For Investors Not Seeking Real Estate: The Complete and Real Rules

When “Turkish citizenship by investment” is mentioned, most sources only discuss real estate. However, Turkey offers multiple paths to capital owners who do not wish to purchase real estate: bank deposits, government debt instruments (bonds), fixed capital investment, investment fund share participation, private pension system, and job creation.

These paths are suitable for investors seeking liquidity, returns, or portfolio diversification; however, much of the information on the internet omits a critical condition introduced in 2022: for financial routes, foreign currency must first be sold to a bank, then by the bank to the CBRT (Central Bank of the Republic of Turkey), and the amount obtained through deposits/bonds must be held in Turkish Lira for 3 years. This is a decisive detail concerning exchange rate risk.

This guide completely explains non-real estate paths based on official sources (General Directorate of Population and Citizenship Affairs, General Directorate of Land Registry and Cadastre guide, relevant Official Gazette amendments).

Scope: The 400,000 USD real estate path is the subject of a separate guide; here we focus on non-real estate options.

Legal Basis and Course of Legislation

Citizenship by investment (exceptional) is regulated by Article 12/1-b of the Turkish Citizenship Law No. 5901 and Article 20 of its Implementing Regulation. The article was amended on 12.01.2017, 19.09.2018, 07.12.2018, 06.01.2022, and 13.06.2022.

Thresholds, over the years to encourage investment, have been significantly lowered:

Thresholds and procedures can be updated with Presidential decisions and regulation amendments; the current amount should be confirmed before application.

The most critical and most frequently overlooked condition: Foreign currency exchange (conversion to TRY)

With the amendment in the Official Gazette dated January 6, 2022, the principle of “foreign currency payment and foreign currency inflow” has been introduced for financial routes. Accordingly, the foreign currency corresponding to the relevant investment amount is sold to a bank operating in Turkey before the transaction; and that bank then sells this foreign currency to the Central Bank of the Republic of Turkey (CBRT). The aim is to ensure foreign currency inflow into the country and prevent fraudulent transactions.

The practical result of this mechanism is as follows:

In the bank deposit route: The Turkish Lira obtained by converting foreign currency is held in a TL deposit account for 3 years.

In the government borrowing instruments route: The obtained Turkish Lira is invested in government borrowing instruments denominated in TL and held for 3 years.

Thus, in these two routes, the investor effectively holds a Turkish Lira position for 3 years. Therefore, the exchange rate risk in these routes directly rests with the investor and must be evaluated before making a decision.

Non-real estate routes — Comparison

In each path, the fulfillment of the minimum condition is documented with an “eligibility/determination certificate” issued by the relevant institution; this document is the basis for the citizenship application.

Details of the Paths

1) Bank Deposit — the most liquid-looking, but TL-dependent path

An amount equivalent to at least 500,000 USD must be deposited in banks operating in Turkey and not withdrawn for 3 years; the determination is made by BRSA (BDDK).

The amount can be deposited into a single account, or the total in different accounts is also considered; it is sufficient for the total to reach the equivalent of 500,000 USD.

Foreign currency is sold to the CBRT (TCMB) through the bank, and the resulting TL is held in a TL deposit for 3 years. Therefore, this path, which appears to be “liquid and simple,” is actually a 3-year TL commitment.

2) Government borrowing instruments (government bonds/bills)

Government borrowing instruments equivalent to at least 500,000 USD must be held for 3 years; the determination is made by the Ministry of Treasury and Finance. The TL obtained by exchanging foreign currency is invested in TL-denominated government borrowing instruments. Earning coupon/interest income while also fulfilling the citizenship requirement makes this path attractive; however, the return and principal are TL-based.

3) Fixed Capital Investment

A fixed capital investment of at least 500,000 USD must be made and verified by the Ministry of Industry and Technology (General Directorate of Incentive Implementation and Foreign Capital). It is suitable for investors establishing a real production/business in Turkey.

Fixed capital investments made before January 12, 2017 are not taken into account for the application.

The investor eligible for citizenship cannot transfer their shares in the company for 3 years.

For applications with missing documents, if the deficiencies are not completed within 1 month following the written notification, the application will be removed from process; in case of detection of fake/misleading documents, the process will be halted.

4) Investment Fund Share (REIF / VCF)

Participation shares in a real estate investment fund (REIF) or venture capital investment fund (VCF) amounting to at least 500,000 USD must be held for 3 years; the CMB verifies this, and the Central Registry Agency (CRA), upon determining that the minimum requirement has been met, notifies the CMB within 3 business days.

Important protective rule: Even if the value of the participation shares falls below 500,000 USD due to currency fluctuations, the application will not be affected. Similarly, a decrease in value/number of shares beyond the investor’s control (such as cash profit share, redemption of participation shares, or liquidation in accordance with the fund’s internal regulations/issuance document) is not considered a loss of the minimum investment requirement. This provision makes the fund option relatively “protected” among financial instruments.

5) Individual Retirement (IRS)

It is required that a contribution of at least 500,000 USD is invested in the individual pension system, provided that it is held in funds determined by SEDDK and remains in the system for 3 years, and this must be confirmed by SEDDK.

6) Job Creation

Citizenship can be acquired if the employment of at least 50 people is confirmed by the Ministry of Labor and Social Security (via SGK records). The threshold has been lowered from the previous 100 people to 50. This is aimed at employers establishing large-scale operations in Turkey.

Determination of the Foreign Currency Amount (Exchange Rate)

For all options, the USD equivalent of the minimum amount is calculated based on the CBRT effective selling rate and/or cross exchange rate on the date of determination. Therefore, the application is evaluated according to the exchange rate on the date of transaction and determination; it is wise to leave a buffer to safely exceed the threshold.

Process: Three Stages (Official Procedure)

Investment + Eligibility/Confirmation Certificate: The requirements of the chosen path are met (foreign currency is exchanged, deposit/bond/fund/capital is processed) and an eligibility/confirmation certificate is obtained from the relevant institution (BRSA, Treasury and Finance, Industry and Technology, CMB, SEDDK, MLSS).

Short-term residence permit: An investor short-term residence permit is obtained under Article 31 of Law No. 6458 (not a requirement to actually live, but a procedural step).

Citizenship application and decision: The applicant may be called to the relevant law enforcement units for fingerprinting and an interview; after examination by the Ministry of Interior and security/public order assessment, citizenship is granted by Presidential decision.

In applications made with missing information/documents, if the deficiencies are not completed within the period following the notification date (1 month in practice), the application may be removed from processing.

Family, residency, language, and dual citizenship

Family: Along with the applicant investor, their spouse and children under 18 years old also acquire citizenship.

No residency requirement: There is no requirement to actually reside in Turkey.

No language requirement.

Dual citizenship is permitted from Turkey’s perspective; whether you can maintain your existing citizenship depends on the legislation of your own country.

Documents and legitimate source (MASAK)

For the application, documents such as a valid passport and notarized/apostilled translations, a biometric photograph, a criminal record, a tax identification number, birth/marital status documents, and the relevant eligibility/determination certificate are required. Furthermore, documenting that the invested amount was obtained through legal means (legitimate source / MASAK) is critical; funds with an unclear source jeopardize the application.

Official service fee: A small application service fee is collected by the NVI (General Directorate of Civil Registration and Nationality) for each individual in the file for citizenship application (the amount is updated periodically).

Risks and Warnings Specific to Financial Routes

TL / exchange rate risk: Since the amount is converted to TL and held in TL for 3 years in the deposit and bond routes, exchange rate and interest rate fluctuations directly affect the investor.

Liquidity / 3-year lock-up: Withdrawal/transfer before the term expires jeopardizes the acquired status.

Legitimate source: Funds whose source cannot be documented lead to rejection.

Revocation of citizenship: If it is subsequently determined that important matters forming the basis of the application were concealed, the citizenship decision may be revoked (annulled) in accordance with TVK m. 31 and 40, provided that the administration relies on concrete, sufficient, and serious information.

“Guaranteed citizenship” advertisements: Citizenship is under the sovereign authority of the state. Statements containing guarantees such as “definite citizenship in 60 days” or “passport for property buyers” are found to be misleading by the Ministry of Trade Advertising Board and are subject to administrative fines. No intermediary can guarantee the outcome.

Frequently Asked Questions (FAQ)

Can I become a Turkish citizen without purchasing real estate? Yes. You can apply by making a 500,000 USD bank deposit, investing in government bonds, fixed capital, investment funds, or individual pension schemes, or by creating employment for 50 people.

Is my money converted to TRY for the deposit/bond route? Yes. As per the regulation of January 6, 2022, foreign currency is sold to the bank and by the bank to the CBRT; the TRY obtained through the deposit route is held in a TRY deposit, and through the bond route, it is held in a TRY denominated government borrowing instrument for 3 years. The currency risk is borne by the investor.

Can I withdraw the money before 3 years? No. It is a condition that the minimum amount is held/not withdrawn for 3 years; otherwise, the status will be at risk.

Can I split the deposit across different banks? Yes. The total of all your accounts in Turkey is taken into consideration; it is sufficient for the total to meet the equivalent of 500,000 USD.

What happens if the fund’s value falls below 500,000 USD due to exchange rates? A decrease in value due to exchange rate changes does not affect the application; furthermore, decreases beyond the investor’s control (profit share, share redemption, liquidation) are not considered a loss of the minimum requirement.

Can I sell my shares in the fixed capital route? Shares in the investment for citizenship cannot be transferred for 3 years; investments made before January 12, 2017, are also not considered for the application.

Which institution approves which route? Deposit → BRSA, bond → Treasury and Finance, fixed capital → Industry and Technology, fund → CMB (CDA notifies), PPS → IRSA, employment → Ministry of Labor and Social Security.

Do I need to live in Turkey or know Turkish? No. In exceptional (investment) citizenship, residency and language requirements are not sought.

Will my family also become citizens? Yes. Spouse and children under 18 years of age are included.

Do I have to prove the source of the money? Yes. The amount must be documented as obtained through legal means (legitimate source/MASAK).

Why is expert legal support necessary? — 2M Law Firm

Non-real estate options are not as simple as “invest the money, become a citizen”. The correct execution of the currency exchange and conversion to TRY process, safely ensuring the amount meets the USD threshold despite the exchange rate, the flawless establishment of the 3-year retention commitment, obtaining the eligibility/determination certificate from the relevant institution, and legitimate source documentation are prerequisites for success. A single incorrect step — payment through the wrong channel, an incomplete determination certificate, or undocumented funds — leads to both a rejected application and a risk of 500,000 USD.

Tuzla-based 2M Law Firm (Founder: Att. Meryem Günay) offers legal consultancy to foreign investors in Istanbul’s Anatolian Side (Tuzla, Pendik, Kartal, Maltepe) and Kocaeli region. The firm’s expertise in commercial, corporate, and banking-finance law directly contributes to the proper structuring of financial investment methods and the flawless management of the citizenship application file.

Support that 2M Law can offer in this process:

Path selection and preliminary risk analysis: Determining the most suitable path for the investor’s goal (liquidity, return, establishing a business); identifying potential obstacles from the outset through source and background analysis.

Foreign Currency/TRY and threshold management: Correct execution of the currency exchange process and exchange rate determination; safely meeting the threshold.

Eligibility/determination certificate process: Application and document management with the relevant institution.

Legitimate source (MASAK) certification: Complete preparation of the source declaration.

Residency + citizenship file: Fast and complete management of investor residence permit and citizenship application, together with family members.

Don’t leave the $500,000 decision to chance. Contact 2M Hukuk Law Office to securely manage the Turkish citizenship process from start to finish through non-real estate investment.

📍 Tuzla / Istanbul — Anatolian Side and Kocaeli 🌐 2mhukuk.com