall within the 22-year rule and be deemed to have completed his military service.
For those who acquire citizenship at 21 or younger, military service obligations may arise. A two-year deferment, previous military service abroad, dual citizenship, education and other circumstances may affect the final position.
Cases involving citizenship through descent, reacquisition of Turkish citizenship, foreign military service or family citizenship applications require particular attention and should not be assessed solely on the person’s current age.
Legal Assistance from TD Law Firm & Consultancy
Military service issues following the acquisition of Turkish citizenship can require an individual legal assessment. The date and legal basis of citizenship acquisition, year of birth, previous nationality, military service completed abroad, dual citizenship and existing records held by the Turkish authorities may all affect the outcome.
TD Law Firm & Consultancy provides legal services concerning Turkish citizenship and foreigners’ law, including the determination of military service status following naturalisation, military service exemptions and deferments, correction of inaccurate military records, applications before the competent military recruitment authorities and the assessment of military service previously completed abroad.
In particular, foreign nationals who acquire Turkish citizenship by investment are advised to verify their military service status after completion of the citizenship process.
Where e-Devlet or military recruitment records do not correspond with the person’s legal status, the matter can be reviewed and the appropriate administrative applications can be made.
Contact TD Law Firm & Consultancy
For legal assistance regarding Turkish citizenship, military service exemption, military service deferment, citizenship by investment or military registration issues, you may contact:
TD Law Firm & Consultancy Attorney Murat Can Dolğun – Istanbul Bar Association, Registration No. 75860
When contacting our office, providing your date of birth, date of acquisition of Turkish citizenship, previous nationality and information concerning any military service completed abroad will assist with the preliminary assessment of your case.
Each case must be assessed according to its individual circumstances. No exemption, deferment or particular administrative outcome can be guaranteed without reviewing the person’s citizenship and military service records.
Summary
Men who subsequently acquire Turkish citizenship and are 22 or older in the year citizenship is acquired are generally deemed to have completed military service under Article 43 of Military Recruitment Law No. 7179. The calculation is based on the year of birth rather than the exact birthday. Men who are 21 or younger may become subject to military service, although a two-year deferment may be available upon request. The same general framework applies to citizenship by investment, while citizenship through descent, reacquisition of Turkish citizenship and military service completed abroad require separate consideration.
