Turkish Aviation Law in Turkey: A Practical Legal Guide for Airlines, Lessors, Airports, Drone Operators, and Investors (2026)
Turkey is one of the world’s most dynamic aviation markets: major hubs, dense domestic networks, strong cargo corridors, and a rapidly evolving ecosystem of airports, ground handlers, maintenance providers, and technology-driven aviation services. But the opportunity comes with a complex legal and regulatory environment. Whether you are launching an airline, leasing aircraft into Turkey, operating an airport business, handling passenger claims, investing in aviation assets, or flying drones for commercial purposes, legal compliance is not optional—it is operational.
This guide explains the foundations of Turkish aviation law, the main regulators and rules, market entry and licensing, aircraft registration and financing, passenger rights and liability, accident investigation, UAV/drone compliance, and how disputes are typically handled in Turkey. It is written for business decision-makers and international stakeholders who need clear legal direction, as well as individuals seeking remedies (e.g., flight delays/cancellations).
Important: Aviation rules change frequently through regulations, instructions, and communiqués. This article provides general information, not legal advice for a specific case.
1) The legal backbone of civil aviation in Turkey
At the center of Turkish aviation regulation is Civil Aviation Law No. 2920 (often referred to as the Turkish Civil Aviation Act). It sets the general framework for civil aviation activities, including key principles on aviation operations, rights and responsibilities, enforcement mechanisms, and the overall structure of the sector.
However, in day-to-day practice, most compliance questions are answered not only by the law itself, but also by secondary legislation (regulations and instructions) issued by the civil aviation authority—covering licensing, operations, safety, continuing airworthiness, airport services, ground handling, passenger rights, and unmanned aircraft.
2) The main regulator and who does what
The primary civil aviation regulator in Turkey is the Directorate General of Civil Aviation (SHGM). SHGM is responsible for regulating and overseeing civil aviation in line with national and international standards, issuing sectoral legislation, and supervising operators.
In parallel, accident/incident investigations and safety recommendations fall under the Transport Safety Investigation Center, which publishes investigation reports and operates within the Ministry of Transport and Infrastructure structure.
Other institutions can become relevant depending on the matter (e.g., airport charges, concessions, and certain airport operations), including the State Airports Authority (DHMİ).
3) How to start an airline or air operator in Turkey
A) Operator categories matter
Turkey differentiates between types of commercial air operators (e.g., airline companies vs. air taxi operators), often based on seating capacity and operational scope. SHGM’s public guidance describes airline companies as commercial operators with seating capacity of 20+ and air taxi operators as those operating aircraft up to 19 seats, subject to the relevant certification and authorization framework.
B) The key approvals: Operating license + AOC (in practice)
For commercial air transport, you generally deal with two core pillars:
- Operating license / commercial authorization (market entry permission, corporate and financial capacity, ownership/control checks, and scope of activity); and
- Air Operator Certificate (AOC) (technical and operational capability: manuals, safety management, training systems, compliance with flight operations rules).
SHGM publishes process documents that reference applications through its licensing system and the relevant regulation provisions (commonly referred to as SHY-6A in practice for commercial air transport licensing frameworks).
C) Why legal structuring is as important as technical readiness
Many aviation projects fail or stall not because the aircraft is unavailable, but because the corporate and legal infrastructure is incomplete. Common pitfalls include:
- Incorrect corporate form or shareholding arrangements that don’t fit licensing expectations
- Weak governance structure (unclear responsible managers, compliance roles, internal control)
- Inadequate documentation (manuals, training programs, continuing airworthiness arrangements)
- Misaligned contracts (wet lease/dry lease terms vs. Turkish operational realities, insurance mismatches, poor maintenance responsibility allocation)
A Turkey-ready legal approach typically includes a pre-application regulatory gap analysis, governance and compliance design, and a documentary package aligned with SHGM expectations.
4) Flight operations compliance: “paper compliance” is not enough
Turkey’s aviation sector is built around the safety logic of international civil aviation standards and operational rules. SHGM maintains extensive operational instructions and announcements relating to flight operations frameworks (for example, SHT-OPS revisions and implementation announcements).
From a legal-risk perspective, the most critical compliance areas are:
- Safety Management System (SMS) design and real implementation
- Crew qualification, rostering, fatigue management, and training compliance
- Operational control and dispatch responsibilities
- Aircraft documentation, MEL/CDL logic, defect management
- Incident reporting and safety occurrence tracking (not just after accidents)
Even where violations begin as administrative matters, they can escalate into contractual defaults (lease events of default), insurance disputes, and civil liability.
5) Airports and ground handling: licensing, safety, and commercial risk
Aviation law in Turkey also governs the “ground side” of aviation: airport and terminal operations, workplace permits, and ground handling services. Ground handling in Turkey is regulated through SHGM’s framework commonly known as SHY-22 (Airports Ground Handling Services Regulation), which is referenced in official tariffs and implementation rules.
Practical legal issues in ground handling
If you operate (or contract with) a ground handler, your legal risk often concentrates in:
- Scope and service level definitions (who does what, and under which operational conditions)
- Allocation of liability for damage to aircraft, baggage, cargo, and equipment
- Insurance structure (matching liability regimes, deductibles, subrogation strategies)
- Operational delays and consequential damages (often heavily negotiated, sometimes excluded)
- Compliance with airport security, access permits, and staff vetting (highly sensitive in practice)
Because ground operations frequently involve multiple actors (airport operator, handler, airline, catering, fuel, security), contracts should be drafted with a disputes-first mindset: evidence, reporting timelines, damage documentation protocols, and claims handling steps.
6) Aircraft registration, ownership, and cross-border leasing into Turkey
Aircraft registration and the “status” of an aircraft in Turkey matters for:
- Validity of operations under Turkish regulatory supervision
- Enforceability of ownership and security rights
- Insurance recognition and claims handling
- Leasing and repossession outcomes
Turkey also interacts with international asset-based financing frameworks—especially for aircraft.
A) Cape Town Convention, aircraft financing, and IDERA logic
Turkey has ratified the Cape Town Convention and the Aircraft Protocol, and there has been domestic harmonization work around these instruments and concepts (including IDERA). Academic analysis and market guidance confirm Turkey’s participation and legal alignment efforts.
Why this matters for lessors and lenders: Turkey-facing aircraft finance structures should be built with a clear plan for:
- perfection of security interests where applicable,
- registration steps and documentary integrity,
- enforcement and deregistration strategy,
- operational handover protocols and export logistics (where relevant).
B) Leasing disputes: preventable problems that keep recurring
The most common leasing disputes arise from:
- unclear maintenance responsibility and return condition standards,
- engine/APU LLP tracking disputes,
- delayed redelivery evidence problems (photos, reports, logs),
- insurance claims with inconsistent timelines and notice requirements,
- mismatch between English-law contracts and Turkey operational realities.
A strong legal design uses Turkey-specific annexes: local registration steps, Turkish-language notices where needed, clear law-and-jurisdiction strategy, and a practical repossession playbook.
7) Passenger rights in Turkey: delays, cancellations, denied boarding
Passenger claims are one of the highest-volume legal and reputational risks in aviation. Turkey regulates minimum passenger rights through SHGM’s Regulation on Air Passenger Rights (SHY-PASSENGER), which sets out minimum rights in cases such as denied boarding, cancellations, and delays.
What SHY-PASSENGER covers (conceptually)
While every case turns on facts, the regulation is designed around core passenger protections such as:
- Right to information and assistance
- Minimum standards for care (e.g., meals/refreshments in certain scenarios)
- Re-routing or refund logic (depending on circumstances)
- Compensation mechanisms in defined situations (with exceptions and proof burdens on certain issues)
Importantly, Turkey has also amended its passenger rights framework over time—e.g., an amendment published on 10 December 2024 extended compensation logic in relation to delays (as summarized in legal commentary).
Practical litigation strategy for passenger claims
For passengers: the winning strategy often depends on evidence—boarding passes, PNR, delay/cancellation notices, and airline communications.
For airlines: the best defense is not aggressive denial; it is documented operational justification, proof of timely information, and consistent, regulation-aligned customer handling. A poorly handled delay turns a small compensation matter into a reputational crisis and multi-layer litigation (consumer authorities + civil courts).
8) Carrier liability for injury, baggage, and cargo: the international convention layer
For international carriage by air, Turkey applies treaty-based liability regimes. Turkey’s treaty status materials and international lists of parties indicate Turkey’s participation in the 1999 Montreal Convention (Convention for the Unification of Certain Rules for International Carriage by Air).
Why Montreal Convention matters commercially
For airlines, cargo operators, freight forwarders, and insurers, Montreal Convention rules impact:
- liability thresholds and defenses (fact-dependent)
- documentation expectations (air waybills, baggage tags, reporting)
- jurisdiction and claims handling
- recoveries and subrogation disputes
If you operate internationally, you should align your customer terms, claims processing, and evidence retention with the Montreal regime—otherwise, disputes become significantly more expensive and unpredictable.
9) Accidents and incidents: investigation vs. liability
Aviation incidents often trigger two parallel tracks:
- Safety investigation (aimed at identifying causes and preventing recurrence), and
- Legal liability (civil, administrative, and potentially criminal).
Turkey’s investigation institution publishes accident investigation materials and defines duties and authorities through its legislation framework.
What businesses should do immediately after an incident
Whether you are an airline, airport operator, ground handler, MRO, or insurer, the first 24–72 hours determine the entire case:
- preserve evidence (records, CCTV, logs, photos, witness statements)
- notify insurers correctly and on time
- manage communications with regulators and investigation bodies
- engage technical experts early (especially for ground damage and maintenance disputes)
- control document creation (avoid speculative statements)
Many aviation disputes are “lost” at the evidence stage long before any courtroom.
10) UAV / drone law in Turkey: registration, approvals, and operational limits
Drone operations are one of the most active and misunderstood areas of aviation law. Turkey regulates unmanned aircraft systems through SHGM’s framework, including the SHT-İHA instruction and the online registry/permission system.
SHGM’s UAS registry information clearly states that pilots intending to fly a UAS weighing 500 grams or more in Turkish airspace must register and obtain approval, with reference to SHT-İHA.
Why drone compliance is a legal risk (not just an admin formality)
Commercial drone operations can intersect with:
- privacy/data protection (filming individuals, property, or private sites)
- critical infrastructure restrictions (airports, military zones, sensitive sites)
- insurance coverage gaps (many policies exclude unauthorized operations)
- contractual liability (client claims when permissions are missing)
If you run a drone business in Turkey (mapping, media, inspections, agriculture, construction), you need a compliance workflow: registration, operational permission planning, pilot qualifications, incident procedures, and client contract templates that allocate risk properly.
11) Aviation contracts you should not “copy-paste”
Aviation is contract-heavy. The following agreements often determine success more than the aircraft itself:
- aircraft lease (wet/dry), sublease, ACMI structures
- maintenance and component support agreements
- ground handling and airport services agreements
- charter agreements and broker arrangements
- codeshare/interline and SPA agreements
- cargo block-space agreements
- insurance placements and claims handling protocols
In Turkey-facing deals, a key legal principle is: your contract must match your regulatory status. A structure that looks elegant under English law can collapse if it contradicts SHGM licensing assumptions or operational control expectations.
12) Dispute resolution in Turkish aviation matters
Aviation disputes in Turkey typically fall into three buckets:
- Administrative disputes: licensing, permits, sanctions, and regulatory measures—often challenged before administrative courts under administrative procedure logic.
- Commercial disputes: leases, maintenance, ground handling, insurance, cargo contracts—frequently handled in commercial courts or arbitration depending on clause design.
- Consumer/passenger disputes: passenger rights claims, overbooking/denied boarding, delay compensation—handled through consumer channels and civil courts depending on claim type and value.
For sophisticated international transactions, arbitration is often preferred. Turkey has an established arbitration ecosystem, and the Istanbul Arbitration Centre (ISTAC) is commonly considered for Turkey-seated arbitration clauses in commercial disputes.
Key drafting point: If you want arbitration to work, you must draft for enforcement: seat, language, governing law, emergency measures, interim relief compatibility, and service-of-process mechanics.
13) Compliance checklist for aviation businesses entering Turkey
If you are entering the Turkish aviation market, a practical compliance plan usually includes:
Regulatory & licensing
- Determine your operator category (airline, air taxi, general aviation, UAS, ground handling, airport business).
- Map required permissions: operating license, AOC, manuals, approvals, training programs.
- Build governance and accountable management roles early.
Operations & safety
- Align flight ops systems with SHGM operational instructions and reporting expectations.
- Implement incident reporting and evidence retention workflows.
Contracts & insurance
- Use Turkey-aware contract annexes and enforceable notice procedures.
- Ensure insurance aligns with local risk: ground damage, passenger claims, cargo, drones.
Passenger & consumer exposure
- Implement SHY-PASSENGER-compliant customer handling and documentation.
- Update processes for regulatory amendments and compensation logic developments.
Drones/UAS
- Register, plan permissions, and operate within SHGM rules—especially for 500g+ platforms.
Finance & asset protection
- Structure leasing/financing with Cape Town/IDERA strategy and local enforcement planning.
14) FAQ: common questions in Turkish aviation law
Is Turkey’s aviation law mostly “EU-style” or “ICAO-style”?
Turkey operates within the global standards environment shaped by International Civil Aviation Organization (ICAO) and implements safety-oriented regulatory approaches through its national authority and secondary legislation.
Can foreign investors own a Turkish airline?
Ownership/control rules are highly sensitive in aviation. A compliant approach requires reviewing the licensing requirements (often tied to SHGM’s commercial air transport licensing framework) and structuring shareholding, governance, and control accordingly.
What is the main passenger rights rule in Turkey?
SHY-PASSENGER is the core regulation on passenger rights for denied boarding, cancellations, and delays, including minimum rights and compensation logic.
Does Montreal Convention apply to Turkey?
Turkey is listed among parties to the 1999 Montreal Convention in international party lists and Turkey’s own treaty status materials.
Do I need permission to fly a drone in Turkey?
For UAS weighing 500 grams or more, registration and approval via SHGM’s system are required, with reference to SHT-İHA.
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