Introduction: What Must a Foreign Company Know Before Hiring Employees in Turkey?

Hiring personnel in Turkey may appear straightforward from a commercial perspective.

A foreign investor establishes a Turkish subsidiary, rents an office or factory, recruits local employees and begins operating.

Legally, however, employment creates a separate compliance structure involving Turkish labour law, social security legislation, payroll taxation, occupational health and safety, immigration rules and employee data protection.

This becomes particularly important for multinational businesses because employment practices routinely used in London, New York, Dubai, Amsterdam or Singapore cannot automatically be copied into Turkey.

For example, a foreign company may be accustomed to:

• terminating employees “at will”;
• using repeated one-year fixed-term employment contracts;
• including broad overtime waivers in salaries;
• monitoring corporate e-mail without a detailed employee privacy policy;
• transferring HR records automatically to overseas headquarters;
• hiring foreign executives immediately while a work permit is processed;
• classifying individuals as consultants instead of employees;
• or changing an employee’s position and salary unilaterally.

Each of these practices can create material legal risks in Turkey.

Turkish employment law is protective of employees and contains mandatory rules concerning wages, working hours, annual leave, termination and workplace safety.

Employers also face potentially significant liabilities for incorrectly terminating personnel.

Employees covered by job-security provisions can challenge a dismissal through mandatory mediation and potentially seek reinstatement. The Ministry of Labour confirms that job-security protection generally applies where the relevant workplace has at least 30 employees and the dismissed employee has at least six months of service. A reinstatement challenge begins with mandatory mediation within one month of notification of dismissal.

Foreign companies should therefore build a Turkish HR compliance framework from the beginning rather than attempt to correct employment documentation after a dispute begins.

This guide explains the principal legal issues foreign-owned businesses should consider when hiring and managing personnel in Turkey in 2026.

1. Determine Who the Legal Employer Will Be

The first question is surprisingly important:

Who actually employs the worker?

A foreign business operating in Turkey may use several structures:

• a Turkish subsidiary;
• a Turkish branch;
• a liaison office where legally permitted;
• another Turkish group company;
• an authorised temporary employment arrangement;
• or, in limited situations, personnel seconded by an overseas company.

The employment contract, payroll, social security registration and work-permit structure should all be consistent with the actual employer.

A common multinational mistake is to place an employee on a foreign parent company’s contract while the employee works permanently:

• in a Turkish office;
• under Turkish management;
• for the Turkish subsidiary;
• and as part of the Turkish operation.

Simply paying salary from abroad does not necessarily prevent Turkish labour, social security or tax rules from becoming relevant.

The employment structure should follow the economic reality.

2. Turkish Labour Law May Apply Even If the Employer Is Foreign-Owned

A Turkish company does not escape Turkish employment law because its shareholder is foreign.

If the employee works under an employment relationship governed by Turkish labour law, mandatory employee protections apply regardless of whether the ultimate parent company is:

• German;
• British;
• American;
• Dutch;
• Chinese;
• Emirati;
• or another nationality.

Foreign headquarters should therefore treat Turkey as a distinct employment jurisdiction.

A global employee handbook can still be used, but it should be supplemented by a Turkey-specific employment policy.

Local mandatory rules should prevail where a global policy provides a lower level of protection.

3. Use Carefully Drafted Employment Contracts

Written employment contracts are strongly advisable for all employees, even where Turkish law may not require the same formality for every indefinite-term relationship.

The agreement should clearly regulate matters such as:

• employer identity;
• employee position;
• job description;
• workplace;
• salary;
• bonus;
• benefits;
• working hours;
• overtime;
• probation where applicable;
• confidentiality;
• intellectual property;
• remote work;
• company equipment;
• data protection;
• termination;
• restrictive covenants where appropriate;
• and applicable workplace policies.

The contract should be drafted for Turkish employment law rather than simply translating a foreign template.

A clause that is valid in another jurisdiction may not produce the intended effect in Turkey.

4. Be Careful With Fixed-Term Employment Contracts

Foreign employers sometimes prefer one-year renewable agreements because they appear to provide greater termination flexibility.

That approach can be risky.

Under Turkish labour law, indefinite-term employment is generally the normal model. A fixed-term contract should have a genuine objective justification connected with matters such as:

• completion of a particular project;
• a specific temporary task;
• replacement of an absent employee;
• or another objectively limited employment need.

Repeated fixed-term contracts without a genuine legal basis can be treated as indefinite-term employment.

Therefore, a company should not automatically place all executives or professional employees on renewable one-year contracts merely because that structure is used at the group level.

5. Probation Does Not Mean “Unregistered Employment”

A probation period can provide flexibility at the beginning of an employment relationship.

However, probation does not allow the employer to:

• avoid salary;
• avoid social security;
• or employ the worker informally.

The employment relationship exists during probation.

The employee should therefore be properly registered and paid from the first day.

The Ministry’s employment guidance confirms that termination during a valid probation period is treated differently for notice-compensation purposes, but the employee’s statutory employment status does not disappear during that period.

Foreign employers should particularly avoid the practice:

“Work for us for two months, and if we are satisfied we will put you on payroll.”

That approach can create both employment and SGK risks.

6. Register Employees With the Turkish Social Security Institution

Employees falling within the normal employee insurance regime must be registered with the Social Security Institution — Sosyal Güvenlik Kurumu (SGK).

SGK states that an employee commencement notification should generally be filed electronically at least one day before the employee starts working, subject to specific statutory exceptions.

This is an important operational rule.

HR teams should not wait until the end of the employee’s first week to inform payroll.

The proper internal workflow should be:

employment approval → contract → payroll onboarding → SGK notification → first working day.

Failure to register personnel correctly can lead to administrative penalties and increased exposure in the event of an occupational accident.

7. Understand the Real Employer Cost of Salary in Turkey

A foreign investor should not calculate Turkish employment cost using only the employee’s net salary.

The employer may have to account for:

• gross salary;
• employer SGK contribution;
• unemployment insurance contribution;
• income tax withholding;
• stamp tax where applicable;
• bonuses;
• meal and transportation benefits;
• overtime;
• private insurance;
• severance exposure;
• annual leave;
• and other contractual benefits.

For 2026, the statutory monthly gross minimum wage is TRY 33,030 and the monthly net minimum wage is TRY 28,075.50. The Ministry’s current calculation shows that total monthly employer cost at minimum wage is approximately TRY 39,223.13 in manufacturing where the stated five-point SGK discount applies, TRY 40,214.03 for other sectors using the two-point discount illustrated by the Ministry, and TRY 40,874.63 where no SGK premium discount is applied.

The exact employer cost for an individual employee depends on the salary, applicable premium ceilings, incentives and employee status.

8. Payroll Is Subject to Turkish Income Tax Rules

Employment income is generally taxed progressively.

For 2026, Turkey’s income tax tariff begins at 15%, rises through 20%, 27% and 35%, and reaches 40% at the highest income levels, with a specific higher threshold applicable to employment income in the 27% band.

The minimum-wage income tax exemption also continues.

GİB confirms that the portion of employees’ wage income corresponding to the statutory minimum-wage exemption is excluded from income tax under the current rules.

This means a foreign employer should budget salaries on a gross-to-net payroll basis rather than promise a net salary without understanding how progressive taxation affects annual employer cost.

Where a net salary has been guaranteed contractually, movements between Turkish tax bands can shift additional cost to the employer.

9. A New 2026 Incentive May Be Relevant for Certain Foreign Investment Service Centres

Foreign investors should also note an important 2026 development.

Following amendments enacted in 2026, qualifying employees working in certain Qualified Service Centres under the Foreign Direct Investment Law can benefit from an income tax exemption.

Current GİB guidance provides that qualifying personnel may receive an income-tax exemption for salary up to three times the gross minimum wage, while employees in specified qualifying industrial zones and qualified service centres operating in the Istanbul Finance Centre can benefit up to five times the gross minimum wage, subject to the statutory conditions.

This is not a general exemption for every foreign-owned company.

However, multinational businesses establishing regional service, finance or support operations in Turkey should examine whether the new regime applies.

10. Salary Must Be Paid Regularly and Properly Documented

The Ministry confirms that wages must generally be paid at least monthly. Employers with at least five employees are also subject to the current requirement to make qualifying salary and similar payments through banks.

Delayed payroll can create serious employee rights.

Where salary is not paid within 20 days of the payment date without force majeure, Turkish labour law allows the employee to refrain from working under the statutory conditions. Delayed salary also attracts the statutory special interest treatment.

Multinational treasury delays therefore cannot be treated casually.

An overseas headquarters saying:

“Payroll will be delayed until the group releases cash next week”

may create a Turkish labour-law problem.

11. Normal Weekly Working Time Is 45 Hours

The general statutory maximum normal working week under the Turkish Labour Law is 45 hours.

Work beyond 45 hours generally constitutes overtime, subject to statutory rules and permitted balancing arrangements.

The 45 hours may be distributed among working days within the permitted daily limits.

Foreign companies frequently operate a five-day schedule such as:

Monday–Friday, 09:00–18:00

with legally compliant rest breaks.

However, the real working time must be calculated correctly.

Meal and qualifying rest breaks do not necessarily count as working time.

The Ministry confirms that where daily work exceeds 7.5 hours, the minimum rest break is generally one hour, while shorter working days have lower statutory minimum breaks.

12. Overtime Must Be Controlled and Recorded

Where the normal weekly working time is 45 hours, work above 45 hours is generally paid at 150% of the employee’s ordinary hourly wage.

The Ministry confirms that one hour of overtime is compensated by increasing the ordinary hourly rate by 50%.

If the contractual weekly working time is below 45 hours—for example 40 hours—work between the contractual limit and 45 hours is treated differently and generally attracts the statutory 25% increase applicable to “extra hours” rather than full statutory overtime.

The total amount of statutory overtime is generally limited to 270 hours per year, and employee approval is required for overtime work under the applicable rules.

Employers should maintain reliable working-time records.

This is especially important for:

• factories;
• sales teams;
• logistics;
• call centres;
• shift workers;
• remote workers;
• and staff who frequently travel.

An employer facing an overtime claim years later may have difficulty defending the case if it maintained no credible working-time records.

13. “Overtime Included in Salary” Clauses Require Careful Drafting

Some foreign companies use employment contracts stating:

“All overtime is included in the monthly salary.”

Such provisions should not be treated as an unlimited waiver of Turkish overtime rights.

The legal enforceability depends on factors including:

• salary level;
• wording;
• employee position;
• actual hours worked;
• and the statutory 270-hour annual limit.

A contract should never suggest that an employee can be required to work unlimited overtime for no additional compensation.

For many employers, the safer approach is to maintain a clear overtime approval and recording procedure.

14. Employees Are Entitled to Weekly Rest and Public Holiday Rights

Turkish employees are entitled to weekly rest under statutory conditions.

The Ministry states that weekly rest is generally 24 uninterrupted hours after the required working period.

National and public holidays also require special treatment.

Where an employee does not work on the public holiday, normal salary continues.

Where the employee works on the public holiday, an additional day’s wage is generally payable for that day under the Labour Law framework.

International companies should therefore ensure that global holiday calendars do not replace Turkish statutory holidays for Turkish employees.

15. Annual Paid Leave Increases With Seniority

Employees normally become entitled to annual paid leave after completing at least one year of service, including the probation period.

The statutory minimum leave periods are:

The Ministry confirms these statutory minimums and also notes that workers aged 18 or younger and workers aged 50 or older must receive at least 20 days.

The contract or collective bargaining agreement may provide more generous leave.

Leave records should be maintained carefully.

Unused statutory leave normally becomes a monetary claim when employment ends.

16. Maternity and Family-Related Rights Must Be Reflected in HR Policies

Turkish labour law includes significant maternity protections.

The general maternity period is:

8 weeks before birth + 8 weeks after birth = 16 weeks.

An additional two weeks applies to the prenatal period in multiple pregnancies.

There are also rights concerning:

• unpaid maternity-related leave;
• half-time work after childbirth in specified circumstances;
• nursing breaks;
• partial-time working;
• and five days of paid paternity leave for an employee whose spouse gives birth.

Foreign HR manuals should therefore be adjusted to Turkish statutory minimums even where the parent company’s global maternity policy differs.

17. Do Not Discriminate in Employment Decisions

Turkish labour law contains an equal-treatment principle.

Among other protections, an employer cannot treat employees differently because of sex or pregnancy unless biological reasons or the nature of the work objectively require different treatment.

The Ministry specifically confirms that a female employee cannot receive lower pay than a male employee merely because of gender where the work is the same or of equal value. A breach may expose the employer to compensation of up to four months’ wages in addition to other employee claims.

Multinationals should therefore review:

• recruitment criteria;
• salary bands;
• promotion systems;
• bonus metrics;
• parental leave;
• and termination decisions

for objective consistency.

18. Turkish Employees Cannot Generally Be Terminated “At Will”

This is one of the most important differences for foreign employers.

Turkey does not operate a broad US-style employment-at-will system.

Termination may require:

• notice;
• valid cause;
• just cause;
• written procedure;
• severance;
• or combinations of these depending on the employee and circumstances.

For indefinite-term employment, statutory notice periods generally range from:

• 2 weeks for service under six months;
• 4 weeks for service between six months and 1.5 years;
• 6 weeks for service between 1.5 and 3 years;
• 8 weeks for service over three years.

The employer can generally terminate immediately by paying the corresponding notice compensation where the statutory conditions allow.

19. Job-Security Protection Creates Reinstatement Risk

Where a workplace has at least 30 employees and the employee has at least six months’ seniority, job-security provisions may apply, subject to the statutory exclusions.

The employer should then have a valid reason connected with:

• employee competence;
• employee behaviour;
• or operational/business/workplace requirements.

The Ministry states that dismissal should be in writing and the reason should be clearly stated.

For dismissals based on performance or behaviour, employers should follow proper evidentiary and procedural steps.

For example, in performance cases the Ministry emphasises:

• obtaining the employee’s defence where required;
• giving a reasonable monitoring/improvement opportunity where appropriate;
• and using objective, measurable performance criteria.

A statement such as:

“Head office no longer feels comfortable with the employee”

is not a strong Turkish termination file.

20. Reinstatement Claims Can Be Expensive

A protected employee who claims the dismissal lacked valid grounds must first apply to mandatory mediation within one month after receiving the dismissal notice.

If mediation fails, court proceedings may follow within the statutory period.

If the dismissal is found invalid and the employer does not reinstate the employee after the employee follows the statutory reinstatement procedure, the employer can face compensation equal to between four and eight months’ salary, together with up to four months of wages and other rights relating to the period specified by law.

For senior executives, this exposure can be substantial.

Termination decisions should therefore be legally reviewed before—not after—the employee receives the notice.

21. Severance Pay Must Be Included in Employment Cost Forecasting

Employees can become entitled to kıdem tazminatı — severance pay where employment ends under qualifying circumstances after the necessary seniority.

The basic calculation is generally 30 days’ gross wage for each full year of service, with proportional calculation for additional periods. Regular monetary and measurable benefits such as recurring meal, transportation and bonus payments can also affect the severance base.

The statutory severance ceiling is updated twice each year.

For 1 July–31 December 2026, the current ceiling is TRY 73,729.87 per year of service.

A multinational planning restructuring or mass workforce reduction should therefore budget:

notice + severance + unused annual leave + unpaid salary/bonus + possible reinstatement exposure.

Looking only at monthly salary materially understates termination cost.

22. Just-Cause Termination Should Not Be Used Lightly

Turkish law permits immediate termination without notice in specific serious circumstances.

Examples can include certain:

• dishonesty;
• harassment;
• abuse of trust;
• workplace crime;
• unjustified absenteeism;
• persistent refusal to perform duties;
• or serious workplace safety violations.

The Ministry provides detailed examples under Article 25 of the Labour Law.

However, an employer should not describe an ordinary performance issue as “gross misconduct” simply to avoid severance and notice payments.

A disputed just-cause termination can lead to litigation over:

• severance;
• notice;
• reinstatement;
• overtime;
• bonus;
• and other employment claims.

Evidence should be preserved before dismissal.

23. Foreign Employees Usually Need a Turkish Work Permit

Hiring Turkish nationals and hiring foreign nationals are legally different processes.

A foreign employee generally needs a valid Turkish work permit or applicable work-permit exemption before lawfully working.

The Ministry confirms that a standard dependent work permit is generally issued for a particular:

• employer;
• workplace;
• occupation;
• and period,

and the initial permit can be granted for up to one year, subject to the employment or service contract.

A residence permit alone is not automatically a work permit.

Conversely, an ordinary valid work permit generally also serves as a residence permit under the relevant immigration legislation, subject to specific categories.

24. Work Permit Applications Are Subject to Employer Criteria

Current 2026 work-permit evaluation criteria generally require employers to satisfy employment and financial standards.

Under the general framework, an employer subject to balance-sheet accounting is normally expected to employ at least five Turkish citizens for each foreign employee.

A newly established employer generally needs at least TRY 500,000 paid-up capital.

An existing business generally needs to satisfy at least one of the following:

• TRY 500,000 paid-up capital;
• TRY 8 million net sales;
• or USD 150,000 exports.

Work-permit salary requirements also vary by employee category:

• senior executives and pilots: at least 5× gross minimum wage;
• engineers and architects: 4×;
• other managers: 3×;
• specialist/skilled positions: 2×;
• other qualifying occupations: at least the minimum wage.

Sector-specific exceptions apply.

The Ministry revised several work-permit criteria effective 3 August 2026, including special arrangements affecting manufacturing and certain other sectors as well as exemptions for specified foreigners with prior lawful residence in Turkey.

Therefore, foreign companies should check the rules applicable on the actual application date rather than relying on an older HR checklist.

25. Employing a Foreigner Without a Permit Is Expensive

The 2026 administrative fine for an employer employing a foreigner without the required work permit is TRY 102,503 per foreign employee.

The foreign worker can also be fined.

Failure to comply with applicable notification duties can result in additional penalties, and repeated violations are subject to increased sanctions.

The employer can also face immigration and social-security consequences beyond the headline administrative fine.

A foreign executive should therefore not begin working simply because:

“The permit application has already been submitted.”

The exact legal status should be confirmed first.

26. International Social Security Agreements May Help With Seconded Employees

Turkey has bilateral or multilateral social security arrangements with a number of countries.

The Ministry confirms that where an applicable social security agreement exists, certain foreign employees temporarily sent to Turkey by an employer in the treaty country may remain subject to that country’s social security system and be exempt from Turkish social-security obligations for the period specified in the relevant agreement, provided applicable requirements are satisfied.

This can be particularly relevant for multinational groups sending senior employees to Turkey for:

• project implementation;
• factory commissioning;
• regional management;
• or temporary assignments.

The applicable treaty and certificate-of-coverage requirements should be reviewed before assignment.

27. Occupational Health and Safety Is a Core Employer Obligation

Turkey’s Occupational Health and Safety Law No. 6331 has broad application.

The Ministry confirms that the legislation applies across public and private workplaces and covers employees as well as employers and employer representatives, subject to statutory exceptions.

Employers must conduct or arrange a workplace risk assessment.

The Ministry expressly states that risk assessment is required in all workplaces covered by Law No. 6331.

Depending on the workplace risk classification and size, additional obligations can include:

• occupational safety specialists;
• workplace physicians;
• health surveillance;
• employee training;
• emergency plans;
• protective equipment;
• accident reporting;
• periodic machinery inspection;
• and professional competency requirements.

Factories, warehouses and construction-related operations require particularly careful compliance.

28. Workplace Accidents Can Create Multiple Forms of Liability

An occupational accident should not be viewed only as an SGK matter.

Depending on the circumstances, employer exposure can include:

• SGK recourse;
• employee compensation;
• moral damages;
• administrative fines;
• criminal liability of managers or responsible individuals;
• and regulatory inspection consequences.

Foreign parent companies should therefore insist on the same level of occupational safety compliance in Turkish subsidiaries as they would in heavily regulated home jurisdictions.

A policy translated from English is not enough.

Actual workplace implementation matters.

29. Remote Work Requires a Turkish-Law Framework

Remote work is expressly regulated in Turkey.

The Remote Working Regulation applies to Labour Law employees and defines remote work as work performed at home or outside the workplace through technological communication tools within the employer’s organisation.

A compliant remote-work arrangement should address subjects including:

• place of work;
• equipment;
• expenses;
• working hours;
• communication;
• information security;
• occupational safety;
• and data protection.

Foreign businesses hiring Turkish employees remotely should avoid assuming that no Turkish employment rules apply simply because the company has no physical office.

The actual structure may also create separate tax, corporate presence and permanent establishment questions for the foreign company.

30. Employee Personal Data Is Protected by the KVKK

Employers process extensive employee information, including:

• identification;
• salary;
• bank information;
• performance data;
• disciplinary records;
• medical information;
• criminal-record information where relevant;
• access logs;
• photographs;
• camera recordings;
• and corporate communications.

Turkish data protection law therefore becomes a major HR compliance issue.

The Personal Data Protection Authority has specifically sanctioned employers for processing employee personal and sensitive data without properly satisfying transparency and legal-basis requirements.

Foreign companies should have a Turkish employee privacy framework covering:

• legal bases;
• privacy notices;
• retention;
• access controls;
• international HR transfers;
• monitoring;
• deletion;
• and employee rights.

31. Do Not Transfer HR Files Automatically to Foreign Headquarters

Many multinational groups use a central global HR platform.

Turkish employee information may automatically be stored in:

• Germany;
• Ireland;
• the US;
• Singapore;
• or another jurisdiction.

This can constitute an international personal-data transfer under the KVKK.

Employee data should therefore not simply be uploaded abroad because:

“Our HR system is global.”

The company should analyse:

• the Turkish data controller;
• the foreign recipient;
• applicable data-processing grounds;
• cross-border transfer mechanism;
• sensitive-data categories;
• and employee privacy notices.

This is particularly important for medical, biometric and other special-category employee data.

32. Employee E-Mail Monitoring Is Not Unlimited

Employers have legitimate interests in protecting:

• information security;
• trade secrets;
• compliance;
• company assets;
• and corporate communications.

But this does not give an unlimited right to read every employee communication.

The Turkish Data Protection Board has stated that employer monitoring should involve a balance between employer interests and employee privacy.

Relevant considerations include:

• advance employee notice;
• scope of monitoring;
• purpose;
• proportionality;
• whether content or merely traffic is monitored;
• duration;
• who can access the records;
• and whether less intrusive methods could achieve the objective.

Foreign companies should therefore maintain clear:

IT Acceptable Use + Employee Monitoring + Privacy Policies.

33. Secret Audio Recording Through Workplace Cameras Is Particularly Risky

Camera surveillance may be justified for legitimate security purposes where the applicable KVKK requirements are met.

Audio recording is considerably more intrusive.

In a 2023 decision, the Turkish Data Protection Board concluded that, in the circumstances examined, adding audio recording to workplace camera monitoring was not necessary or proportionate for security and lacked an appropriate legal basis.

Employers should therefore not purchase surveillance systems with continuous audio enabled merely because the technology allows it.

34. A Major 2026 Rule: Do Not Use Fingerprints or Facial Recognition Merely for Attendance Tracking

Foreign employers should pay particular attention to a new 2026 development.

In its 29 April 2026 Principle Decision No. 2026/921, the Personal Data Protection Board addressed the growing use of biometric systems for employee attendance.

The Board concluded that, under the current framework, biometric processing for ordinary attendance tracking generally fails proportionality where less intrusive alternatives exist. It specifically pointed employers toward alternatives such as:

• encrypted cards;
• PIN systems;
• traditional signature records;
• RFID/NFC employee cards;
• or supervised manual entry.

The Board also emphasised that employee consent is problematic because of the inherent power imbalance in employment and that even apparently valid consent does not cure a disproportionate biometric attendance system.

This is highly relevant to factories and offices using:

fingerprint readers or facial-recognition terminals for clock-in/clock-out.

Foreign companies should reassess those systems.

35. Collective Bargaining Agreements Can Override Less Favourable Contract Terms

If a Turkish workplace is covered by a collective bargaining agreement, the employer must analyse that agreement separately from individual employment contracts.

The Ministry confirms that individual employment terms generally cannot contradict applicable collective bargaining provisions unless the individual contractual term is more favourable to the employee.

Foreign investors acquiring an existing Turkish company should therefore conduct labour due diligence on:

• union membership;
• authorised unions;
• collective agreements;
• ongoing negotiations;
• and industrial-action history.

A collective agreement can materially change:

• wages;
• bonuses;
• leave;
• overtime;
• severance;
• and working conditions.

36. Outsourcing Does Not Automatically Remove Employer Liability

Foreign companies frequently outsource:

• cleaning;
• security;
• logistics;
• catering;
• warehousing;
• production support;
• and other services.

Turkish law regulates the relationship between principal employers and subcontractors.

The Ministry confirms that a principal employer can be jointly responsible with a subcontractor for specified employee obligations arising from law, the employment contract or applicable collective agreement in relation to the workplace.

Therefore, selecting a subcontractor purely on price can be dangerous.

Companies should conduct vendor employment compliance due diligence and obtain contractual protections concerning:

• salary payments;
• SGK;
• overtime;
• occupational safety;
• work permits;
• and employee records.

37. Business Transfers Do Not Automatically Terminate Employees

This point matters particularly for M&A.

Where a workplace or business transfers to a new employer, employees generally continue with the transferee under their existing employment terms.

The Ministry confirms that a workplace transfer does not by itself create a right for employees to demand severance merely because ownership has changed, and pre- and post-transfer service is generally combined for purposes such as severance and annual leave.

For liabilities arising before the transfer and due at transfer, the transferor and transferee can also have joint liability for the statutory period.

Foreign buyers should therefore include employment liabilities in acquisition due diligence.

38. A Practical HR Compliance Structure for a Foreign Company in Turkey

Assume a US technology company establishes a Turkish subsidiary and plans to employ:

• one country manager;
• two software developers;
• one finance manager;
• one HR manager;
• and ten sales and support employees.

Before hiring, the company should establish:

Turkish employment contract templates, including confidentiality, IP and remote-work terms.

It should register the Turkish workplace with SGK and create a procedure ensuring every employee is registered before commencing work.

Payroll should be configured for Turkish:

• SGK;
• unemployment insurance;
• income tax;
• minimum-wage tax exemption;
• and statutory benefits.

Working-time policies should address:

• 45-hour limit;
• overtime;
• approval;
• time recording;
• weekly rest;
• and public holidays.

Annual leave should be tracked based on Turkish seniority rules.

A termination procedure should require Turkish legal review before dismissing protected employees.

Foreign executives should not begin working until work-permit status has been confirmed.

The company should also implement:

• occupational safety procedures;
• employee KVKK notice;
• international HR data-transfer compliance;
• monitoring policy;
• and remote-working rules.

That structure substantially reduces employment disputes compared with importing the US employee handbook unchanged.

Foreign Employer Compliance Checklist

Before employing personnel in Turkey, a foreign-owned business should confirm:

Frequently Asked Questions

Can a foreign-owned company hire Turkish employees?

Yes. A Turkish company owned partly or entirely by foreign investors can employ Turkish personnel in the same general manner as other Turkish employers.

What is the 2026 minimum wage in Turkey?

The monthly gross minimum wage is TRY 33,030, and the monthly net minimum wage is TRY 28,075.50 for 2026.

What is the ordinary weekly working time?

The statutory normal maximum is generally 45 hours per week.

How is overtime paid?

Ordinary statutory overtime beyond 45 weekly hours is generally paid at 150% of the normal hourly rate.

Is there an annual overtime limit?

Yes. Ordinary overtime generally cannot exceed 270 hours per year.

How much annual leave does an employee receive?

The minimum is generally 14 days for one to five years of service, 20 days for more than five and less than 15 years, and 26 days for 15 years or more.

What are the statutory notice periods?

They are generally 2, 4, 6 or 8 weeks depending on seniority.

How is severance calculated?

Where the employee qualifies, the basic calculation is generally 30 days of gross salary for each full year of service, subject to the statutory severance ceiling and the inclusion of qualifying recurring benefits.

What is the current 2026 severance ceiling?

For 1 July–31 December 2026, the ceiling is TRY 73,729.87 per year.

Can employees challenge termination?

Yes. Employees covered by job-security protection can challenge an allegedly invalid dismissal through mandatory mediation and potentially reinstatement litigation. The ordinary threshold includes at least 30 employees at the workplace and six months’ service.

Does a foreign employee need a work permit?

Generally yes unless a statutory work-permit exemption applies.

What is the penalty for employing a foreigner without a work permit in 2026?

The administrative fine imposed on the employer is TRY 102,503 for each foreigner employed without a permit.

Can a foreign company monitor employee e-mails?

Potentially, but monitoring must have an appropriate legal basis and satisfy transparency, necessity and proportionality requirements.

Can an employer use fingerprint recognition for attendance?

The KVKK Board’s 2026 Principle Decision takes a highly restrictive position on using biometric data merely for employee attendance and directs employers toward less intrusive methods such as cards, PINs or RFID/NFC systems.

Conclusion: How Should Foreign Companies Build an Employment Compliance System in Turkey?

For a foreign company, hiring personnel in Turkey should not be treated as a simple administrative extension of global HR.

Turkish employment law creates its own mandatory framework.

The foreign-owned business should therefore begin by identifying the correct employer entity.

Payroll, social security, work permits and employment contracts should all reflect who actually manages and employs the worker.

The next stage is documentation.

Employment agreements should be prepared under Turkish law.

Foreign fixed-term templates should not be used automatically.

Confidentiality, intellectual property, bonus, remote-work, overtime and termination clauses should be adapted to Turkish mandatory rules.

The third stage is payroll and social security.

Employees generally need to be registered with SGK before starting work.

The 2026 gross minimum wage is TRY 33,030, but the employer’s real monthly employment cost is higher once SGK and unemployment insurance are included.

The fourth stage is working-time compliance.

Ordinary weekly working time generally cannot exceed 45 hours, while overtime attracts a 50% premium and is ordinarily subject to the 270-hour annual maximum.

Foreign companies should maintain actual time records rather than relying solely on contract wording.

The fifth stage is statutory leave.

Employees acquire annual paid leave after completing one year, with statutory minimum periods rising from 14 to 20 and then 26 days according to seniority.

Turkish maternity, paternity, nursing and family-related rights should also be built into local HR policies.

The sixth stage is termination.

This is the area where foreign companies most frequently underestimate Turkish risk.

Turkey does not generally recognise an unrestricted at-will dismissal system.

Notice periods, severance, valid reasons, just causes and job-security procedures must be analysed separately.

Where job-security protection applies, an employee can challenge dismissal through mandatory mediation and potentially obtain reinstatement-related compensation.

Termination planning should therefore follow:

reason → evidence → procedural review → notice/severance calculation → written dismissal → mediation/litigation risk assessment.

The seventh stage is foreign personnel.

A foreign national should not begin working merely because the employer has submitted a permit application.

Current work-permit criteria impose employer financial and employment thresholds and salary requirements based on the position.

The rules were further updated on 3 August 2026 for certain employee groups and sectors, making current-date review important.

The eighth stage is occupational health and safety.

Every covered workplace requires risk assessment, and dangerous industrial workplaces require significantly more extensive compliance.

For factories and warehouses, occupational safety should be treated as a board-level legal issue rather than an administrative HR formality.

The ninth stage is employee privacy.

Foreign companies increasingly centralise HR, e-mail, CCTV and attendance systems.

This creates significant KVKK exposure.

The Turkish Data Protection Board expects employers to justify monitoring and balance employer interests against employee privacy.

The 2026 biometric attendance decision is particularly important: ordinary attendance tracking by fingerprint, facial recognition or similar biometric tools will generally be very difficult to justify where less intrusive alternatives exist.

For multinational groups, the most effective Turkish employment compliance framework can therefore be summarised as:

local employer structure → Turkish employment contracts → SGK/payroll → working-time records → leave system → OHS → foreign work permits → termination protocol → KVKK/HR data compliance → subcontractor and union monitoring.

The key lesson is simple:

A foreign-owned company may operate globally, but its Turkish employees are employed locally.

Global HR policies are useful.

They are not a substitute for Turkish employment law.

Before hiring the first employee, a foreign investor should be able to answer:

Who employs this person?

How will salary, SGK and tax be handled?

What hours, overtime and leave rules apply?

What would it cost to terminate the employee legally?

If the employee is foreign, can they legally begin working?

Where will the employee’s personal data be stored and transferred?

When those questions are addressed at the beginning of the employment relationship, Turkey provides a predictable framework for hiring and managing personnel.

When they are ignored, routine HR decisions can turn into expensive:

overtime claims + severance disputes + reinstatement litigation + SGK penalties + work-permit fines + occupational safety liability + KVKK sanctions.

For foreign companies entering the Turkish market, employment compliance should therefore be treated as part of the original investment structure—not as an HR issue to be addressed after recruitment begins.

This article reflects Turkish employment, social security, work permit, occupational safety, payroll and personal data protection rules and publicly available official guidance as of August 2026. It is intended for general informational purposes only and does not constitute employee-specific legal, tax, immigration, payroll or HR advice. The applicable rules may differ according to the employer’s sector, workplace size, employee role, salary, seniority, nationality, collective bargaining status and the circumstances of termination.