Etiket: Turkish citizenship criminal investigation

  • Turkish Citizenship Criminal Investigations 2026 | KYOK

    Turkish Citizenship Criminal Investigations 2026 | KYOK

    DOLĞUN AKADEMİ | LEGAL RESEARCH

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

    Author: Attorney Murat Can Dolğun – Istanbul Bar Association

    Original Publication: October 22, 2026

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

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

    Abstract

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

    2. Developments in Turkish Citizenship Investigations During 2025–2026

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

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

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

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

    Source: Anadolu Agency, September 24, 2025.

    2.2. August 4, 2026: Investigation Concerning 687 Individuals

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

    4.1. Suspect

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

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

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

    4.2. Witness

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

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

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

    4.3. Complainant and Victim

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

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

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

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

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

    4.4. Different Procedural Roles Within One Investigation

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

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

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

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

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

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

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

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

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

    5.2. Migrant Smuggling – Article 79

    Article 79 regulates migrant smuggling.

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

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

    5.3. Fraud and Aggravated Fraud – Articles 157 and 158

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

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

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

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

    5.4. Forgery of Official Documents – Article 204

    Article 204 concerns forgery involving official documents.

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

    5.5. Forgery of Private Documents – Article 207

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

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

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

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

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

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

    5.7. Multiple Charges Arising from the Same Transaction

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

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

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

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

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

    6.1. The Right to Be Informed of the Accusation

    The suspect must be informed of the alleged offence.

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

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

    The nature of the defence depends on those distinctions.

    6.2. The Right to Legal Counsel

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

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

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

    6.3. The Right to Remain Silent

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

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

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

    6.4. The Right to Request Favourable Evidence

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

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

    6.5. Accuracy of the Written Statement

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

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

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

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

    6.6. Police Statements Taken Without Defence Counsel

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

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

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

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

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

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

    7.1. Incorrect Translation of Legal and Financial Terminology

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

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

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

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

    7.2. Challenging an Incorrect Interpretation

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

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

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

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

    8.1. Confidentiality of Criminal Investigations

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

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

    8.2. Article 153 and File Inspection

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

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

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

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

    8.3. Investigation Files Not Visible Through UYAP

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

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

    8.4. Representation and Authorisation

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

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

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

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

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

    9.1. Summons for Questioning

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

    A summons and an arrest warrant are different procedural measures.

    9.2. Arrest and Apprehension

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

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

    9.3. Police Custody

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

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

    9.4. Pretrial Detention

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

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

    9.5. Judicial Supervision

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

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

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

    9.6. Assessing Border-Control Risks

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

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

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

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

    10.1. Bank Transfers

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

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

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

    10.2. Land Registry and Sale Documents

    Registration of a property transfer is an important legal fact.

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

    10.3. Valuation Reports

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

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

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

    10.4. MASAK Financial Analyses

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

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

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

    10.5. Digital Evidence

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

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

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

    11. How Can Expert Reports Be Examined or Challenged?

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

    11.1. The Scope and Methodology of the Expert Report

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

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

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

    11.2. Independent Expert Opinions

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

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

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

    11.3. Historical Value Versus Current Market Value

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

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

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

    11.4. Preservation of Evidence and Expert Assessment

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

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

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

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

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

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

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

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

    12.1. Insufficient Evidence to Establish the Required Suspicion

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

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

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

    12.2. Legal Impossibility of Prosecution

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

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

    12.3. KYOK Is Not an Acquittal

    KYOK is a prosecutorial decision issued during the investigation stage.

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

    12.4. Objections to a Non-Prosecution Decision

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

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

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

    12.5. New Evidence Following KYOK

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

    13.4. Does KYOK Automatically Restore Citizenship?

    No.

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

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

    14. What Happens If the Prosecutor Files an Indictment?

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

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

    14.1. An Indictment Is Not Proof of Guilt

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

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

    14.2. Distinguishing Criminal Allegations

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

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

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

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

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

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

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

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

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

    15.1. An Acquittal Does Not Automatically Annul Administrative Withdrawal

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

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

    15.2. The Presumption of Innocence

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

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

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

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

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

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

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

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

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

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

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

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

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

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

    16.3. Different Temporal Consequences

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

    The court dismissed the action challenging the withdrawal of citizenship.

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

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

    17.3. Comparative Legal Assessment

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

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

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

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

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

    18. Administrative Litigation Against Turkish Citizenship Cancellation or Withdrawal

    18.1. The Competent Court

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

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

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

    18.2. Filing Deadlines

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

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

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

    18.3. Administrative Applications

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

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

    18.4. Suspension of Execution

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

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

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

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

    18.5. Use of Criminal Evidence in Administrative Litigation

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

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

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

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

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

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

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

    19.1. Establish the Current Official Status

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

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

    19.2. Prepare a Chronology of the Investment

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

    19.3. Identify Individual Conduct

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

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

    19.4. Preserve Documents and Financial Evidence

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

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

    19.5. Distinguish Technical Findings from Criminal Intent

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

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

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

    19.6. Protect Independent Administrative Deadlines

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

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

    20. Frequently Asked Questions About Turkish Citizenship and Criminal Investigations

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

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

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

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

    Can I have a lawyer present during questioning?

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

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

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

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

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

    Will KYOK guarantee that I retain Turkish citizenship?

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

    Can a KYOK decision support my citizenship case?

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

    Will an acquittal automatically reverse a citizenship withdrawal?

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

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

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

    I genuinely paid for the property. Is that enough?

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

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

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

    Does filing a citizenship lawsuit automatically suspend the administrative decision?

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

    Is every purchaser from an investigated developer considered a suspect?

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

    Does living abroad stop a Turkish criminal investigation?

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

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

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

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

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

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

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

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

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

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

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

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

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

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

    23. Legislation, Case Law and References

    A. Constitutional and Statutory Sources

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

    B. Council of State Decisions

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

    C. Official Announcements and News Reporting

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

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

    About the Author

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

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

    Contact Information

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

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

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

    © 2026 DOLĞUN AKADEMİ | ATTORNEY MURAT CAN DOLĞUN

  • Has My Turkish Citizenship Been Cancelled? 2026

    Has My Turkish Citizenship Been Cancelled? 2026

    DOLĞUN AKADEMİ | TURKISH CITIZENSHIP LAW

    Has My Turkish Citizenship Been Cancelled? 2026 Legal Review of Official Records, Notification, Passports, Family Rights and Entry into Türkiye

    Author: Attorney Murat Can Dolğun – Istanbul Bar Association

    Original Publication: October 22, 2026

    Fields: Turkish Citizenship Law, Administrative Law, Immigration Law, Criminal Procedure and Private International Law.

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

    Abstract

    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.

    For the broader statistical and international context, see our 2026 study on official citizenship revocation figures and international media coverage.

    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.

    Official e-Devlet Population Registration Extract Service.

    4.2. Citizenship Application Enquiries

    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.

    Directorate General of Population and Citizenship Affairs – e-Devlet Services.

    4.3. Turkish Identity Numbers

    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.

    Statutory source: Administrative Judicial Procedure Law No. 2577.

    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.

    Council of State – Full Decision, E.2024/3835, K.2026/324.

    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.

    Council of State – Full Decision, E.2024/405, K.2026/361.

    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.

    Council of State – Full Decision, E.2025/6295, K.2025/7133.

    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.

    For a detailed assessment, see Turkish Citizenship Cancellation and Criminal Investigations in 2026: KYOK, Acquittal and Judicial Remedies.

    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.

    Related study: Citizenship Withdrawal, Family Members, Children and Investment Valuation.

    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.

    Law No. 6458 on Foreigners and International Protection.

    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.

    Republic of Türkiye – Consular Information.

    17.3. Scope of Authorisation

    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.

    22. Legislation, Official Records and Judicial References

    A. Constitutional and Statutory Materials

    1. Constitution of the Republic of Türkiye, particularly Articles 16, 23, 35, 36, 40, 66 and 125. Official Constitutional Text.
    2. Turkish Citizenship Law No. 5901, particularly Articles 7, 12, 29, 31, 32, 33, 36, 37, 40 and 41. Ministry of Justice – Legislation Portal.
    3. Regulation on the Implementation of the Turkish Citizenship Law, particularly Articles 20 and 66.
    4. Administrative Judicial Procedure Law No. 2577, particularly Articles 7, 8, 10, 11 and 27. Statutory Text.
    5. Council of State Law No. 2575, Article 24.
    6. Notification Law No. 7201.
    7. Law No. 6458 on Foreigners and International Protection. Official Gazette, April 11, 2013.

    B. Council of State Decisions

    1. 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.
    2. 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.
    3. Council of State, 10th Chamber, E.2025/6295, K.2025/7133, December 30, 2025. Notification to legal counsel and judicial filing deadlines. Full Decision.

    C. Official Administrative Resources

    1. Directorate General of Population and Citizenship Affairs – e-Devlet Services.
    2. Official Population Registration Extract Service.
    3. Turkish Consular Services and Powers of Attorney.
    4. Ministry of Justice, August 4, 2026 – Citizenship Investigation Announcement.

    About the Author

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

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

    Contact Information

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

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

    Legal Disclaimer: This publication is intended for general legal and academic information. It does not constitute individual legal advice or guarantee the outcome of citizenship, immigration, criminal or administrative litigation. The applicable law, administrative record, notification history and individual case circumstances must be examined before taking legal action. Judicial decisions discussed above are assessed according to the information available at the research date; subsequent appeals or changes in law must be checked separately.

    © 2026 DOLĞUN AKADEMİ | ATTORNEY MURAT CAN DOLĞUN

  • REVOCATION AND WITHDRAWAL OF TURKISH CITIZENSHIP IN 2026: FREQUENTLY ASKED QUESTIONS, CRIMINAL INVESTIGATIONS, LITIGATION AND FILE REVIEW

    REVOCATION AND WITHDRAWAL OF TURKISH CITIZENSHIP IN 2026: FREQUENTLY ASKED QUESTIONS, CRIMINAL INVESTIGATIONS, LITIGATION AND FILE REVIEW

    Updated: 28 September 2026

    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

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

    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.