Turkish citizenship by investment: the document file and the role of the bank

Türkiye treats citizenship for investors as an exceptional route under Article 12 of Law No. 5901 and Article 20 of its implementing Regulation. This guide sets out the routes and thresholds in force, how the foreign currency must be sold through a bank to the Central Bank, what the three-year commitment and the conformity certificate are, and which personal documents make up the file. The decision belongs to the state.

Legal basis and who decides

Article 12(1)(b) of Law No. 5901 allows a foreigner who holds a residence permit under Article 31(1)(j) of Law No. 6458, the short-term permit for investors, to acquire citizenship by decision of the President, provided there is no obstacle of national security or public order. Article 20 of the Regulation defines which investments qualify.

The same provision covers the investor’s foreign spouse and the minor or dependent foreign children of the investor and of the spouse. Adult children who are not dependent fall outside this wording. There is one file, but each family member has a personal document set inside it.

Meeting the conditions gives no absolute right: Article 10 of the Law says so directly, and the Ministry of Interior runs the procedure and may refuse. In the texts we read, neither the Law nor Article 20 fixes a period for the decision, so any timeline you hear is practice, not law.

Investment routes and thresholds in force

Article 20(2) of the Regulation lists seven routes. Amounts are in US dollars or the equivalent in another foreign currency; since January 2022 a lira equivalent is no longer accepted. Every route except employment and fixed capital carries a three-year holding condition.

Source: Regulation, Article 20(2), read in copies of the amending decisions. The real estate minimum rose from USD 250,000 to 400,000 by Decision No. 5554 (Resmî Gazete 13.05.2022, No. 31834), in force 13.06.2022; Decision No. 7938 (12.12.2023, No. 32397) limited it to units with condominium title and land with a building. Checked 11.11.2026.

The bank: currency sale, DAB and source of funds

Under Article 20(10), the foreign currency for the real estate, deposit, government debt, fund and pension routes is sold before the transaction to a bank operating in Türkiye, which sells it on to the Central Bank (TCMB). The Central Bank sets the rules in a dedicated implementation instruction; the investment itself is then made in lira.

The bank records the sale in a foreign currency purchase certificate, Döviz Alım Belgesi (DAB). For real estate, the TKGM Guide requires the certificate to show:

• the name of the person for whom the currency was sold;
• the passport number or foreigner ID number;
• the property number, or the block, parcel and unit;
• the US dollar equivalent of the amount;
• a statement that the sale serves the acquisition of citizenship.

Before it buys the currency, the bank applies customer due diligence under Law No. 5549: identity, the origin of the money and whether the transfer matches the stated purpose. It may ask for the sale contract, dividend resolution or statements behind the incoming transfer.

Real estate: valuation report, three-year annotation, determination certificate

TKGM, the land registry directorate, checks three figures, and each must separately reach the minimum: the price in the official deed, the market value in the valuation report and the payments shown by bank receipts. The valuation report is ordered through the Web-Tapu (TADEBİS) system; reports obtained outside it are not counted.

At registration the buyer undertakes not to sell for three years, and the registry enters this commitment in the declarations section of the title record. A notarised promise-to-sell contract can also qualify if the minimum is paid up front and a three-year commitment not to assign or cancel the contract is annotated.

If the figures hold, the regional directorate issues the Real Estate Investment Determination Certificate (Taşınmaz Yatırım Tespit Belgesi). On other routes the confirmation comes from other authorities:

• deposits: BDDK;
• government debt instruments: Ministry of Treasury and Finance;
• fund units: SPK, after a block at the central registry (MKK).

Personal documents and why files come back

Article 20(3) of the Regulation lists the file compiled for each applicant. Foreign documents need an apostille or consular legalisation and a notarised Turkish translation. The core of the file:

• application form and photographs per the authority’s current checklist;
• passport or an equivalent document showing nationality;
• civil status document and, as applicable, marriage, divorce or spouse’s death certificate;
• birth certificate or civil registry extract, plus proof of family ties for spouse and children;
• receipt for the service fee.

Files mostly come back for formal defects the TKGM Guide itself names: a power of attorney lacking explicit authority for the three-year commitment, a receipt that does not refer to the DAB or shows no reasonable link to the seller, incomplete nationality or identity papers. Names spelled differently across passport, certificates and translations have the same effect.

The Law makes the investor residence permit a precondition; NVİ announced in 2018 that dedicated offices take the permit and citizenship applications together. To have the document file prepared and checked for you, contact us.

Sources

• alomaliye.com — copy of Decision No. 5554 (Resmî Gazete 13.05.2022, No. 31834) amending Article 20 of the Regulation; Law No. 5901 and Decisions No. 5072 and 7938 were read on the same site because mevzuat.gov.tr blocks automated access
• invest.gov.tr — Invest in Türkiye, “Acquiring Property and Citizenship”: routes, amounts and confirming authorities
• lexpera.com.tr — copy of the TKGM Guide on the Regulation (in force 01.02.2024): valuation report, DAB, three-year commitment, determination certificate; tkgm.gov.tr was not readable
• spk.gov.tr — Capital Markets Board: procedure for the conformity certificate on fund units, reference to the Central Bank instruction on currency sales

Questions