What Are the Conditions for Acquiring Turkish Citizenship by Exception?

The acquisition of Turkish citizenship may be possible through different legal means under Turkish law. One of these means is the acquisition of Turkish citizenship by exception. Exceptional citizenship is a special method of acquiring citizenship that allows a foreign national to acquire Turkish citizenship by a decision of the President when the special circumstances prescribed by law are fulfilled, rather than requiring all of the conditions generally applicable to the acquisition of Turkish citizenship.

The principal legal basis for the acquisition of Turkish citizenship by exception is Article 12 of Law No. 5901 on Turkish Citizenship and Article 20 of the Regulation on the Implementation of the Turkish Citizenship Law. Under the current version of Article 20 of the Regulation, foreign nationals who satisfy any of the specified investment conditions may acquire Turkish citizenship by a decision of the President pursuant to Article 12, paragraph 1(b) of the Law. (lexpera.com.tr)

The exceptional citizenship system is, in particular, a mechanism designed to encourage investment in Türkiye, promote capital inflows, create employment, and direct investments toward certain investment instruments within the Turkish economy. However, merely making an investment does not mean that citizenship is automatically acquired. The investment must satisfy the qualifications prescribed by the applicable legislation, its compliance must be determined by the competent authority, and the citizenship application must pass through the relevant administrative procedures.

Acquisition of Turkish Citizenship by Exception

Article 12 of the Turkish Citizenship Law allows certain foreign nationals to be admitted to Turkish citizenship on an exceptional basis.

Article 20, paragraph 1 of the Regulation also provides that foreign nationals may acquire Turkish citizenship exceptionally in the circumstances specified in Article 12 of the Law.

An important point here is that exceptional citizenship is not, in the strict sense, an automatic method of acquiring citizenship. The fulfillment of the conditions prescribed by the Law and the Regulation does not itself confer citizenship status on the applicant. The fulfillment of those conditions must be determined by the competent authorities, followed by the relevant citizenship decision.

Accordingly, citizenship through investment should be regarded as a comprehensive process consisting of making the relevant investment, obtaining the necessary certificate or determination from the competent authority, submitting the citizenship application, and completing the relevant administrative assessment.

Legal Basis for Acquiring Exceptional Citizenship through Investment

Article 20, paragraph 2 of the Regulation is one of the most important provisions concerning exceptional citizenship through investment.

According to this provision, a foreign national who satisfies any one of the specified investment conditions may acquire Turkish citizenship by a decision of the President pursuant to Article 12, paragraph 1(b) of the Turkish Citizenship Law. (lexpera.com.tr)

Accordingly, an investor is not required to carry out all investment types simultaneously. Satisfying one of the investment options specified in the Law and the Regulation, together with the required amount and holding-period conditions, may be sufficient.

These investment options include fixed capital investment, acquisition of real estate, creation of employment, deposits in banks, acquisition of government debt instruments, acquisition of investment fund participation shares, and investment in the private pension system. (lexpera.com.tr)

Acquisition of Citizenship through Fixed Capital Investment

One of the methods of acquiring exceptional citizenship is making a fixed capital investment.

Under Article 20 of the Regulation, foreign nationals whose fixed capital investment of at least USD 500,000 or the equivalent amount in foreign currency is determined by the Ministry of Industry and Technology may apply for citizenship under this provision.

However, merely making an investment of a certain amount is not sufficient. The investment must qualify as a fixed capital investment within the meaning of the Regulation, and the competent Ministry must determine that the relevant condition has been fulfilled. (lexpera.com.tr)

This provision is intended to encourage investments that directly create economic activity and productive capacity.

For an application based on fixed capital investment, the reality, amount, and legal qualifications of the investment are assessed by the competent authority. Therefore, from the investor’s perspective, it is important not only to carry out the financial transaction but also to ensure that the investment is made within the scope prescribed by the legislation.

Acquisition of Turkish Citizenship through the Acquisition of Real Estate

One of the most well-known investment routes for exceptional citizenship is acquiring real estate.

Under the current regulation, foreign nationals who purchase qualifying real estate worth at least USD 400,000 or the equivalent amount in foreign currency and place a restriction in the land registry preventing the sale of the property for three years may apply under this provision. In addition, subject to the conditions specified in the Regulation, a notarized preliminary agreement for the sale of qualifying real estate and the registration of the relevant restriction in the land registry may also fall within the scope of the regulation. (lexpera.com.tr)

Two elements are particularly important in citizenship through real estate investment.

First, the value of the real estate must satisfy the minimum investment amount prescribed by the Regulation.

Second, the investor must comply with the three-year holding requirement, meaning that the property must not be disposed of during the specified period.

Therefore, purchasing the property alone is not sufficient. The necessary restriction must be recorded in the land registry, and the investment must satisfy the conditions required for citizenship purposes.

The assessment of whether the real estate investment satisfies the citizenship requirements is also important. Under the current system, this assessment is carried out by the Ministry of Environment, Urbanization and Climate Change. (lexpera.com.tr)

Acquisition of Citizenship through the Creation of Employment

Another route to exceptional citizenship is creating employment in Türkiye.

Under Article 20 of the Regulation, foreign nationals whose creation of employment for at least 50 persons is determined by the Ministry of Labour and Social Security may apply for citizenship under the investment-based exceptional citizenship system.

The purpose of this provision is not merely to encourage capital inflows but also to promote economic activity and employment creation in Türkiye.

Accordingly, what matters for citizenship purposes is not merely that the investor has established a company, but that the investor has created the number of jobs prescribed by the Regulation.

The competent Ministry determines whether the employment requirement has been fulfilled. Accordingly, the applicant must document the number of employees and demonstrate that the employment relationships comply with the applicable legislation. (lexpera.com.tr)

Acquisition of Citizenship through Deposits in Banks

Another investment option is depositing a specified amount of money with banks operating in Türkiye.

Under the Regulation, foreign nationals whose deposit of at least USD 500,000 or the equivalent amount in foreign currency with banks operating in Türkiye, subject to the condition that the deposit be maintained for three years, is determined by the Banking Regulation and Supervision Agency may apply under this investment category. (lexpera.com.tr)

The investor must therefore maintain the deposit in accordance with the conditions prescribed by the Regulation for the three-year period.

There are also special provisions concerning the sale of foreign currency amounts used for citizenship purposes to a bank operating in Türkiye and, by that bank, to the Central Bank of the Republic of Türkiye. The implementation principles regarding the holding of the Turkish lira amount obtained from such sale in the specified investment instrument for three years are determined by the Central Bank. (lexpera.com.tr)

Therefore, for citizenship through deposits, it is not sufficient merely to have a certain amount of money in a bank account. The transactions must also be carried out in accordance with the procedures prescribed by the Regulation and the relevant implementing rules.

Acquisition of Citizenship through the Purchase of Government Debt Instruments

Another investment method is the purchase of government debt instruments.

Under the Regulation, foreign nationals whose purchase of government debt instruments worth at least USD 500,000 or the equivalent amount in foreign currency, subject to the condition that they be held for three years, is determined by the Ministry of Treasury and Finance may apply for citizenship under this category. (lexpera.com.tr)

This method requires the investor to make a specified level of investment in Türkiye’s public debt market.

As of 2026, the implementation principles applicable to this investment category are also regulated separately. The Ministry of Treasury and Finance has published current procedures and principles concerning the purchase of government debt instruments under the relevant provision of Article 20 of the Regulation, including the application process and the transactions that investors are required to carry out. (ms.hmb.gov.tr)

Acquisition of Investment Fund Participation Shares

The Regulation also permits exceptional citizenship to be acquired through investment funds.

Foreign nationals who purchase at least USD 500,000 or the equivalent amount in foreign currency in participation shares of a real estate investment fund or venture capital investment fund and hold those shares for at least three years may satisfy this condition if the relevant requirement is determined by the Capital Markets Board. (lexpera.com.tr)

This provision demonstrates that the citizenship route is not limited to direct real estate or bank investments, but also includes capital market instruments.

The investor must hold the relevant fund participation shares for the specified period and ensure that the investment reaches the amount prescribed by the Regulation.

Acquisition of Citizenship through the Private Pension System

Another investment method available under the exceptional citizenship system is investment in the private pension system.

Under the Regulation, foreign nationals who invest at least USD 500,000 or the equivalent amount in foreign currency as a contribution into the private pension system, keep the contribution in funds whose scope is determined by the Insurance and Private Pension Regulation and Supervision Agency, and remain in the system for three years, may apply for citizenship under this provision. (lexpera.com.tr)

This provision is important in terms of supporting long-term financial investments and expanding the citizenship program to different types of investment instruments.

Transition between Investment Types

One of the important features of the Regulation is that it permits, under certain circumstances, transitions between investment types.

Article 20 provides for the possibility of transitioning between the investment types listed in the second paragraph for the purpose of completing the required holding period. (lexpera.com.tr)

This provision may allow an investor, within certain limits, to change the type of investment during the process of satisfying the citizenship requirements.

However, the transition mechanism does not mean that an investor may change investment types without restriction. Any such change must be carried out in accordance with the applicable legislation and the implementation principles established by the competent authorities.

Determination of Investment Conditions by the Competent Authorities

One of the most important characteristics of the exceptional citizenship system is that fulfillment of the investment requirements is determined by the competent authority relevant to the particular type of investment, rather than by a single institution.

For example, the Ministry of Industry and Technology is competent with respect to fixed capital investment; the Ministry of Labour and Social Security with respect to employment; the Banking Regulation and Supervision Agency with respect to bank deposits; the Ministry of Treasury and Finance with respect to government debt instruments; and the Capital Markets Board with respect to investment funds. (lexpera.com.tr)

Article 20, paragraph 9 of the Regulation also provides that the procedures and principles applicable to determining whether the investment conditions have been satisfied shall be established by the institution making the determination. (lexpera.com.tr)

Therefore, investors should consider not only the provisions of the Regulation but also the current implementation principles issued by the relevant institution concerning the particular type of investment before submitting a citizenship application.

Special Rules Concerning Foreign Exchange Transactions

The Regulation also contains special provisions concerning foreign exchange transactions in connection with investment-based citizenship.

Article 20, paragraph 10 provides that, for certain investment types, foreign currency amounts must first be sold to a bank operating in Türkiye and then by the bank to the Central Bank of the Republic of Türkiye. The Turkish lira amount obtained from the sale must subsequently be maintained for three years in the relevant deposit, government debt instrument, or designated fund within the private pension system, depending on the type of investment. (lexpera.com.tr)

This regulation means that the investment-based citizenship system must be considered not only in terms of citizenship legislation but also together with the regulations governing banking, capital markets, and foreign exchange transactions.

Administrative Nature of the Exceptional Citizenship Application

Fulfilling the investment requirement does not result in the automatic acquisition of citizenship.

The investor first satisfies the conditions applicable to the relevant investment type, and the competent authority then makes the necessary determination. The citizenship application must subsequently be assessed by the relevant administrative authorities.

At the final stage, a decision of the President concerning the acquisition of Turkish citizenship becomes relevant.

Accordingly, citizenship through investment is an administrative process involving a special assessment procedure and the participation of multiple public institutions.

Status of the Spouse and Children

The status of the investor’s family members is also important in the context of exceptional citizenship.

When the investor acquires Turkish citizenship, the investor’s spouse and children who satisfy the conditions prescribed by the Law and the Regulation may also benefit from the citizenship application.

However, the acquisition of citizenship by the investor should not be understood to mean that all family members automatically acquire Turkish citizenship. The conditions prescribed by the Law and the Regulation must be assessed separately in respect of each relevant person.

Maintenance of the Investment Conditions

Under the exceptional citizenship system, it is important not only for the investor to make the required investment but also to maintain the investment for the prescribed period.

For real estate investments, this involves the three-year restriction on sale. For deposits, government debt instruments, investment funds, and the private pension system, the Regulation provides for three-year holding or participation requirements. (lexpera.com.tr)

The purpose of these holding-period requirements is to prevent the citizenship application from being used merely as a short-term investment transaction and to ensure that the investment remains within the Turkish economy for a specified period.

Legal Consequences of Exceptional Citizenship

Acquiring Turkish citizenship through the exceptional citizenship route does not create a different citizenship status from that acquired through other methods in terms of the individual’s status as a Turkish citizen. Once the person acquires Turkish citizenship, they become subject to the rights and obligations arising from Turkish citizenship.

However, the acquisition of citizenship and the obligation to maintain the investment should be distinguished from one another. Where the investor remains subject to an obligation to maintain the investment for a prescribed period, disposing of or terminating the investment prematurely may have consequences under the applicable legislation.

Conclusion

The acquisition of Turkish citizenship by exception is a special method of acquiring citizenship that enables certain foreign nationals who invest in Türkiye or make an economic contribution to be admitted to Turkish citizenship.

Under Article 20 of the current Regulation, the principal routes available to investors include making a fixed capital investment of at least USD 500,000, acquiring qualifying real estate worth at least USD 400,000, creating employment for at least 50 persons, maintaining a deposit of at least USD 500,000 for three years, acquiring at least USD 500,000 in government debt instruments, holding at least USD 500,000 in investment fund participation shares for three years, and investing at least USD 500,000 in the private pension system and remaining in the system for three years. (lexpera.com.tr)

Nevertheless, making the investment alone does not mean that Turkish citizenship is automatically acquired. The relevant public institution must determine that the investment requirements have been satisfied, the citizenship application must be assessed by the competent administrative authorities, and ultimately a decision of the President must be issued.

Under this system, investors must also pay particular attention to three-year holding-period requirements, foreign exchange transactions, the approval and determination procedures of the competent institutions, and the documents required during the application process. Since investment amounts and implementation procedures may change over time, the Regulation in force on the date of application and the current regulations and implementation principles of the relevant institutions must be taken into consideration. (lexpera.com.tr)

In conclusion, the exceptional citizenship system is a special citizenship acquisition mechanism under Turkish nationality law based on investment, economic contribution, employment, and the establishment of strong economic ties with Türkiye. In applying this mechanism, it is necessary to consider not only the Turkish Citizenship Law and the Regulation, but also the implementation principles of the relevant Ministries, regulatory authorities, and the Central Bank of the Republic of Türkiye, depending on the nature of the investment.