Introduction
The pharmacy licensing procedure in Turkey is a strictly regulated administrative process governed by healthcare law, pharmacy legislation and public health principles. A pharmacy in Turkey is not considered an ordinary commercial shop. It is a licensed healthcare institution operated under the professional responsibility of a pharmacist. Therefore, opening a pharmacy requires more than renting a workplace, purchasing pharmaceutical stock and registering a business. It requires legal eligibility, administrative authorization, compliance with population-based pharmacy planning, proper documentation, premises suitability and approval by the competent health authorities.
The main statute governing pharmacies in Turkey is Law No. 6197 on Pharmacists and Pharmacies. This law defines pharmacy practice as opening and operating pharmacies, pharmaceutical warehouses, medicine cabinets, laboratories and similar institutions, preparing pharmaceutical products or acting as responsible manager in such institutions. The law also sets out the basic qualifications required to practice pharmacy in Turkey.
In addition to Law No. 6197, the Regulation on Pharmacists and Pharmacies regulates the practical aspects of pharmacy opening, relocation, transfer, licensing, inspection, premises requirements and pharmacy services. The regulation contains a specific section titled “Procedures and Principles Regarding the Opening, Relocation and Transfer of Pharmacies,” which includes rules on pharmacy opening criteria, initial application and placement, required documents, sham ownership review and license issuance.
For pharmacists, investors, foreign healthcare professionals and legal advisors, understanding the licensing procedure is essential. A mistake at the licensing stage may result in loss of placement rights, rejection of the application, administrative delay, financial loss or future disputes regarding ownership and operation.
Legal Framework of Pharmacy Licensing in Turkey
The pharmacy licensing procedure in Turkey is primarily based on three pillars. The first is professional eligibility under Law No. 6197. The second is population-based placement and administrative application under the Regulation on Pharmacists and Pharmacies and the Eczacı Yerleştirme Sistemi, known as EYS. The third is license issuance and approval by the provincial health directorate and governorate.
Law No. 6197 provides that a person who wishes to open, sell or relocate a pharmacy must apply to the competent health authority. The law also lists basic documents historically required for opening a pharmacy, including identity documentation, diploma copy, curriculum vitae, criminal record documentation, health report and photographs. Once the file is complete, the health authority examines the documents and issues the license within the legal framework.
The Regulation on Pharmacists and Pharmacies provides more detailed and modern procedural rules. It states that pharmacies are regulated according to district population, generally on the basis of at least one pharmacy per 3,500 people. It also states that the Turkish Medicines and Medical Devices Agency, TİTCK, determines and announces three times per year the districts where pharmacies may be opened and the number of pharmacies that may be opened, based on population data.
This means that pharmacy licensing in Turkey is not merely a document submission process. It is a combined system involving professional status, population quota, electronic placement, health authority review, chamber of pharmacists involvement, premises inspection and final administrative approval.
Who Can Apply for a Pharmacy License in Turkey?
The first legal condition for obtaining a pharmacy license is being legally entitled to practice pharmacy in Turkey. Law No. 6197 requires Turkish citizenship, graduation from a Turkish pharmacy school or faculty or recognition of foreign pharmacy education under the applicable legal procedure, registration of the diploma by the health authority and absence of legal obstacles to practicing pharmacy.
This rule is very important because a pharmacy license cannot be obtained by an ordinary investor, a commercial company or a non-pharmacist entrepreneur. Private pharmacy ownership and operation are tied to the professional status of the pharmacist. The pharmacist is not simply an employee; the pharmacist is the license holder and professional responsible person.
Law No. 6197 also restricts certain persons from opening or managing pharmacies. For example, civil servants and soldiers cannot open a pharmacy or act as responsible manager of a pharmacy, except in limited temporary situations. The law also prohibits a pharmacist from opening more than one pharmacy or assuming responsible management of more than one pharmacy.
Therefore, before beginning the licensing procedure, the applicant must confirm that they satisfy all professional eligibility requirements. If the applicant lacks pharmacist status, citizenship, diploma recognition, diploma registration or legal capacity, the licensing process cannot proceed successfully.
The Role of EYS in Pharmacy Licensing
One of the most important stages in the pharmacy licensing procedure in Turkey is the Eczacı Yerleştirme Sistemi, commonly referred to as EYS. EYS is the electronic placement system used for pharmacists who wish to open a new pharmacy or relocate an existing pharmacy where population-based restrictions apply.
The EYS Guide states that it was prepared to determine the procedures and principles for electronic applications made by pharmacists who wish to open or relocate pharmacies under the Regulation on Pharmacists and Pharmacies. The guide also states that it covers applications made through EYS by pharmacists subject to restrictions on opening and relocating pharmacies according to population under Law No. 6197.
According to the EYS Guide, there are three application periods each year. These periods are determined by TİTCK and announced on the official website of the agency or on the separate EYS platform. The application period is thirty days from the announcement date, although TİTCK may change application dates when necessary and announce such changes officially.
The EYS system makes pharmacy licensing more structured and competitive. Pharmacists cannot simply choose any district and apply whenever they wish. They must monitor official announcements, check available quotas, submit their electronic application within the announced period and participate in the placement process according to their service and placement points.
Population-Based Pharmacy Quota
A central feature of the pharmacy licensing procedure in Turkey is the population-based quota system. The Regulation on Pharmacists and Pharmacies provides that the number of private pharmacies is regulated according to district population on the basis of at least one pharmacy per 3,500 people. The regulation also states that the population criterion is not applied for relocations within the same district.
The same regulation provides an exception for places where there is no pharmacy. In settlements without any pharmacy, one pharmacy may be opened without applying the population criterion. However, if a pharmacy opened under this exception is later relocated outside the permitted settlement, the population criterion will apply.
The EYS Guide further explains that population data used to determine districts where pharmacies may be opened is obtained from the Turkish Statistical Institute. It also states that one pharmacy quota is opened for districts with a population below 3,500 if there is no pharmacy in that district.
This system has a major practical consequence: a pharmacist may be fully qualified but still unable to open a pharmacy in a desired district if there is no available quota. For this reason, location planning must begin with EYS and quota analysis, not with lease negotiations.
Step One: Checking Professional Eligibility
The first practical step in the licensing procedure is confirming the pharmacist’s professional eligibility. The applicant must verify citizenship, pharmacy diploma, diploma registration, absence of legal obstacles and any special requirements related to assistant pharmacy or professional service.
Law No. 6197 sets out the general conditions for practicing pharmacy in Turkey, including Turkish citizenship, a pharmacy diploma or recognized foreign equivalent, diploma registration and absence of statutory obstacles.
This stage is especially important for pharmacists with foreign education. A Turkish citizen who graduated from a foreign pharmacy faculty may need to prove equivalence or satisfy additional examination procedures before practicing pharmacy in Turkey. A foreign national who does not meet the statutory conditions cannot assume that foreign pharmacy experience alone is sufficient.
Professional eligibility should be confirmed before any financial commitment. A pharmacist should not sign a lease, purchase pharmacy furniture, enter into a transfer protocol or pay a deposit before ensuring that they are legally entitled to apply for a pharmacy license.
Step Two: Following EYS Announcements
After professional eligibility is confirmed, the pharmacist should follow EYS announcements. TİTCK announces application periods and available districts. The EYS Guide provides that the institution determines three application periods each year and announces them through the official website or EYS-specific platform. The application period is thirty days from the announcement date.
At this stage, the pharmacist should examine the districts where pharmacy opening is permitted, the number of available quotas, the expected level of competition, service points and placement criteria. Since placement depends on calculated points and preference order, the application must be prepared carefully.
Incorrect preference order, incomplete electronic information or failure to apply within the deadline may cause the pharmacist to lose an opportunity. In practice, pharmacists should prepare documents and strategic preferences before the application period ends.
Step Three: Placement and Opening Right
After applications are completed, placement is made according to the rules set out in the Regulation on Pharmacists and Pharmacies. The regulation provides that, after the application period ends, placement points are calculated within ten business days, and placement is made according to the pharmacist’s placement point and preference order. Pharmacists with the highest placement points obtain the right to open a pharmacy in the announced places. If applicants have equal placement points, a draw is held before a notary.
The placement list is notified to the provincial health directorate and announced on the official website of the institution. If places remain vacant, a second placement is made within thirty days.
Placement is not the same as receiving a license. It gives the pharmacist the right to continue with the licensing process for the relevant district or location. The pharmacist must then submit the required original documents and additional documents to the competent health authority within the legal time limit.
Step Four: Submission of Required Documents
Once the pharmacist obtains the right to open a pharmacy through placement, the next stage is document submission. The Regulation on Pharmacists and Pharmacies provides that pharmacists who are entitled to open a pharmacy after placement must apply to the relevant provincial or district health directorate within ninety days from the announcement date, together with the originals of the documents entered electronically during the first application and additional documents required by the regulation.
The regulation lists several required documents, including the chamber of pharmacists registration certificate, a plan of the premises prepared by an architect or engineer, a report prepared by the regional chamber of pharmacists regarding compliance with pharmacy legislation and approved after on-site inspection by the provincial health directorate, and a building permit, occupancy permit or official document from the relevant municipality showing that the premises may be used as a shop or workplace.
This stage is critical. The regulation states that if the pharmacist fails to apply within the deadline without force majeure or submits incomplete documents, the pharmacist loses the pharmacy opening right obtained through placement and cannot apply for placement in the next institutional announcement.
Step Five: Premises Suitability Review
The pharmacy premises must be legally and technically suitable. A pharmacy is not any ordinary shop. It must be suitable for medicine storage, patient service, professional supervision, pharmaceutical safety and inspection.
Law No. 6197 provides that the physical structure of pharmacy buildings, laboratory features, required equipment and internal services are determined by the health authority.
The Regulation on Pharmacists and Pharmacies contains a separate section on pharmacy locations and sections, including the characteristics of premises to be used as pharmacies, laboratory section, cabinets for poisonous substances, renovations, technical facilities, pharmacy name, signboard and display window.
For this reason, premises review should be conducted before signing a lease. If the premises cannot be approved by the chamber of pharmacists and provincial health directorate, the licensing process may fail even if the pharmacist has obtained a placement right. The safest approach is to conduct legal and technical due diligence before committing to rent, renovation or purchase.
Step Six: Sham Ownership Review
A distinctive element of the pharmacy licensing procedure in Turkey is the muvazaa, or sham ownership, review. The Regulation on Pharmacists and Pharmacies states that after the provincial health directorate notifies the regional chamber of pharmacists about the opening or relocation application, the regional chamber prepares a sham ownership assessment report within fifteen business days and submits it to the provincial health directorate with concrete information and documents. The provincial health directorate then makes a decision within fifteen business days from receipt of the report or expiration of the report period.
This review is very important because Turkish law does not allow hidden pharmacy ownership by non-pharmacists. A pharmacy cannot be formally licensed in the name of a pharmacist while being economically or operationally controlled by another person, investor or company.
The sham ownership review may examine whether the pharmacist is the genuine owner and responsible operator, whether there is hidden financing or control, whether a third party is effectively running the pharmacy, and whether the arrangement complies with the professional ownership model. Any suspicious structure may delay or jeopardize the license.
Step Seven: License Issuance and Governorate Approval
After the application file is reviewed, required assessments are completed and necessary fees are paid, the pharmacy license is issued. The Regulation on Pharmacists and Pharmacies provides that after the provincial health directorate examines applications made according to placement results and completes evaluations, the pharmacy license is prepared after payment of the required fees, approved by the governorate and delivered to the pharmacist. The issued licenses are regularly notified to TİTCK and the Turkish Pharmacists’ Association at the end of each month.
The same regulation states that if issued licenses are not collected by pharmacists within thirty days, except in cases of force majeure, they are cancelled. It also provides that problems concerning licenses are resolved by the institution.
The Ministry of Health circular on pharmacy applications and licensing also states that before the license is issued, approval for license preparation is obtained upon the proposal of the provincial health director and the approval of the governorate; the prepared license is signed jointly by the health directorate and governorate and sealed.
Is a Separate Municipal Workplace License Required?
One practical advantage in pharmacy licensing is that a separate municipal workplace license is not required after the pharmacy license is issued. The Regulation on Pharmacists and Pharmacies provides that pharmacies for which a license has been issued do not need to obtain a separate workplace license from the municipality, pay a municipal fee or obtain any additional registration or approval certificate from another institution.
This does not mean that the premises may ignore municipal documentation entirely. At the application stage, the regulation requires a building permit, occupancy permit or official municipal document showing that the premises may be used as a shop or workplace.
Therefore, municipal suitability matters at the document stage, but the pharmacy license itself replaces the need for a separate municipal workplace license after approval.
Common Reasons for Licensing Problems
The most common problems in the pharmacy licensing procedure include failure to satisfy pharmacist eligibility, missing EYS application deadlines, choosing a district without quota, submitting incomplete documents, failing to apply within ninety days after placement, selecting unsuitable premises, inability to obtain chamber of pharmacists approval, municipal documentation problems and sham ownership concerns.
Another frequent problem is signing a lease too early. A pharmacist may rent premises before confirming quota, placement, physical suitability and legal documentation. If the license is not issued, the pharmacist may remain liable under the lease while being unable to operate a pharmacy.
A further risk is hidden investor involvement. If a non-pharmacist finances and controls the pharmacy while the pharmacist is only formally shown as the license holder, the sham ownership review may create serious problems. Even if the license is initially obtained, later inspection may still lead to administrative action.
Pharmacy Licensing and Transfer Situations
The licensing procedure is not limited to newly opened pharmacies. Pharmacy transfer may also require license procedures. Law No. 6197 states that a person who acquires a pharmacy may receive a license in their own name if they satisfies the legal conditions for opening a pharmacy, and that sales are carried out before the government physician and notary.
This means that a pharmacy cannot be sold to a non-pharmacist as an ordinary business. The buyer must be legally eligible to obtain a pharmacy license. Transfer due diligence should include license status, stock, controlled medicines, lease rights, SGK risks, employee obligations, tax liabilities and potential inspection findings.
The law also requires notification to the highest local health authority regarding the transfer or sale of narcotic substances located in the transferred pharmacy.
Pharmacy Relocation and Licensing
Relocation is another area connected to licensing. Law No. 6197 provides that a pharmacist who wishes to close, relocate or change the name of a pharmacy must notify the highest local health authority one month in advance.
The Regulation on Pharmacists and Pharmacies provides that population criteria are not applied to relocations within the same district, but the rules may apply when a pharmacy moves outside the permitted area or when special exceptions are involved.
Therefore, relocation should not be treated as a purely commercial decision. The pharmacist must review population rules, premises suitability, notification obligations, licensing amendments and practical approval procedures before moving the pharmacy.
Post-License Compliance Obligations
Obtaining a pharmacy license is not the end of the legal process. After the license is issued, the pharmacist must operate the pharmacy in accordance with prescription rules, record-keeping duties, medicine storage standards, inspection requirements, İTS procedures, SGK reimbursement rules and professional ethics.
Law No. 6197 prohibits supplying prescription-only medicines without prescription and states that medicines prepared in the pharmacy must be prepared without alteration of the prescription. The law also provides that the responsible manager is directly responsible for errors in medicines prepared in the pharmacy.
The law further requires pharmacies to maintain a daily prescription register in the prescribed form and preserve these registers for five years.
This means that a pharmacy may have a valid license but still face serious legal risks if it fails to comply with operational rules. Licensing must therefore be understood as the beginning of continuous regulatory responsibility.
Practical Checklist for Pharmacy Licensing in Turkey
A pharmacist planning to obtain a pharmacy license in Turkey should follow a careful checklist. First, professional eligibility must be confirmed under Law No. 6197. Second, EYS announcements must be monitored. Third, available district quotas must be reviewed. Fourth, the electronic application must be completed within the announced period. Fifth, placement results must be followed. Sixth, the pharmacist must apply to the provincial or district health directorate within ninety days after placement with complete documents. Seventh, premises suitability must be confirmed through chamber and health authority review. Eighth, sham ownership concerns must be avoided. Ninth, required fees must be paid. Finally, the license must be collected within the legal period after governorate approval.
This checklist should be completed before major financial commitments. Legal due diligence is especially important before lease agreements, pharmacy transfer protocols, investor arrangements or relocation decisions.
Conclusion
The pharmacy licensing procedure in Turkey is a detailed administrative process based on professional pharmacist eligibility, population-based placement, documentary compliance, premises suitability, chamber review, sham ownership assessment and governorate-approved licensing. It reflects the Turkish legal policy that pharmacies are healthcare institutions, not ordinary commercial stores.
A pharmacist who wishes to open a pharmacy must first satisfy the conditions for practicing pharmacy under Law No. 6197. The pharmacist must then follow EYS announcements, apply within the proper period, obtain placement rights where applicable, submit complete documents within ninety days, prove premises suitability and pass the necessary administrative evaluations.
The most important practical risks are missing deadlines, selecting an unsuitable location, submitting incomplete documents, relying on hidden investor arrangements and signing commercial agreements before confirming licensing feasibility. These risks can be avoided through proper legal planning.
For pharmacists, pharmacy licensing in Turkey should be approached as both a legal and administrative project. For investors and foreign parties, the Turkish system must be understood as pharmacist-centered and restrictive. A legally secure pharmacy licensing process requires compliance with Law No. 6197, the Regulation on Pharmacists and Pharmacies, EYS procedures, provincial health directorate practice and professional ethics.
In a sector directly connected to public health, pharmacy licensing is not a formality. It is the legal foundation of safe, accountable and sustainable pharmacy practice in Turkey.
Yanıt yok