Author: Attorney Murat Can Dolğun – Istanbul Bar Association

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

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

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

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reported that citizenship acquisition decisions concerning a total of 6,134 individuals had previously been annulled or withdrawn through various administrative procedures.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

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mentioned in a criminal investigation does not establish that an individual’s Turkish citizenship has been cancelled or withdrawn.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

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

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

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

Table of Contents

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

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

September 2025: An Earlier Major Citizenship Investigation

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

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

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

August 4, 2026: Investigation Involving 687 Citizenship Acquisitions

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

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

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

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

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

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

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

September 25, 2026: Further Judicial Measures

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

5. Unconfirmed Verbal Information Concerning Investigation Procedures in October 2026

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

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

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

5.1. Reports of Temporary Suspension of Certain Police Interviews

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

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

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

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

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

5.2. Reports Concerning the Separation of Investigation Files

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

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

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

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

5.3. Different Stages of Administrative Citizenship Proceedings

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

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

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

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

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

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

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

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

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

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

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

7. Annulment of Turkish Citizenship Under Article 31 and Withdrawal Under Article 40

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

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

7.1. Annulment of Citizenship – Article 31

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

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

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

7.2. Withdrawal of Citizenship Acquisition Decisions – Article 40

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Such facts may be extremely important to a legal defence.

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

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

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

Three separate matters must therefore be examined:

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

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

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

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

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

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

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

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

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

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

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

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

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

Not necessarily.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

11.3. What Can Be Learned from These Two Judgments?

These decisions should be read together.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Step 1: Establish the Current Citizenship Status

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

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

Step 2: Identify the Criminal Investigation and Its Scope

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

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

Step 3: Reconstruct the Investment Transaction

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

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

Step 4: Verify the Source and Movement of Funds

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

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

Step 5: Examine the Property’s Historical Value

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

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

Step 6: Coordinate Administrative and Criminal Defence

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

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

Step 7: Pursue Appropriate Administrative and Judicial Remedies

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

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

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

Step 8: Continue Reviewing Material Developments

Citizenship and criminal files can evolve over time.

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

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

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

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

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

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

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

18.1. Time Limits for Judicial Review

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

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

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

18.2. Can the Court Suspend the Citizenship Decision?

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

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

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

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

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

19. Frequently Asked Questions About Turkish Citizenship Revocation in 2026

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

19. Can I challenge an inaccurate retrospective property valuation?

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

20. What is the most important first step?

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

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

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

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

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

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

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

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

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

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

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

Legal Assessment of Turkish Citizenship and Investment Investigations

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

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

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

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

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

A. Legislation and Official Regulations

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

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

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

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

B. Academic Publications

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

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

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

C. Decisions of the Council of State (Danıştay)

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

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

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

D. Official Statements and News Reports

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

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

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

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

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

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

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

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

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

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

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

22. Previously Published Research on Turkish Citizenship Law – Dolgun Akademi

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

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

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

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

All related publications: Dolgun Akademi – Citizenship Law.

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