Abstract

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Turkish law provides several routes to exceptional naturalisation through investment.

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

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

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

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

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

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

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

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

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

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

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

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

4.1. The Sale Price and Officially Recognised Investment Amount

Consider an apartment marketed at USD 450,000.

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

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

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

4.2. Legal Suitability Before Payment

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

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

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

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

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

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

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

5.1. Agricultural Property and Undeveloped Land

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

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

5.2. Restrictions Based on Previous Ownership

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

5.3. Foreign Ownership Restrictions

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

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

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

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

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

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

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

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

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

6.1. The Chain of Ownership

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

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

6.2. Encumbrances and Legal Claims

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

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

6.3. Corporate Sellers

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

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

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

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

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

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

7.1. The Electronic Valuation System

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

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

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

7.2. September 2026 Changes to Valuation Rules

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

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

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

7.3. Twelve-Month Validity

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

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

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

7.4. Special Circumstances Involving Real Estate Investment Trusts

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

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

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

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

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

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

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

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

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

8.1. Documentary Consistency

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

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

8.2. Genuine Payment Versus Circular Transfers

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

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

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

8.3. Payment Through Third Parties

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

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

8.4. Warning Signs

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

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

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

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

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

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

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

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

9.1. Properties Acquired on Different Dates

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

9.2. Shared Ownership

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

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

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

Official source: Your Key Türkiye – Frequently Asked Questions.

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

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

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

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

10.1. Properties Under Construction

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

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

10.2. Payment and Registration Requirements

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

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

10.3. Risk of Uncompleted Developments

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

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

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

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

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

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

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

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

11.1. Sale After Three Years

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

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

11.2. Historical Irregularities

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

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

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

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

A. Bank Deposits

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

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

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

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

B. Real Estate Investment Funds and Venture Capital Investment Funds

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

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

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

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

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

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

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

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

C. Government Debt Instruments

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

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

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

D. Fixed Capital Investment

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

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

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

E. Employment Creation

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

The relevant ministry must determine compliance with the requirements.

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

F. Private Pension System

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

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

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

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

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

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

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

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

13.1. Ownership and Land Registry Examination

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

13.2. Planning and Construction Records

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

13.3. The Seller’s Legal Authority

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

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

13.4. Uncompleted Developments

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

13.5. Independent Assessment

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

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

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

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

Exceptional naturalisation through investment involves several administrative stages.

14.1. Completion of the Qualifying Investment

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

14.2. Investment Conformity Determination

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

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

14.3. Residence Permit Stage

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

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

14.4. Nationality Application

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

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

14.5. Security and Public-Order Examination

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

14.6. Final Decision

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

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

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

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

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

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

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

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

15.1. Age and Dependency

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

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

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

15.2. Marriage and Family Documentation

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

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

15.3. Family Changes During the Application

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

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

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

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

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

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

16.1. Powers of Attorney

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

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

16.2. Powers of Attorney Issued Abroad

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

Certified Turkish translations and additional formalities may also be required.

16.3. Procedures Requiring Personal Attendance

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

19.3. The Importance of Good Faith

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

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

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

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

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

XX. Which Contractual Safeguards Should Protect a Foreign Investor?

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

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

20.1. Representations Concerning Legal Eligibility

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

20.2. Conditions Precedent to Payment

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

20.3. Remedies for Contractual Non-Compliance

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

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

20.4. Secure Payment Arrangements

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

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

20.5. The Limits of Contractual Guarantees

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

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

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

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

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

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

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

21.1. Administrative Judicial Review

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

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

21.2. Contractual and Financial Remedies

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

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

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

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

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

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

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

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

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

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

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

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

3. Can I qualify by purchasing undeveloped land?

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

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

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

5. Can I sell my property after three years?

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

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

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

7. Can I complete the process without visiting Türkiye?

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

8. How long does the citizenship application take?

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

9. Can my spouse and children obtain citizenship?

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

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

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

11. Is relying on the official valuation company sufficient?

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Legislation, Official Sources and Academic References

1. Turkish Citizenship Law No. 5901. Particularly Articles 12, 31 and 40. Official legislation.
2. Regulation on the Implementation of the Turkish Citizenship Law. Particularly Article 20 and the relevant amendments.
3. Land Registry Law No. 2644. Particularly Articles 35 and 36.
4. Law No. 6458 on Foreigners and International Protection. Particularly Article 31(1)(j).
5. General Directorate of Land Registry and Cadastre. Circular No. 2024/4, including amendments applicable in September and October 2026, concerning citizenship through real estate acquisition and investment amount determination. Your Key Türkiye.
6. General Directorate of Land Registry and Cadastre. Circular No. 2024/2 and relevant valuation procedures. Official TTB information.
7. Directorate General of Population and Citizenship Affairs. Citizenship Services – Frequently Asked Questions. Official information.
8. Invest in Türkiye. Acquiring Property and Citizenship – Investment Guide. Official English-language guide.
9. Capital Markets Board of Türkiye. Exceptional Acquisition of Turkish Citizenship Through Investment. Official regulatory guidance.
10. Özgür, Çiçek. “Yatırım Yoluyla Kazanılan Türk Vatandaşlığının İptali ve Geri Alınması” [Cancellation and Withdrawal of Turkish Citizenship Acquired Through Investment]. Ankara Üniversitesi Hukuk Fakültesi Dergisi, Vol. 75, No. 1, 2026, pp. 741–779. DOI: 10.33629/auhfd.1710185.
11. Dülger, Ahmet. “Taşınmaz Satın Alınmasıyla Türk Vatandaşlığının İstisnai Yoldan Kazanılmasında Değerleme Raporu ve Uygunluk Belgesi Alınması” [Valuation Reports and Certificates of Conformity in Exceptional Turkish Citizenship Acquisition Through Property Purchase]. İnönü Üniversitesi Hukuk Fakültesi Dergisi, Vol. 16, No. 1, 2025, pp. 167–180. DOI: 10.21492/inuhfd.1600688.
12. Administrative Judicial Procedure Law No. 2577. Particularly Articles 7, 11 and 27, concerning filing periods, administrative applications and suspension of execution.

Related Publications by Dolğun Akademi

This article concludes our five-part 2026 research series on Turkish citizenship revocation, legal status verification, criminal investigations, protection of genuine investors and citizenship-by-investment requirements.

Five-Part Turkish Citizenship Law Series

1. Turkish Citizenship Revocations in 2026: Official Figures and International Media Coverage.
2. Has My Turkish Citizenship Been Cancelled? Official Records, Notification, Passports and Legal Remedies.
3. Turkish Citizenship Revocation and Criminal Investigations: KYOK, Acquittal and Administrative Litigation.
4. Can a Genuine Investor Lose Turkish Citizenship? Property Valuation, Banking Evidence and Judicial Protection.
5. Turkish Citizenship by Investment in 2026: Requirements, Legal Safeguards and Revocation Risks. This article.

Earlier Academic and Legal Research

September 19, 2026 – Cancellation and Withdrawal of Turkish Citizenship Acquired Through Investment.

September 26, 2026 – The Citizenship Investigation Involving 1,070 Individuals.

September 28, 2026 – Property Valuations, Investment Shortfalls, Families and Investigated Construction Companies.