Short-term residential rentals have become an increasingly important part of the Turkish real estate market. Apartments in Istanbul, Antalya, Bodrum, Fethiye, İzmir and other tourism-oriented locations may generate significantly different returns when rented for days or weeks rather than under traditional long-term residential leases.

However, Turkish law no longer treats this activity as an ordinary residential rental arrangement.

Since 1 January 2024, Law No. 7464 on the Rental of Residential Properties for Tourism Purposes has established a specific regulatory regime for short-term residential rentals. In addition, the Ministry of Culture and Tourism’s implementing Regulation determines the application procedure, technical requirements, operational duties and inspection system applicable to licensed residences.

For property owners and investors, the central question is therefore no longer simply:

“Can I rent this apartment on Airbnb?”

The correct question is:

“Can this particular apartment legally obtain and maintain a tourism rental permit?”

The distinction can materially affect the value and expected rental return of an investment property.

1. What Is a Tourism Rental Under Turkish Law?

The regulatory system generally applies where a residence is rented to a user for 100 days or less in a single rental contract.

Importantly, the reason for the tenant’s stay is not decisive. The Ministry’s guidance states that the permit requirement applies to rentals of 100 days or less regardless of whether the residence is used for travel, business, education, health, sport or another purpose.

Accordingly, the regime is broader than conventional “holiday rentals.”

A 10-day apartment rental to a tourist clearly falls within the system.

But so may:

• a 30-day rental to a business traveller;
• a 60-day rental to a foreign visitor;
• an 80-day temporary accommodation arrangement; or
• another residential rental not exceeding the statutory period.

The legislation expressly excludes a rental made for more than 100 days in a single contract from the scope of Law No. 7464.

This does not, however, create an unlimited loophole.

2. Repeated 101-Day Contracts Are Not a Safe Way Around the Law

The legislation specifically addresses attempts to avoid the tourism-rental regime through repeated long-term contracts.

Law No. 7464 provides for a substantial administrative fine where the same residence is rented more than four times within one year from the date of the first contract, even though each individual contract is concluded for more than 100 days.

This anti-avoidance provision is particularly important for investors.

An owner should therefore not structure repeated 101-day agreements merely to create the appearance that the residence is outside the tourism-rental regime.

The factual pattern of the rental activity matters.

3. A Tourism Rental Permit Must Be Obtained Before the Rental Contract

A residence subject to the legislation cannot lawfully begin tourism rental activity first and obtain permission later.

Article 3 of Law No. 7464 requires the tourism rental permit to be obtained before entering into the tourism rental agreement. The Ministry also requires the official tourism-rental plaque to be displayed at the entrance of the licensed residence.

For investors acquiring a property specifically for short-term rental income, this creates an important transaction risk.

The correct sequence is not:

buy → advertise → rent → apply for licence.

Instead, the property’s legal eligibility should ideally be investigated before the purchase itself.

4. Who Can Obtain the Permit?

The permit is not generally available to anyone who happens to possess or rent the apartment.

Under the current Regulation, the applicant is principally the owner of the residence or, where properly established and registered, the holder of a usufruct or superficies right. Certain management and marketing businesses may also obtain permits in the special regime applicable to qualifying high-quality residences.

This creates a significant restriction on “rental arbitrage.”

For example:

A person cannot ordinarily rent an apartment from its owner under a normal one-year lease and then independently obtain a tourism rental permit in his own name in order to operate the property as an Airbnb business. Ministry guidance expressly states that an ordinary tenant cannot obtain the permit merely on the basis of a long-term lease.

5. Ordinary Tenants Cannot Simply Sublet the Apartment to Tourists

Law No. 7464 expressly prohibits a person who rented a residence for residential purposes from subsequently renting that residence to third parties for tourism purposes in his or her own name and account.

Likewise, a user renting an already licensed tourism residence cannot ordinarily re-rent it to another person in his or her own name and for his or her own account. An exception exists for certain corporate users providing the accommodation to their own personnel.

This is particularly important for investors considering business models involving:

long-term lease + short-term subletting.

Such a model should not be implemented without first analysing the licensing structure.

6. The Biggest Problem for Apartment Owners: Unanimous Approval

For an ordinary apartment in a multi-unit residential building, obtaining a permit may be significantly more difficult than many investors expect.

As a general rule, the applicant must submit a notarised copy of a unanimous decision of the owners of all residential independent units in the building approving the tourism rental activity for the relevant residence.

This requirement can completely change the investment economics of an apartment.

Imagine an investor purchasing an apartment in a 40-unit residential building because similar apartments in the area generate attractive daily rental income.

If even one of the relevant apartment owners refuses to approve the tourism rental operation, the investor may be unable to satisfy the unanimity requirement applicable to an ordinary apartment.

This is why an investor should never assume:

“Other apartments in this neighbourhood are on Airbnb, so mine can also be rented.”

The legal position of the particular building must be examined.

7. The Rule Applies to the Building, Not Automatically to the Entire Residential Complex

Where a housing complex contains several separate buildings, the ordinary unanimity requirement generally relates to the building containing the apartment for which the permit is requested.

The Ministry’s current guidance confirms that, in such complexes, the rule is normally applied with reference to the relevant building rather than automatically requiring approval from every owner throughout the entire complex.

However, additional approval requirements may arise where a single lessor seeks permits for a larger number of units.

8. The 25% Limitation Can Restrict Portfolio Investors

There is another important restriction that primarily affects professional property investors.

In buildings containing more than three independent units, permits may generally be issued in the name of the same lessor for no more than 25% of the independent units in that building.

For example, an investor purchasing multiple apartments in the same building cannot automatically assume that every unit can be placed into the short-term rental market.

The number of units owned and the total number of independent units in the building must be analysed together.

This restriction should therefore be included in the acquisition due diligence of any investor purchasing several apartments in a single building.

9. More Than Five Units Creates Additional Regulatory Requirements

Where more than five independent units in the same building are to be licensed in the name of the same lessor, the regulatory burden becomes even greater.

The legislation requires, among other things, an işyeri açma ve çalışma ruhsatı — workplace opening and operating licence.

If the relevant building is located within a residential complex consisting of multiple buildings, further unanimous owner approval requirements may also arise.

At this stage, the investment increasingly resembles an organised accommodation business rather than a passive residential investment.

10. Detached Houses Have an Important Advantage

The unanimity and 25% limitations do not apply in the same way to qualifying detached residences.

The Ministry’s current Regulation expressly excludes detached residences and qualifying high-quality residences from the ordinary unanimity and 25% restrictions.

The Ministry has also issued guidance on what may qualify as a detached residence for application purposes, including certain independently accessible properties that are not functionally connected to another structure.

This means that, from a short-term rental investment perspective, a detached villa may present a fundamentally different regulatory profile from an ordinary apartment in a condominium building.

11. High-Quality Residences — “Rezidans” — Have a Special Regime

Turkish legislation also recognises a special category of yüksek nitelikli konut, broadly corresponding to qualifying high-service residences.

The Regulation refers to buildings containing several residential units and providing features such as reception, security and daily cleaning areas, with the possibility of additional services including laundry, transport, food services, sports facilities and swimming pools.

Where the statutory requirements are satisfied, these high-quality residences are exempt from the ordinary unanimity and 25% restrictions. Their rental activities may also, in qualifying circumstances, be conducted through the relevant residential management or authorised marketing business.

However, merely marketing a building as a “luxury residence” is not enough.

Its official legal and planning status must satisfy the regulatory definition.

12. Applications Are Made Electronically

Tourism rental permit applications are submitted through the e-Devlet system.

The Ministry’s current application page states that applications are made exclusively through the electronic system rather than by ordinary physical filing.

Depending on the property and applicant, required documents may include:

• ownership documentation;
• applicant identification;
• corporate registration information;
• co-owner approvals;
• unanimous condominium approval;
• management-plan documentation;
• workplace licence where required; and
• special documentation for high-quality residences.

For jointly owned property, the exact ownership structure also matters.

In shared ownership, the Regulation requires approval satisfying both share and co-owner majority requirements, while jointly owned property subject to collective ownership requires the written participation of all owners.

13. Getting the Permit Is Not the End of the Compliance Process

One of the most important mistakes an investor can make is treating the tourism rental permit as a one-time licence with no continuing obligations.

The Regulation requires an inspection after the permit is issued, and licensed residences are also subject to periodic inspections thereafter. The current Regulation provides that licensed residences are inspected at least once every two years.

Therefore, compliance must continue throughout the investment period.

A residence that originally qualified for a permit can face sanctions or ultimately lose its licence if the required conditions cease to be satisfied.

14. The Residence Must Meet Minimum Physical Standards

The Regulation prescribes specific minimum standards.

A licensed residence must include appropriate sleeping accommodation, bathroom facilities, a living space and kitchen arrangement.

It must also provide hot and cold water and specified accommodation equipment. Fire-safety requirements include appropriate fire extinguishers, smoke detectors in relevant areas and an escape-route plan.

The furniture, equipment and appliances must also remain clean, maintained and operational.

These are not merely hotel-quality recommendations.

They form part of the regulatory conditions for licensed tourism residences.

15. There Is Also a Maximum Guest Capacity

The Regulation calculates capacity primarily according to the number of bedrooms and permits limited additional capacity outside the bedrooms.

Even where the physical space might accommodate more guests, the same residence may generally host no more than 12 persons, excluding children under three years of age, and the licensed capacity cannot be exceeded.

Overcrowding therefore creates a regulatory risk in addition to any contractual or condominium-law problem.

16. Renting Individual Rooms Is Restricted

The Turkish tourism-rental system is designed primarily around the licensing of the residence as a whole, not informal room-by-room accommodation.

The Regulation provides that a permit cannot be issued simply for one or several rooms within an unlicensed residence that the owner continues to use as his or her own home.

Moreover, even within a licensed tourism residence, individual rooms cannot be separately contracted to different users.

Accordingly, an owner should not assume that a spare bedroom can automatically be placed on a short-term accommodation platform.

17. The Official Plaque Must Be Displayed

Every licensed tourism residence must display the Ministry-issued plaque at the entrance.

The plaque identifies the property as a “TURİZM AMAÇLI KONUT”, states that it is subject to Ministry supervision and includes information concerning the licence and property.

Failure to display the plaque can lead to administrative sanctions, with increased consequences if the violation is not corrected after the statutory period.

18. Airbnb and Other Online Advertisements Must Also Comply

Digital advertising is itself regulated.

The current Regulation requires the tourism rental permit to be displayed clearly in promotional and marketing channels.

Advertisements must also contain accurate information concerning matters such as:

• location;
• guest capacity;
• floor;
• bedrooms and bathrooms;
• balcony or terrace;
• available equipment;
• heating and cooling;
• swimming pool or sports facilities;
• parking;
• internet;
• accessibility;
• pet policy;
• check-in and check-out arrangements; and
• applicable building or site rules.

Misleading advertisements and failure to provide promised conditions can result in administrative sanctions.

Therefore, an online listing should be treated as a legally relevant commercial representation, not merely marketing language.

19. Online Platforms Are Also Part of the Enforcement System

Law No. 7464 does not regulate only property owners.

Persons who intermediate unlicensed tourism rentals may also be sanctioned.

The legislation further provides that electronic intermediary service providers who continue to facilitate unlawful advertisements after receiving a Ministry warning may face administrative sanctions if they fail to remove the content within 24 hours. Access-blocking or content-removal measures may also follow.

This substantially reduces the viability of attempting to operate an unlicensed property solely through an online platform.

20. Guest Identity Reporting Is Mandatory

Licensed tourism residences are subject to the Identity Notification Law No. 1774.

The legislation expressly treats the tourism permit holder as the responsible person for the relevant notification obligations.

The Regulation additionally requires compliance with the Turkish Personal Data Protection Law No. 6698 when processing guest information.

Therefore, an investor operating a short-term residence has simultaneous obligations relating to:

identity reporting
and
lawful processing and protection of personal data.

21. Property Management Companies Cannot Be Appointed Without Considering the Licensing Rules

An investor may naturally wish to outsource:

• advertising;
• guest communication;
• cleaning;
• check-in;
• price management; and
• reservation administration.

However, the legal structure of the arrangement must be examined carefully.

Law No. 7464 provides that, where the tourism rental activity is conducted by someone other than the lessor, the relevant intermediation is subject to the framework applicable to authorised Group A travel agencies, except for special arrangements concerning qualifying high-quality residences.

Therefore, merely signing a broad “property management agreement” does not automatically give a third-party company unrestricted legal authority to operate the property as its own short-term rental business.

22. Administrative Fines Can Become Extremely Significant

The sanction system under Law No. 7464 is deliberately severe.

The statutory structure begins with an administrative fine for each residence being rented without a permit and provides a period for compliance.

If the illegal activity continues, the sanction increases substantially.

Continued unlicensed operation after the successive compliance periods can ultimately trigger the highest level of sanction specified by the legislation.

The Law as enacted established a staged system based on figures of:

TRY 100,000 → TRY 500,000 → TRY 1,000,000

for continued unlicensed activity. Separate base penalties are also prescribed for unauthorised subletting, illegal intermediation, failure to display the plaque, misleading advertising and various other violations.

Because administrative fine amounts can be affected by annual statutory revaluation rules, the amount applicable at the date of a specific violation should always be checked rather than relying solely on the original figures printed in the 2023 legislation.

23. Using Long-Term Tenants as “Hosts” Can Create Serious Exposure

A particularly dangerous investment model is:

1. owner rents apartment to operator for one year;
2. operator places apartment on Airbnb;
3. operator keeps the short-term rental income;
4. owner receives a fixed monthly amount.

This may look commercially convenient, but the regulatory system expressly restricts tourism subletting by ordinary residential tenants.

Investors should therefore examine not only whether the property has a permit, but also who legally conducts the rental activity and in whose name the reservation contract is made.

24. The Permit Does Not Eliminate Condominium Rules

Obtaining a tourism rental permit does not mean that other rules concerning the building become irrelevant.

The Regulation specifically requires permit holders to inform users of rules adopted by the site or building management.

Noise, common-area usage, security, swimming pools, parking and other matters may therefore continue to create disputes between short-term rental operators and permanent residents.

For this reason, the condominium management plan should be reviewed before an investment property is purchased.

This is particularly important because the management plan is a long-term legal document governing the use and management of the condominium.

25. Sale of the Property Creates a Licence-Continuity Risk

An investor purchasing an apartment that is already being operated as a tourism residence should not automatically assume that the existing permit can simply be treated as a permanent feature of the property.

Law No. 7464 contains specific rules concerning changes in the lessor.

Failure to notify a change resulting from a legal transaction within the relevant period may lead to an administrative sanction, and failure by the new lessor to complete the required permit-transfer/application process may lead to cancellation of the existing permit.

Therefore:

“The seller has an Airbnb permit”

does not by itself answer:

“Will I be entitled to operate the apartment under that permit after I buy it?”

Licence continuity must be examined as part of the acquisition.

26. Tax Compliance Is a Separate Issue

The tourism rental licence should not be confused with tax clearance.

The Regulation provides that copies of issued permits, cancellations and rejected applications are communicated to several public authorities, including the relevant tax office.

Law No. 7464 also refers expressly to compliance with obligations concerning the tourism share under the legislation governing the Türkiye Tourism Promotion and Development Agency.

Accordingly, investors should separately assess:

• income tax or corporate tax consequences;
• VAT treatment where applicable;
• invoicing/documentation obligations;
• tourism share obligations; and
• the appropriate commercial structure for multiple-property operations.

The existence of the tourism rental permit does not by itself resolve these tax questions.

27. What Happens If the Apartment Is Sold as an “Airbnb Investment” but Cannot Obtain a Permit?

This creates an important private-law question between buyer and seller.

Imagine that an apartment is marketed to an investor as:

“Airbnb suitable – very high daily rental income.”

After completing the purchase, the buyer discovers that:

• the other condominium owners will not unanimously approve the activity;
• the 25% building limit has already been reached;
• the apartment does not qualify for an exception;
• the existing management structure prevents the intended operation; or
• the property cannot obtain the necessary licence for another legal reason.

Whether the buyer can pursue the seller will depend upon the representations made before the sale, the wording of the contract, the buyer’s due diligence and whether short-term rental suitability constituted an agreed or represented quality of the property.

Depending on the facts, Turkish rules concerning defects, contractual liability, misrepresentation and damages may become relevant.

This is why advertisements, WhatsApp communications, brochures and written statements concerning “Airbnb eligibility” should be preserved as evidence.

28. Due Diligence Before Buying a Short-Term Rental Investment

An investor intending to operate an apartment as a tourism rental should investigate the licensing position before signing the acquisition agreement.

At minimum, the following questions should be answered:

1. Is the independent unit legally registered as residential property?
2. Is it an ordinary apartment, detached residence or qualifying high-quality residence?
3. Is unanimous owner approval required?
4. Has unanimous approval already been obtained?
5. Does the condominium management plan contain relevant provisions?
6. How many independent units are in the building?
7. How many units are already licensed in the name of the same lessor?
8. Will the 25% restriction apply?
9. Will a workplace opening and operating licence be required?
10. Is the current tourism permit valid?
11. Will the permit continue after acquisition?
12. Does the property satisfy fire and physical safety requirements?
13. What is the authorised guest capacity?
14. Who will legally operate and advertise the property?
15. Are tax and tourism-share obligations properly structured?

Only after these questions are answered should projected short-term rental income be included in the investment valuation.

29. The Most Important Investment Principle

The legal value of an apartment intended for short-term rental is not determined only by:

location + square metres + nightly rate.

The correct calculation is closer to:

property value + legal ability to operate + licence sustainability + compliance cost + regulatory risk.

A theoretically profitable Airbnb apartment that cannot legally obtain a permit may be worth substantially less to an investor than a slightly less attractive property with a secure licensing structure.

Conclusion: Do Not Buy an Airbnb Investment Before Checking the Licence

Turkey’s short-term rental regime has transformed tourism accommodation in residential properties into a closely regulated activity.

Law No. 7464 requires a tourism rental permit for qualifying short-term rentals and imposes substantial sanctions for unlicensed operations. Ordinary apartment owners may also face one of the most restrictive requirements in the system: unanimous approval from the relevant condominium owners.

Portfolio investors must additionally consider the 25% building limitation and additional licensing requirements where several independent units are involved.

Once a permit is obtained, the owner remains subject to continuing obligations involving physical standards, fire safety, guest capacity, identity reporting, personal data, advertising, consumer information, building rules, inspections and the official plaque.

For this reason, investors should not purchase property merely because an estate agent describes it as:

“Airbnb suitable.”

The better question is:

“Can this specific property legally obtain, retain and commercially use a tourism rental permit under Turkish law?”

For short-term rental investments in Turkey, that question may be worth more than the property’s nightly rental rate.