Introduction: Does Becoming a Shareholder in a Turkish Company Automatically Require a Work Permit?

No.

A foreign person does not automatically need a Turkish work permit merely because they acquire shares in a Turkish company.

This distinction is extremely important for foreign investors.

Turkish law separates:

ownership of a company

from

working for or actively managing that company.

A foreign investor may therefore own shares in a Turkish limited liability company or joint stock company without necessarily obtaining a work permit simply to hold those shares.

The legal position changes, however, if the foreign shareholder begins to:

• act as manager of a Turkish limited liability company;
• serve as an operational board member of a joint stock company;
• work as CEO, general manager or another executive;
• perform day-to-day management;
• provide services to the company;
• or otherwise work in Turkey on behalf of the business.

The Ministry of Labour and Social Security currently makes this distinction expressly. Its guidance states that foreign shareholder-managers of limited liability companies, foreign shareholder board members of joint stock companies and certain other managing partners may work by obtaining a work permit. At the same time, non-resident board members of joint stock companies and non-managing shareholders of other companies fall within the work permit exemption framework.

The correct question is therefore not:

“Am I a shareholder?”

It is:

“What am I actually going to do for the Turkish company?”

This distinction can materially affect the company’s capital structure, employment planning, immigration strategy and even the percentage of shares a foreign founder should acquire.

It is particularly important because Turkey’s current 2026 work permit criteria for foreign company partners include financial and employment requirements that can be substantially higher than the minimum capital required simply to establish a Turkish company.

For many foreign founders, company formation and work permit planning should therefore be done at the same time.

This guide explains when a foreign investor needs a work permit after becoming a shareholder in a Turkish company, which shareholders may fall within an exemption, what the current TRY 500,000 and 20% rules mean, how the USD 100,000 exception works and what happens if a foreign shareholder works without permission.

1. Foreign Share Ownership and the Right to Work Are Separate Legal Concepts

Turkey generally allows foreign persons to become shareholders of Turkish companies.

But acquiring a corporate ownership right does not itself create a right to work in Turkey.

A person may therefore be:

100% owner of a Turkish company

without automatically being authorised to perform employment or management activities in Turkey.

The reverse can also occur.

A foreign executive may legally work for a Turkish company while holding no shares at all.

For immigration and labour law purposes, the legal questions should therefore be separated into:

1. Can the foreigner own shares?
2. Can the foreigner reside in Turkey?
3. Can the foreigner work in Turkey?
4. Can the foreigner actively manage the Turkish company?

These are not the same question.

This separation is particularly relevant where an international group establishes a Turkish subsidiary.

The foreign parent company may own 100% of the Turkish business.

A foreign director may sit on the board from London or Frankfurt without moving to Turkey.

Another foreign executive may relocate to Istanbul and manage the business full-time.

Those two foreign individuals should not automatically receive identical work permit treatment.

2. Passive Foreign Shareholders Generally Do Not Need a Work Permit Merely to Own Shares

The clearest practical rule is:

Passive investment does not automatically create a work permit obligation.

The Ministry of Labour’s current FAQ explains that non-managing shareholders of companies established under the Turkish Commercial Code can fall within the work permit exemption framework.

Therefore, imagine a German investor owns:

30% of a Turkish software company

but:

• does not act as manager;
• does not work from the Turkish office;
• does not receive a Turkish employment salary;
• does not conduct daily operations;
• and remains primarily resident abroad.

The fact that this person owns 30% does not, by itself, mean that a standard work permit is automatically required.

The shareholder’s actual function is decisive.

3. What Does “Non-Managing Shareholder” Mean?

A foreign investor should be careful with labels.

Simply writing:

“passive shareholder”

in a shareholder agreement does not necessarily resolve the issue if the individual actually performs management duties in practice.

Authorities may look at the real activity.

Factors that can indicate an active managerial role include:

• being formally appointed as manager;
• having company representation authority;
• regularly signing contracts;
• supervising employees;
• directing company operations;
• maintaining a permanent office in Turkey;
• receiving management remuneration;
• controlling daily banking;
• acting publicly as CEO;
• negotiating on behalf of the company on an ongoing basis.

A genuine financial investor whose involvement is limited to shareholder rights is in a materially different position.

For this reason, corporate documentation should reflect the intended operational reality.

4. Does a Foreign Manager of a Turkish Limited Company Need a Work Permit?

Generally, yes if the foreign shareholder will actively work as the manager.

The Ministry of Labour specifically states that a foreign shareholder who is also a manager of a limited liability company may work by obtaining a work permit.

Consider:

Foreign Founder – 100% shareholder of ABC Teknoloji Ltd. Şti.

The founder is also formally appointed as:

Company Manager / Müdür

and moves to Istanbul to run the business.

In that case, it would be unsafe to argue:

“I do not need a work permit because I own the company.”

Ownership is precisely what must be distinguished from management.

The founder is not merely holding shares; they are actively performing management functions.

A work permit should therefore be analysed before active work begins.

5. What About a Foreign Shareholder of a Turkish A.Ş.?

A Turkish joint stock company – Anonim Şirket (A.Ş.) – requires a more nuanced distinction.

A foreign investor may be:

• shareholder only;
• shareholder and board member;
• shareholder, board member and active executive;
• non-resident board member;
• or resident operational board member.

The Ministry expressly states that foreign board members and foreign shareholders who actively work in the relevant capacities may work after obtaining a work permit.

However, it also states that non-resident members of the board of directors of a Turkish joint stock company are within the work permit exemption framework.

Therefore:

Foreign board member living abroad

May fall within the exemption framework if the statutory conditions are met.

Foreign board member living in Turkey and managing daily operations

Should not assume the non-resident board member exemption applies.

A work permit analysis is required.

6. Owning 100% of a Turkish Company Does Not Eliminate the Work Permit Requirement

This is one of the most frequent misunderstandings among foreign founders.

An entrepreneur may say:

“How can I be my own employee? I own the entire company.”

Under Turkish corporate law, however, the company is a legal entity separate from its shareholder.

A shareholder may own 100% of the capital while the company itself remains a separate legal person.

Work permit legislation can therefore regulate the foreigner’s work for or management of that Turkish legal entity.

The percentage of ownership matters for evaluation criteria, but complete ownership does not create an automatic work permit exemption.

7. What Are the 2026 Work Permit Criteria for a Foreign Company Partner?

The Ministry of Labour currently applies specific criteria to foreigners who open a new business or become a partner in an existing Turkish business.

For workplaces operating under the balance-sheet accounting method, the current ordinary framework requires:

• the company’s paid-up capital to be at least TRY 500,000;
• the foreign shareholder’s own capital amount to be at least TRY 500,000;
• the foreign shareholder to own at least 20% of the company.

This means that two separate TRY 500,000 concepts should be understood.

The company itself needs the required paid-up capital.

The foreigner’s personal capital participation must also reach the applicable minimum.

Example

Suppose:

Company paid-up capital: TRY 2,000,000
Foreign shareholder ownership: 10%
Foreign shareholder’s capital: TRY 200,000

The company itself exceeds TRY 500,000.

But the foreign shareholder does not satisfy:

TRY 500,000 personal capital participation

or

20% ownership.

The ordinary company-partner criteria are therefore not satisfied merely because the target company is financially substantial.

8. Why Is the 20% Shareholding Requirement Important?

Under the ordinary foreign-company-partner criteria, the foreign applicant must generally hold at least 20%.

This matters when foreign entrepreneurs structure ownership among multiple founders.

Example

Five foreign founders establish a company equally:

Founder A – 20%
Founder B – 20%
Founder C – 20%
Founder D – 20%
Founder E – 20%

Each founder potentially satisfies the percentage requirement, subject to the capital and other work permit criteria.

But if:

Founder A – 15%
Founder B – 15%
Founder C – 15%
Investor D – 55%

the 15% founders cannot simply rely on the general 20% company-partner rule.

The shareholding structure should therefore be reviewed together with the intended work permit strategy where several foreign founders expect to work actively in Turkey.

9. The Foreign Partner’s Capital Share Must Generally Reach TRY 500,000

The percentage requirement is not enough.

The Ministry’s current criteria also require the foreign shareholder’s own capital participation to be at least TRY 500,000 under the ordinary framework.

Consider:

Company capital: TRY 1,000,000
Foreign shareholder: 20%

Capital attributable to foreign shareholder:

TRY 200,000

Although the investor owns 20%, the personal capital amount is still below TRY 500,000.

This is why work permit planning may require a substantially higher company capital than corporate law alone requires.

10. Minimum Company Capital and Work Permit Capital Are Not the Same

Foreign founders should distinguish:

Corporate-law minimum capital

The amount legally required to establish the company.

from

Work-permit evaluation capital

The financial threshold used when evaluating a foreign company partner’s work permit.

For example, a Turkish Ltd. Şti. can be established with much less capital than may be commercially appropriate for the foreign partner’s work permit structure.

Therefore, establishing the company at the statutory minimum and planning immigration later may create unnecessary:

• capital increases;
• Trade Registry filings;
• accounting work;
• delay;
• and cost.

The work permit structure should ideally be determined before the articles of association are finalised.

11. The Five Turkish Employee Requirement

The ordinary foreign company partner criteria also contain an employment obligation.

The Ministry states that a business applying for a work permit for a foreign company partner must generally employ at least five Turkish citizens.

However, an important concession applies to a new foreign partner’s first work permit.

The first permit is issued with an annotation concerning the employment condition, and the obligation to maintain at least five Turkish citizen employees applies from the beginning of the seventh month of the first work permit period.

Therefore, a newly established startup does not necessarily need five Turkish employees on its first day merely to obtain the foreign founder’s first work permit.

But it needs to plan to satisfy the requirement once the seventh month begins.

12. How Does the Five-Employee Rule Work in Practice?

Suppose a foreign entrepreneur receives a first work permit beginning:

1 January 2027.

Under the ordinary company-partner framework, the business should plan for the five-Turkish-employee requirement to apply from the seventh month.

This means the company should not wait until the last moment to hire employees.

A technology startup whose founder expects to remain the only employee for two years may therefore need to consider whether:

• another work permit category applies;
• a statutory exemption applies;
• the USD 100,000 exception applies;
• or the business structure should be reconsidered.

13. The USD 100,000 Capital Share Exception

This is one of the most significant rules for foreign investors.

The Ministry’s current criteria expressly state that where the foreign company’s partner has a capital participation of at least USD 100,000, the ordinary requirements concerning:

• TRY 500,000 company/foreign-partner capital;
• 20% shareholding;
• and five Turkish employees

under the company-partner subsection do not apply.

This can materially simplify work permit planning for substantial foreign investors.

Example

A foreign investor contributes:

USD 150,000 equivalent

to the Turkish company and holds a substantial ownership interest.

The investor may fall within the USD 100,000 capital-share exception to the specific ordinary company-partner financial/shareholding and employment criteria.

However, the exception should not be interpreted as:

“USD 100,000 automatically guarantees a work permit.”

It does not.

The Ministry still evaluates the application under the International Labour Force Law and applicable policy.

14. Does USD 100,000 Guarantee Approval?

No.

The rule means that the specified company-partner financial/shareholding and employment criteria are not applied.

It does not create an automatic legal entitlement to the permit.

Work permit applications remain subject to the Ministry’s overall assessment.

Therefore, the distinction is:

exempt from specific evaluation criteria

not

automatically approved.

This distinction is important throughout Turkish work permit law.

15. Important 2026 Exception for Foreigners Already Lawfully in Turkey

A significant change took effect on 3 August 2026.

Under the Ministry’s current general evaluation criteria, work permit applications for certain foreigners who, at the time of application, have legally stayed in Turkey for at least one year during the previous three years through qualifying work permit, residence permit or international protection status may be exempt from the employment and financial eligibility criteria for up to three foreigners at the same workplace.

The Ministry also states that the number of foreigners employed under that exception should not exceed the number of Turkish citizens working at the same workplace. If more than three qualifying foreigners are employed, the ordinary employment and financial criteria apply to the fourth and subsequent foreign employees.

This 2026 amendment may be particularly relevant to foreign entrepreneurs who have already been lawfully living in Turkey before becoming shareholders or joining the management of a Turkish business.

Because the application of general exceptions can depend on the precise category and facts, foreign company partners should confirm how the Ministry will apply the current rule to their particular application rather than relying solely on the existence of prior residence.

16. Other Foreigners May Be Exempt From Evaluation Criteria

The Ministry’s current criteria also exempt specified foreign nationals from employment, financial eligibility and salary criteria when their status is properly documented.

Examples currently include:

• foreigners whose mother, father or child is a Turkish citizen;
• holders of humanitarian residence permits;
• stateless persons with the relevant identity document;
• long-term residence permit holders;
• foreigners married to a Turkish citizen for at least three years;
• certain persons with at least eight years of qualifying lawful status in Turkey;
• certain persons of Turkish origin;
• and citizens of the Turkish Republic of Northern Cyprus.

Again, being exempt from these evaluation criteria does not automatically guarantee issuance of a work permit.

The Ministry expressly states that satisfying an exemption category does not create an absolute right to approval.

17. Work Permit Exemption Is Different From Exemption From Evaluation Criteria

This terminology is easy to confuse.

There are two different concepts:

Work Permit Exemption

The foreigner falls within a category where they may perform the relevant activity under a formal work-permit-exemption framework rather than obtaining an ordinary work permit.

Exemption From Work Permit Evaluation Criteria

The person still applies for a work permit, but specified financial, employment or salary criteria are not applied.

These are not the same thing.

For example, a qualifying non-managing company shareholder may fall within the work permit exemption framework.

By contrast, a long-term residence permit holder who intends to work may still submit a work permit application but benefit from exemption from specified evaluation criteria.

Foreign investors should therefore identify which type of exemption they are actually relying on.

18. Does a Passive Foreign Shareholder Need to Apply for a Work Permit Exemption Document?

The Ministry operates a formal e-Muafiyet system for work permit exemption applications and publishes dedicated exemption application guidance.

A foreign investor who believes that they fall within a work permit exemption category should therefore not simply self-classify and begin activities without reviewing whether an exemption application/document is required for the particular activity.

The safer approach is:

identify exemption category → confirm legal scope → complete the applicable e-Muafiyet process where required → preserve documentation.

This is particularly important for foreign directors who travel frequently to Turkey for business activities.

19. Does a Non-Resident A.Ş. Board Member Need a Work Permit?

The Ministry expressly places non-resident board members of Turkish joint stock companies within the work permit exemption framework.

This rule is particularly relevant for multinational groups.

For example:

A German parent company owns 100% of a Turkish A.Ş.

The German group’s CFO is appointed as one of five Turkish subsidiary board members.

The CFO:

• lives in Munich;
• attends several board meetings each year;
• does not work daily in the Turkish office;
• and does not perform ongoing operational management in Turkey.

This type of arrangement can fall within the non-resident A.Ş. board member exemption framework.

However, if the CFO permanently relocates to Istanbul and becomes the company’s daily executive manager, the factual position changes.

20. Can a Foreign Shareholder Attend Meetings Without a Work Permit?

Ordinary shareholder participation should be distinguished from employment.

A foreign shareholder does not become an employee merely because they:

• attend a general assembly;
• vote as a shareholder;
• review company financial information;
• participate in investor discussions;
• or exercise ordinary ownership rights.

Likewise, limited business visits for meetings and negotiations may fall under different work permit exemption categories depending on the nature and duration of activity.

The Ministry’s exemption framework includes certain temporary commercial activities such as participation in meetings, seminars, conferences, trade fairs and specified contract negotiation activities.

But repeated daily operational work should not be disguised as “attending meetings.”

The actual substance matters.

21. Does the Foreign Shareholder Need a Residence Permit as Well?

A valid work permit generally also serves as a residence permit during its validity.

The Presidency of Migration Management expressly confirms that a work permit is considered a residence permit for the period in which it remains valid.

Therefore, once a valid work permit is issued, the foreign shareholder generally does not need a separate residence permit covering the same period merely to reside lawfully.

This is an important advantage for active foreign founders.

The work permit provides:

legal right to work + legal basis to reside.

However, if the work permit expires or is cancelled, the associated residence basis also ends, subject to the applicable post-expiry procedures.

22. Can a Residence Permit Replace a Work Permit?

Generally, no.

This works in only one direction.

Work permit → generally substitutes for residence permit.

But:

Residence permit → does not automatically substitute for work permit.

A foreign shareholder may therefore have:

• a property-owner residence permit;
• family residence;
• short-term residence;
• or another lawful residence status

and still require a work permit before beginning employment or active management.

This is one of the most important immigration distinctions foreign investors should remember.

23. Can the Work Permit Be Applied for From Within Turkey?

Yes, where the applicable domestic application conditions are satisfied.

The Ministry currently states that a domestic work permit application may generally be made for a foreigner in Turkey who has a valid residence permit issued for at least six months and still valid at the time of the application.

Domestic applications are submitted electronically through the Ministry’s work permit system.

Certain foreigners lawfully present in Turkey may also be allowed to apply domestically under specific rules determined by the Directorate General.

24. What if the Foreign Shareholder Does Not Have a Turkish Residence Permit?

The application can generally begin from abroad.

The foreigner first applies to the Turkish embassy or consulate in the country of nationality or lawful residence and receives a 16-digit reference number.

The Turkish-side work permit application is then completed electronically using that reference number.

Therefore, a foreign entrepreneur does not necessarily need to obtain an ordinary Turkish residence permit first merely to begin a work permit process.

The correct route depends on whether the person qualifies for a domestic or overseas application.

25. How Long Is the First Work Permit Valid?

Where a fixed-term work permit application is approved, the first permit may generally be issued for up to one year, subject to the employment/service relationship and other statutory conditions.

For extensions under the same employer, the first extension may be granted for up to two years, and subsequent extensions for up to three years.

This means a foreign founder should treat work permit compliance as an ongoing corporate obligation rather than a one-time incorporation document.

26. When Should a Work Permit Extension Be Filed?

The Ministry currently permits extension applications beginning 60 days before the existing work permit expires, and the application must be filed before the permit expires.

An extension application made only after expiry is treated under the rules applicable to an initial application rather than an ordinary timely extension.

Companies employing foreign managers should therefore include work permit expiry dates in their compliance calendar.

27. Are There Special Rules for Major Foreign Direct Investments?

Yes.

Turkey maintains special rules for certain Specific Foreign Direct Investments – Özellik Arz Eden Doğrudan Yabancı Yatırımlar.

The Ministry updates the relevant financial thresholds each year.

For 2026, qualifying tests include circumstances involving substantial foreign capital together with high turnover, export or employment, significant fixed investment, or a multinational parent company having direct investments in another country.

For qualifying specific foreign direct investments, the first foreign employee classified as key personnel can benefit from special treatment; the Ministry’s FAQ states that the ordinary five-Turkish-employee criterion is not sought when evaluating the first such key person’s work permit.

This can be highly relevant for multinational corporations establishing substantial Turkish operations.

28. What About an Independent Work Permit?

Turkey also provides an independent work permit.

This allows a foreigner to work on their own behalf and account without being tied to a particular employer.

The Ministry states that independent work permit applications are evaluated under international labour force policy by considering matters including:

• education;
• professional experience;
• contribution to science and technology;
• the economic and employment impact of the person’s activities or investment;
• and, for a foreign company partner, the person’s capital share.

An independent work permit is not automatically issued merely because someone is an entrepreneur.

It is a discretionary category based on the applicant’s profile and contribution.

29. Could a Major Investor Qualify for a Turquoise Card?

Potentially.

The Turquoise Card provides another route for highly qualified foreign investors, executives and professionals whose contribution to Turkey is considered significant.

The Ministry evaluates matters including:

• education;
• experience;
• science and technology contribution;
• investment;
• economic contribution;
• and employment.

For an ordinary small-company shareholder, a standard company-partner work permit may be more relevant.

For a substantial foreign investor or highly qualified executive, the Turquoise Card should at least be considered as part of the immigration strategy.

30. What Happens if a Foreign Shareholder Works Without a Permit?

The consequences should not be underestimated.

For 2026, the Ministry currently lists administrative fines including:

• TRY 102,503 per foreigner for an employer employing a foreigner without a work permit;
• TRY 40,977 for a foreigner working dependently without a work permit;
• TRY 82,010 for a foreigner working independently without a work permit.

The applicable fines can be increased where the violation is repeated.

Therefore, a foreign founder should not begin working informally while saying:

“We will apply for the permit later.”

The work permit should be addressed before unlawful work begins.

31. Practical Example: Passive Foreign Investor

Assume:

Foreign Investor: 40%
Turkish Founder: 60%

The foreign investor:

• lives in London;
• does not manage the company;
• does not work in Turkey;
• attends two shareholder meetings per year.

The foreign investor generally should not need an ordinary work permit merely because of the 40% shareholding.

The Ministry places non-managing company partners within the work permit exemption framework.

The appropriate exemption/documentation requirements should nevertheless be confirmed for the actual activities performed in Turkey.

32. Practical Example: Foreign Founder Is Manager of an Ltd. Şti.

Assume:

Foreign Founder: 100% shareholder
Company: Turkish software Ltd. Şti.
Role: Manager
Residence: Istanbul
Activity: Full-time operational management

This is not a passive investment.

The founder should analyse a company-partner work permit.

Under the ordinary current criteria, the structure may need to satisfy:

TRY 500,000 paid-up company capital + TRY 500,000 foreign partner capital + at least 20% shareholding, together with the five-Turkish-employee requirement from the seventh month of the first permit.

If the foreign partner’s capital share reaches at least USD 100,000, those specific company-partner criteria do not apply.

33. Practical Example: Foreign Board Member Lives Abroad

Assume a Dutch corporation owns a Turkish A.Ş.

A Dutch executive becomes one of the Turkish company’s board members.

The executive:

• remains resident in Amsterdam;
• attends periodic board meetings;
• has no permanent operational role in Turkey.

The Ministry expressly treats non-resident A.Ş. board members within the work permit exemption framework.

This structure should therefore be distinguished from appointing the same executive as full-time Istanbul-based general manager.

34. Practical Example: USD 150,000 Foreign Capital Participation

Assume a foreign entrepreneur makes a capital contribution equivalent to:

USD 150,000

and becomes an active shareholder-manager.

Because the foreign partner’s capital share exceeds USD 100,000, the specific company-partner requirements concerning:

• TRY 500,000 capital;
• 20% shareholding;
• five Turkish employees

are not applied under the current criteria.

However, the applicant still needs a valid work permit unless another complete exemption applies, and the Ministry continues to evaluate the application.

35. Practical Example: Investor Has a Residence Permit but No Work Permit

Assume a foreign investor:

• purchases a home in Istanbul;
• obtains short-term residence;
• buys 60% of a Turkish company;
• becomes company manager;
• begins working every day from the company’s office.

The property residence permit does not itself authorise that work.

The investor should separately obtain the appropriate work authorisation.

Once a valid work permit is granted, it generally serves as the person’s residence permit during its validity.

Foreign Shareholder Work Permit Checklist

Before a foreign investor begins work in a Turkish company, the following should be checked:

1. Is the person merely a shareholder or an active manager?
2. Is the company an Ltd. Şti. or A.Ş.?
3. Is the foreigner formally appointed as manager?
4. Is the person a board member?
5. Does the person reside in Turkey?
6. Does a work permit exemption apply?
7. Does an e-Muafiyet application need to be completed?
8. If a permit is required, is the company subject to balance-sheet accounting?
9. Is paid-up capital at least TRY 500,000?
10. Is the foreign shareholder’s capital amount at least TRY 500,000?
11. Does the foreigner own at least 20%?
12. Is the foreign partner’s capital participation at least USD 100,000?
13. Does the five-Turkish-employee rule apply?
14. When does the seventh month begin?
15. Does a 2026 evaluation-criteria exception apply?
16. Does the company qualify as a specific foreign direct investment?
17. Can the application be made domestically?
18. Does the foreigner have a qualifying six-month residence permit?
19. If not, should the application begin abroad?
20. Who will monitor renewal deadlines?

This analysis should ideally be completed before the foreign investor starts operational activity.

Frequently Asked Questions

Does every foreign shareholder need a Turkish work permit?

No. Merely holding shares does not automatically require a standard work permit. Non-managing company partners can fall within the work permit exemption framework.

Does a foreign manager of an Ltd. Şti. need a work permit?

A foreign shareholder who actively works as the manager of a Turkish Ltd. Şti. should generally obtain the appropriate work permit unless a specific exemption applies.

Does a foreign A.Ş. board member need a work permit?

It depends on the role. A non-resident board member is expressly included within the exemption framework, while a foreign board member actively working in Turkey should analyse the work permit requirement.

Does owning 100% of the company exempt me?

No. Ownership percentage does not automatically eliminate work authorisation requirements.

What is the minimum foreign-shareholder capital requirement in 2026?

Under the ordinary company-partner framework, the company’s paid-up capital and the foreign partner’s own capital amount must generally each reach TRY 500,000, and the foreigner must generally own at least 20%.

How many Turkish employees are required?

The ordinary company-partner criterion requires at least five Turkish citizens. For the first permit, the requirement applies from the beginning of the seventh month.

What if my capital participation is USD 100,000 or more?

The specific company-partner criteria concerning the TRY 500,000 amounts, 20% shareholding and five Turkish employees do not apply where the foreign partner’s capital participation is at least USD 100,000.

Does USD 100,000 guarantee the work permit?

No. It removes the application of those specific criteria; the permit remains subject to Ministry evaluation.

Can I use my Turkish residence permit instead of a work permit?

No. Residence permission does not ordinarily authorise work.

Does a work permit also allow residence?

Yes. A valid Turkish work permit generally substitutes for a residence permit during its validity.

Can I apply from Turkey?

Generally yes if you hold a valid residence permit issued for at least six months and satisfy the domestic application rules.

What if I do not have a residence permit?

The application can generally begin through a Turkish embassy or consulate abroad, after which the Turkish-side application is completed using the 16-digit reference number.

How long is the first permit?

A fixed-term first work permit can generally be granted for up to one year.

What are the 2026 fines for working without permission?

The Ministry currently lists TRY 102,503 per foreigner for the employer, TRY 40,977 for a dependent foreign worker and TRY 82,010 for a foreigner working independently without authorisation.

Conclusion: When Does a Foreign Investor Need a Work Permit in Turkey?

The most important rule is simple:

Becoming a shareholder of a Turkish company does not, by itself, automatically require a foreign investor to obtain a work permit.

The requirement depends primarily on whether the foreign investor will actually work or perform management functions in Turkey.

A passive foreign shareholder who merely holds an investment is legally different from a foreign founder who owns the company and runs it every day from Istanbul.

The Ministry of Labour’s current guidance recognises this distinction. Non-managing shareholders and non-resident board members of Turkish joint stock companies can fall within the work permit exemption framework.

By contrast, a foreign shareholder who acts as manager of an Ltd. Şti., a foreign operational board member of an A.Ş. or another foreign person actively performing management work must analyse the work permit requirement.

Where a foreign company partner applies under the ordinary current framework, the 2026 criteria are particularly important.

For businesses operating under the balance-sheet method, the Ministry generally requires:

company paid-up capital: at least TRY 500,000

foreign partner’s capital: at least TRY 500,000

foreign partner ownership: at least 20%

and

five Turkish citizen employees from the beginning of the seventh month of the first permit.

These numbers demonstrate why incorporation and work permit planning should not be separated.

A company can be perfectly valid under the Turkish Commercial Code while still being poorly structured for the foreign founder’s work permit.

There is, however, a highly important exception for substantial foreign capital.

If the foreign partner’s capital share is at least USD 100,000, the Ministry does not apply the specific ordinary company-partner criteria concerning the TRY 500,000 capital amounts, 20% ownership and five-Turkish-employee requirement.

That does not mean a USD 100,000 investor automatically receives a work permit.

It means those particular criteria no longer constitute the relevant obstacle.

Another important development took effect on August 3, 2026. Certain foreigners who have lawfully remained in Turkey for at least one year during the previous three years may benefit from an exemption from general employment and financial eligibility criteria for up to three qualifying foreigners at the same workplace, subject to the detailed current conditions.

Foreign investors already living lawfully in Turkey should therefore have their status reviewed under the new criteria rather than relying on older work permit rules.

Major international investors may also benefit from special foreign direct investment rules. Turkey has a separate regime for qualifying Specific Foreign Direct Investments, under which key personnel can receive more favourable treatment and the first qualifying key foreign employee may be exempt from the ordinary five-Turkish-employee test.

Residence should also be analysed separately.

A foreign shareholder’s short-term residence permit does not ordinarily authorise employment.

However, once a valid work permit is granted, that work permit generally also functions as the foreigner’s residence permit during its validity.

The practical distinction can therefore be summarised as:

Own shares only → work permit may not be required.

Passive/non-managing shareholder → exemption framework may apply.

Non-resident A.Ş. board member → exemption framework may apply.

Ltd. Şti. shareholder-manager → work permit generally required to work.

Resident/operational A.Ş. board member → work permit analysis required.

Foreign CEO or daily manager → work permit generally required.

Capital share of at least USD 100,000 → specific company-partner financial/shareholding/employment criteria do not apply, but permit approval is still required unless another exemption exists.

Foreign investors should also avoid working informally while the company “sorts out the paperwork.”

For 2026, unauthorised work can generate administrative fines both for the company and the foreigner, including a TRY 102,503 fine for an employer for each unauthorised foreign worker and separate penalties against the foreign worker.

Accordingly, the safest sequence for a foreign investor planning to actively participate in a Turkish business is:

determine company type → define shareholder role → determine whether the foreigner will manage or only invest → check exemption status → design capital and ownership structure → analyse five-employee requirement → examine USD 100,000 exception → assess 2026 residence-based exceptions → establish company/acquire shares → file work permit or exemption application → begin active work after proper authorisation → monitor employment and renewal requirements.

For foreign founders in particular, the key strategic question should be asked before company incorporation:

“Will I simply own this Turkish company, or will I personally work for and manage it in Turkey?”

If the answer is the second, the work permit structure should form part of the company’s original corporate planning.

Otherwise, a foreign entrepreneur may discover after incorporation that the company’s capital, shareholder percentages or employment model does not support the immigration strategy originally expected.

In short:

Foreign investment does not automatically create a work permit obligation—but active work and management can. The decisive factor is not merely how many shares the foreign investor owns, but what the investor actually does for the Turkish company.

This article reflects Turkish work permit and international labour force rules and publicly available official guidance as of August 2026. It is prepared for general informational purposes only and does not constitute individual corporate, immigration, employment or work permit advice. Each foreign shareholder’s position should be assessed according to the company type, management role, residence status, capital participation, ownership percentage, employment structure and actual activities performed in Turkey.