Introduction
The population-based pharmacy planning system in Turkey is one of the most important legal mechanisms regulating the opening and distribution of private pharmacies. Under Turkish pharmacy law, a pharmacist cannot freely open a pharmacy in any desired district, street or commercial area. Pharmacy openings are subject to population criteria, district-based quotas, electronic placement procedures and administrative approval by health authorities.
This system reflects the special legal nature of pharmacies in Turkey. A pharmacy is not considered an ordinary retail business. It is a healthcare institution where medicines are supplied under the professional responsibility of a pharmacist. For this reason, pharmacy planning is not left entirely to market competition. The Turkish legal framework aims to ensure balanced access to medicines, prevent excessive concentration of pharmacies in commercially attractive areas and protect the professional structure of pharmacy practice.
The main legal sources governing this system are Law No. 6197 on Pharmacists and Pharmacies, the Regulation on Pharmacists and Pharmacies, and the Eczacı Yerleştirme Sistemi, commonly known as EYS. Law No. 6197 defines pharmacy as a healthcare service and states that opening and operating a pharmacy requires being a pharmacist. The Regulation on Pharmacists and Pharmacies further provides that private pharmacy numbers are regulated according to district population, generally on the basis of at least one pharmacy per 3,500 people.
Legal Nature of Pharmacy Planning in Turkey
The population-based pharmacy planning system is not merely an administrative preference. It is a legal policy choice based on public health, equal access to medicines and professional regulation. Unlike ordinary businesses, pharmacies operate in a sector where excessive competition, hidden ownership, uncontrolled expansion and commercial pressure may negatively affect public health.
The Regulation on Pharmacists and Pharmacies states that its purpose is to determine pharmacists’ duties, powers and responsibilities and to regulate the opening, operation, relocation, transfer and closure of pharmacies, as well as the characteristics of pharmacies and pharmacy services. This shows that pharmacy planning is part of a broader regulatory framework, not an isolated licensing formality.
The system is also connected to the pharmacist-based ownership model. Turkish law requires that private pharmacies be opened and operated under pharmacist responsibility. Therefore, when the state limits the number of pharmacies by population and district, it is also controlling how professional pharmacy services are distributed across the country.
The 3,500-Person Rule
The central rule of the population-based pharmacy planning system is the 3,500-person rule. Under the Regulation on Pharmacists and Pharmacies, the number of private pharmacies is regulated according to the population within district boundaries, on the basis of at least one pharmacy per 3,500 people.
This does not mean that a pharmacy automatically opens whenever the population increases by 3,500 people. The rule is implemented through administrative quota calculations. The relevant authority determines how many pharmacies may be opened in each district by considering population data, existing pharmacies and the rules of the placement system.
For example, if a district’s population supports an additional pharmacy under the calculation method, that district may be announced as available for a new pharmacy opening. Pharmacists then apply through EYS, and placement is made according to the applicable ranking and scoring rules.
The 3,500-person rule is therefore a legal threshold for planning, not a direct individual entitlement. A pharmacist must still comply with application periods, EYS procedure, placement criteria, document submission, premises suitability and licensing requirements.
Why Turkey Uses Population-Based Pharmacy Planning
The purpose of population-based pharmacy planning is to regulate pharmacy distribution in a balanced way. Without such a system, pharmacies would likely concentrate in central, wealthy, high-traffic or hospital-adjacent areas, while smaller districts and less profitable regions could remain underserved.
From a public health perspective, the supply of medicines must be accessible not only in commercially attractive districts but also in less developed or less populated areas. Population-based planning aims to prevent a purely market-driven distribution model that may ignore access needs.
The system also reduces destructive competition between pharmacies. If too many pharmacies are opened in the same district, commercial pressure may increase. Such pressure may lead to unethical prescription competition, informal arrangements, aggressive discounting, hidden cooperation with healthcare providers or other conduct that may harm professional independence.
Therefore, the Turkish model seeks to balance access, professional ethics and sustainable pharmacy practice.
District-Based Planning
The population criterion is applied according to district boundaries. This is significant because pharmacy planning is not calculated on a national or provincial average. A province may have enough population overall, but a specific district may not have an available quota. Conversely, a smaller district without sufficient population may still become relevant if there is no pharmacy in that settlement.
The Regulation provides that private pharmacy numbers are regulated according to district population and that the institution determines and announces the districts where pharmacies may be opened, together with the number of pharmacies that may be opened, using population data.
This district-based approach creates practical consequences for pharmacists. A pharmacist who wishes to open a pharmacy in Istanbul, Ankara, Izmir, Antalya or another major city cannot simply rely on the province’s total population. The pharmacist must check the specific district quota.
For this reason, location analysis is a legal issue as much as a commercial issue. Before signing a lease or investing in premises, a pharmacist must determine whether the relevant district is open for pharmacy placement.
The Role of EYS
The Eczacı Yerleştirme Sistemi, known as EYS, is the electronic placement system used for pharmacists who are subject to population-based pharmacy opening and relocation rules. The EYS Guide states that the system governs electronic applications by pharmacists who wish to open or relocate pharmacies under the population-based restrictions of Law No. 6197 and the Regulation on Pharmacists and Pharmacies.
EYS is essential because pharmacy openings are no longer based merely on individual applications made at any time. Instead, pharmacists apply during announced periods through the electronic system. The available districts and quotas are published, pharmacists submit their applications and preferences, and placement is carried out according to the applicable points and ranking rules.
In 2026, for example, the Turkish Pharmacists’ Association published a TİTCK announcement stating that applications for pharmacists subject to the population criterion would be received through EYS between 17 June 2026 and 16 July 2026, and that applicants were required to upload their documents and confirm the originals with provincial or district health directorates by the deadline.
This demonstrates that EYS is not a theoretical system. It is an active administrative mechanism used for current pharmacy placement procedures.
Application Periods and Announcements
A pharmacist who wishes to open a pharmacy under the population-based system must follow official EYS announcements carefully. Application periods are determined and announced by the competent authority. Missing the application deadline may mean losing the chance to apply during that placement period.
The EYS Guide provides rules on application periods, determination of places where pharmacies may be opened, quota calculation, application procedures, service points, placement points and post-placement procedures.
In practice, pharmacists should monitor announcements from TİTCK, EYS and the Turkish Pharmacists’ Association. Because placement periods are time-sensitive, document preparation should begin before the application window closes. Waiting until the last days may create risk, especially if original documents must be confirmed by provincial or district health directorates.
A pharmacist who fails to upload documents properly or fails to confirm them within the announced time may lose the right to participate in the placement process.
Service Points and Placement Points
The population-based pharmacy planning system does not only depend on district population. It also includes a ranking mechanism among applicant pharmacists. The EYS Guide explains that districts are assigned coefficients based on socio-economic development classifications, and that a pharmacist’s service point is calculated by multiplying the number of years of professional activity in a district by the district coefficient. If the pharmacist has worked in more than one district, service points are added together.
The guide also explains that the pharmacist’s placement point is determined by adding the pharmacist’s total years in the profession to the service point total. In addition, the district coefficient is increased by one quarter for professional activities after completion of a doctorate.
This scoring mechanism aims to create a more structured and objective placement process. It may favor pharmacists who have served in less developed or underserved districts. It also prevents placement from being determined only by financial power or private negotiation.
Therefore, pharmacists should calculate their service and placement points carefully before applying. Understanding the scoring system is essential for choosing realistic district preferences.
Effect of Previous Pharmacy Transfer on Placement Points
The EYS Guide states that if a pharmacist has transferred their pharmacy and later wishes to open a new pharmacy, the placement points related to services before the transfer are reduced by half.
This rule is important because pharmacy transfer may have long-term consequences for future pharmacy opening rights. A pharmacist who sells or transfers a pharmacy should not evaluate the transaction only from a commercial perspective. The transfer may affect future EYS placement calculations.
From a legal planning perspective, transfer agreements and future business strategies should be considered together. If a pharmacist plans to sell a pharmacy and later open another pharmacy in a more attractive district, the reduction in placement points may become a significant factor.
Exception for Settlements Without a Pharmacy
The Regulation on Pharmacists and Pharmacies provides an important exception: in settlements where there is no pharmacy, one pharmacy may be opened without applying the population criterion. However, if a pharmacy opened under this exception is later relocated to another place, the population criterion is applied.
This exception reflects the access-to-medicine purpose of the system. If a settlement has no pharmacy, public health needs may justify opening a pharmacy even if the population is below the normal threshold.
However, the exception cannot be used as a loophole to bypass the population system. A pharmacist who opens a pharmacy in an underserved settlement cannot freely move that pharmacy to a more attractive area without satisfying the relevant population rules.
This is important for both pharmacists and investors. The legal value of a pharmacy opened under the no-pharmacy exception may be different from the value of a pharmacy that can freely relocate under ordinary rules.
Relocation Within the Same District
The Regulation states that the population criterion is not applied to pharmacy relocations within the same district.
This rule is practical. If a pharmacy is already lawfully operating in a district, moving within the same district does not normally create a new pharmacy in population-planning terms. However, this does not mean that relocation is completely free or automatic.
The new premises must still comply with pharmacy premises requirements. The pharmacist must complete the required administrative procedure, submit relevant documents and obtain approval for the new location. If the new premises are physically or legally unsuitable, relocation may still be refused or delayed.
Therefore, same-district relocation avoids the population quota problem but does not eliminate licensing, premises suitability and administrative compliance requirements.
Relocation to Another District
Relocation to another district is more sensitive. If a pharmacy is moved outside its existing district, population-based restrictions may apply. The pharmacist may need to participate in EYS or comply with the district quota system, depending on the circumstances.
This is a major legal risk in pharmacy transactions. A pharmacy may be commercially valuable because of its license, customer base or location. However, if the buyer intends to move it to another district, the relocation may not be legally possible unless the population-based rules allow it.
Before purchasing a pharmacy with a relocation plan, the buyer should verify whether the target district has an available quota, whether EYS participation is required and whether the new premises satisfy legal requirements.
Natural Disaster and Force Majeure
The Regulation contains special rules for population decrease caused by natural disaster or force majeure. It states that where population decreases due to natural disaster or force majeure, the population-based pharmacy opening criterion is not applied to relocation of pharmacies in that settlement, and the determination and announcement of this situation are made by the Ministry.
This rule protects pharmacists from losing rights because of events beyond their control. For example, if a district’s population falls temporarily due to disaster, it would be unfair to prevent existing pharmacies from relocating within the affected settlement.
However, force majeure rules should be interpreted carefully. A pharmacist relying on such an exception should obtain official documents, follow Ministry announcements and complete the required administrative procedure. Informal claims of hardship are not enough.
Urban Transformation and Premises Loss
Although the main population rule is based on district population, pharmacy relocation may also be affected by urban transformation, demolition, compulsory evacuation or loss of premises. In such cases, pharmacists may need to relocate under special rules.
The legal issue is whether the relocation is voluntary or forced. If the pharmacist is forced to move because the building is demolished or included in an urban transformation process, strict application of ordinary population limits may create unfair results. For this reason, the regulation includes force majeure and special relocation logic.
In practice, pharmacists should act early when facing urban transformation. They should obtain official documents from the municipality or competent authority, notify the provincial health directorate and chamber of pharmacists, and identify legally suitable replacement premises.
Population Planning and Pharmacy Transfers
Population-based planning also affects pharmacy transfers. When a pharmacy is sold or transferred, the buyer must be a legally eligible pharmacist. However, if the buyer wants to relocate the pharmacy after transfer, population rules may become decisive.
A pharmacy transfer agreement should therefore address whether the pharmacy will remain at its current address or be relocated. If relocation is intended, the agreement should make the transaction conditional upon obtaining the necessary approvals. Otherwise, the buyer may pay for a pharmacy but later discover that the planned relocation is not legally possible.
In addition, if the seller previously opened the pharmacy under a special no-pharmacy settlement exception, the relocation limitations should be reviewed carefully.
Population Planning and Premises Selection
Even if a district has an available pharmacy quota, the pharmacist must still choose legally suitable premises. Population-based planning only answers the question: “May a pharmacy be opened in this district?” It does not answer the separate question: “Is this specific shop suitable for a pharmacy?”
The Regulation on Pharmacists and Pharmacies contains detailed rules on pharmacy premises, physical requirements and pharmacy service conditions. The pharmacy must satisfy the legal standards applicable to healthcare premises, storage, access, hygiene and other technical conditions.
This means that pharmacists must conduct two separate checks. First, they must check EYS and district quota. Second, they must check the physical and legal suitability of the premises.
Signing a lease before completing both checks is risky. If the district is not available under EYS or the premises are unsuitable, the pharmacist may be unable to obtain a pharmacy license despite having made financial commitments.
Population Planning and Competition Law Perspective
The population-based pharmacy planning system limits free market entry. However, this limitation is based on healthcare regulation and public health policy. Pharmacies are not ordinary commercial businesses, and medicines are not ordinary goods.
The system aims to prevent uncontrolled clustering of pharmacies in certain districts. It also seeks to support professional independence by reducing excessive competition pressure.
From a legal policy perspective, the system attempts to balance three interests: patient access to medicines, sustainable pharmacy operation and professional quality of pharmacy services. If pharmacy opening were completely free, some areas might have too many pharmacies while others might have none. The population-based system reduces this imbalance.
Advantages of the System
The first advantage is equal access. By distributing pharmacies according to population and district needs, the system encourages pharmacy presence across the country.
The second advantage is professional sustainability. Pharmacies require qualified pharmacists, proper storage systems, prescription compliance, medicine tracking and SGK-related procedures. Excessive competition may undermine quality and compliance.
The third advantage is administrative transparency. EYS provides a structured electronic system for applications and placement.
The fourth advantage is protection against purely capital-based entry. Since placement is based on legal criteria and pharmacist points, financial power alone does not determine who opens a pharmacy.
Criticism of the System
Despite its public health purpose, the population-based pharmacy planning system may also be criticized. Some pharmacists may argue that the system restricts professional freedom. Others may argue that it increases the economic value of existing pharmacy licenses and makes it difficult for young pharmacists to open pharmacies in attractive districts.
There may also be practical concerns about scoring, service points, document deadlines, quota calculations and transparency. Applicants must understand the system well, because procedural mistakes may have serious consequences.
However, these criticisms do not change the current legal framework. As long as the system remains in force, pharmacists must comply with EYS, population quota, placement point and licensing rules.
Legal Risks for Pharmacists
The main legal risks include applying for an unavailable district, missing EYS deadlines, submitting incomplete documents, choosing unsuitable premises, misunderstanding same-district relocation rules, purchasing a pharmacy with unrealistic relocation expectations and ignoring the impact of previous pharmacy transfer on placement points.
Another major risk is hidden ownership. Because pharmacy openings are restricted, some investors may attempt to use nominee pharmacists. Such arrangements may trigger sham ownership review and administrative sanctions.
The safest approach is to complete legal due diligence before making commercial commitments. Population quota, EYS eligibility, pharmacist status, premises suitability, chamber procedures and health directorate approval should be reviewed together.
Practical Checklist for Population-Based Pharmacy Planning
A pharmacist planning to open or relocate a pharmacy in Turkey should follow this checklist:
First, confirm pharmacist eligibility under Law No. 6197. Second, monitor official EYS announcements. Third, identify districts with available quotas. Fourth, calculate service and placement points. Fifth, choose district preferences strategically. Sixth, upload required documents within the EYS deadline. Seventh, confirm original documents with the relevant health directorate. Eighth, verify that the selected premises satisfy legal requirements. Ninth, avoid hidden investor or sham ownership structures. Tenth, complete licensing procedures before starting operation.
This checklist should be followed before signing a lease, purchasing fixtures, entering into a pharmacy transfer agreement or accepting investor financing.
Frequently Asked Questions
What is the population-based pharmacy planning system in Turkey?
It is the legal system regulating the number and distribution of private pharmacies according to district population, generally on the basis of at least one pharmacy per 3,500 people.
What is EYS?
EYS is the electronic pharmacist placement system used for applications by pharmacists who wish to open or relocate pharmacies subject to population-based restrictions.
Can a pharmacist open a pharmacy anywhere in Turkey?
No. A pharmacist must comply with district quota, EYS placement, premises suitability and licensing rules.
Does the population criterion apply to relocation within the same district?
No. The Regulation states that population criteria are not applied to pharmacy relocations within the same district.
Can a pharmacy be opened in a place with fewer than 3,500 people?
Yes, if there is no pharmacy in that settlement, one pharmacy may be opened without applying the population criterion. However, relocation from that settlement may later trigger the population rule.
Conclusion
The population-based pharmacy planning system in Turkey is a fundamental part of Turkish pharmacy law. It limits pharmacy openings according to district population and applies a general rule of at least one pharmacy per 3,500 people. This system is implemented through EYS, which manages applications, quotas, service points, placement points and post-placement procedures.
The system reflects the healthcare nature of pharmacy practice. Its purpose is not merely to regulate market entry but to protect public health, ensure access to medicines, prevent excessive pharmacy concentration and support professional pharmacy services.
For pharmacists, the key point is that pharmacy opening requires more than professional qualification. A pharmacist must also comply with district quota, EYS deadlines, placement rules, premises standards and licensing procedures. For buyers and investors, the key issue is that pharmacy value depends not only on commercial potential but also on regulatory status.
A legally secure pharmacy opening or relocation strategy in Turkey must therefore begin with population planning analysis. Before signing a lease, purchasing a pharmacy, financing a project or choosing a district, pharmacists should carefully review Law No. 6197, the Regulation on Pharmacists and Pharmacies, EYS announcements and administrative practice. In Turkish pharmacy law, location is not only a business decision; it is a regulated legal condition.
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