Saying “I meet the conditions” does not mean your application will be accepted

The biggest misconception regarding Turkish citizenship by real estate is the idea that “I bought a $400,000 house, the rest is just formality”. However, a significant portion of applications, even from investors who genuinely meet the threshold, are rejected or suspended due to a single technical error: incorrect valuation, missing foreign exchange purchase document, incompatible payment receipt, shared property, or incorrect ownership structure.

Scope note: This content focuses on the legal risk and determination aspect of the 400,000 USD real estate pathway.

“Valuation Rule”: A single appraisal is never sufficient

The most common trap investors fall into is the assumption that “a high appraisal report meets the threshold”. According to the official statement of TKGM, EVERY TYPE OF VALUE used for valuation must individually meet the required amount. These value types are:

Rule: Each of these values must independently meet the required amount based on the acquisition date. (It is commonly referred to as the “three-value rule”; the official text refers to the above items as “each value type.”)

Practical outcome: Even if the appraisal is 450,000 USD, if your actual payment (DAB/receipt) or your declared sale price is below 400,000 USD, the threshold is considered not met. It is mandatory that all values are consistent with each other and each one exceeds the threshold.

Threshold amounts (current Circular): 400,000 USD for real estate acquired after 19.09.2018; 1,000,000 USD for acquisitions between 12.01.2017–18.09.2018. (Thresholds have changed over the years; the acquisition date is decisive, border cases must be professionally confirmed.)

Official valuation: GEDAŞ and TTB (most critical current change)

The most important current change in this area is the centralization of valuation. It has evolved in two stages:

Circular No. 2024/2 (early 2024): Valuation reports for citizenship purposes are issued solely by GEDAŞ (a TKGM subsidiary) via WebTapu. Valuation reports obtained from other institutions within this scope are not accepted for citizenship applications.

Circular No. 2024/4 (effective: 09.12.2024): Confirmation of the investment amount is now done with TTB (Amount Determination Document for Citizenship Acquisition by Real Estate Acquisition). The TTB is generated from the GEDAŞ report, prepared via TADEBİS, and sent to TAKBİS/WebTapu; it indicates the acceptable investment amount of the real estate for citizenship.

Important nuances:

TTB is submitted electronically; physically submitted TTB will not be processed.

TTB is not binding in terms of title deed fee — meaning the amount in TTB does not imply the fee basis.

Valuation reports are no longer required for non-citizenship transactions; the report/TTB is only for citizenship transactions.

Exception from TTB: TTB confirmation is not required for transactions involving public institutions/organizations and real estate investment trusts (REITs) as parties (the administration may request it if deemed necessary).

Validity periods (official FAQ):

After the promise to sell is annotated in the registry, a new appraisal report is not required during the registration of the immovable property by sale in the name of the promisee.

What happens if the appraisal is below the threshold? In GEDAŞ reports before 009.12.2024, even if the DAB and receipt provide 400,000 USD, if the report is below 400,000 USD, the situation is referred by the Land Registry Directorate to the General Directorate before the transaction, and the transaction is processed according to the received evaluation. However, TTB documents after 09.12.2024 are processed directly based on the value on the document, as they undergo a software comparison.

Payment and Foreign Exchange Purchase Document (DAB) rules

It is essential that the payment be made through the banking system and in foreign currency:

The amount paid must be deposited in a bank in foreign currency; DAB is sent by the bank via KEP to the relevant Land Registry Directorate.

The payment must be made by the buyer (or relevant person) to the account of the seller (or relevant person) and must be documented with a bank-approved receipt (wire transfer/EFT/blocked check).

DAB can be arranged in installments (piece by piece); a separate DAB is possible for each payment.

If the receipt contains items other than the property price, such as commission/expenses, these amounts are deducted and taken as the basis for valuation, provided they are specified in the explanation.

2026 current restriction: According to the TKGM’s instruction dated January 22, 2026, foreigners cannot acquire real estate with loans provided by Savings Finance Companies. This restriction must be taken into account when planning financing.

The most common pitfalls that derail citizenship applications

The following technical errors often underlie rejections or suspensions:

The fallacy of “one appraisal is enough”: Relying solely on a high appraisal; DAB/receipt or declared value falling below the threshold

Non-GEDAŞ report: Non-acceptance of a valuation report obtained from an institution other than GEDAŞ.

Shared (undivided) property: Citizenship applications cannot be made with shared properties acquired since the effective date of the Guide dated 01.02.2023. (Applications based on shared property purchases made before this date are valid.)

Incorrect ownership/company structure: If the real estate is registered in the land registry in the name of a company of which the foreign national applying for citizenship or their first-degree relatives (by blood or affinity) is a partner/manager, this acquisition will not be accepted in the application. The acquisition must be in the name of the foreign real person themselves.

Cash/hand-to-hand payment, lack of DAB: Off-bank payment or no/incomplete issuance of DAB.

Payment from a third party / receipt inconsistency: Payment made outside the buyer-seller line, or receipt explanations not matching the transaction.

Inflated valuation: The value shown above the fair market value; when the DAB/receipt reflects the truth, it falls below the threshold, leading to inconsistency.

“Completing” the sale with a promise to sell: If real estate acquired by purchase does not meet the threshold, the remaining amount cannot be completed with a promise to sell contract.

Multiple promise to sell contracts: In the case of a promise to sell, the threshold must be met with a single contract; applications based on multiple promise to sell contracts are not considered. (In the case of purchase, multiple real estate properties, even if at different times/locations, can be evaluated collectively.)

Unsuitable real estate type: For a commitment in a purchase, the real estate must be classified as a plot of land with condominium ownership/construction servitude established, or with a building on it; in the case of a promise to sell, condominium ownership/construction servitude must be established.

Time limit exceeded: TTB exceeding 6 months after 09.12.2024 (or 3 months for a previous report).

Non-retroactive acquisition: Acquisitions made before 12.01.2017 are not taken as a basis for the application.

Administrative discretion and security: Even if all conditions are met, the application may not be accepted within the scope of the administration’s discretionary power and security/public order assessment.

Formal deficiencies are not definitive grounds for rejection: In cases of formal deficiencies that can be rectified later during the compliance review, the correction of the deficiency is requested without revoking the commitment, and a reassessment is made once completed. However, if the process is not managed correctly, the risk of delay/rejection increases.

Process and Certificate of Conformity (official procedure)

GEDAŞ valuation + TTB: Request for “valuation report for citizenship purposes” via WebTapu/TADEBİS; production of TTB

3-year commitment + Certificate of Conformity: A 3-year commitment not to sell/transfer is registered in the title deed; the Land Registry Directorate forwards the process to the competent authority. Once the Certificate of Conformity is issued, it is sent to the Presidency of Migration Management and the General Directorate of Population and Citizenship Affairs (to provincial directorates), and the interested party is notified via e-mail.

Residence + citizenship application: Application for citizenship residence to the Provincial Directorate of Migration Management, followed by a citizenship application to the Provincial Directorate of NVI (or Joint Offices for Acquiring Citizenship); acceptance occurs after a security review and Presidential decision.

Main documents (official list): title deed/information; passport/national ID (translation if necessary); GEDAŞ appraisal report; municipal property fair value certificate; mandatory earthquake insurance (DASK) for buildings; identity declaration form and photo (last 6 months, 6×4); foreign identity number determination (with tax ID if not available); DAB (bank sends via KEP); bank-approved receipt; sworn translator for the party who does not speak Turkish; duly prepared power of attorney, if any (application with power of attorney is possible if this matter is explicitly stated in the power of attorney).

Pre-acquisition legal review (due diligence) — checklist

Review of title deed status (attachment, mortgage, annotation, easement) and seller’s authority.

Obtaining the GEDAŞ appraisal report/TTB before acquisition — “first report, then decision, then sale”.

Verification that the threshold of each value type (DAB, declared value, appraisal, total payment) is met separately and consistently.

Planning for payment to be made through the bank, between correct accounts, and with DAB; avoidance of using savings financing credit.

Establishing ownership in the name of a foreign real person; avoidance of fractional acquisition and acquisition from a closely related company.

Suitability of the property’s nature (condominium ownership/easement or developed land).

Single contract for promise to sell; understanding that the threshold cannot be completed with a sale-promise to sell mix.

Progress in accordance with the TTB (6 months) schedule; legitimate source (MASAK) and receipt consistency.

Frequently Asked Questions (FAQ)

Is a high appraisal report threshold sufficient on its own? No. Each type of value used for valuation — DAB (Document of Foreign Exchange Purchase), declared sale price, appraisal value, and total payments — must individually meet the threshold and be consistent.

Where should I obtain the appraisal report? Only from GEDAŞ, via WebTapu/TADEBİS. Reports from other institutions are not accepted for citizenship applications.

What is TTB, and how long is it valid? It is the official document generated from the GEDAŞ report, indicating the acceptable amount of the immovable property for citizenship (as of 09.12.2024). Its validity is 6 months; if exceeded, the report must be renewed. TTB is not binding for the land registry fee.

Can I apply by purchasing a shared (jointly owned) house? No. Citizenship applications cannot be made with shared immovable properties acquired as of 01.02.2023; applications based on shared purchases made before this date are valid.

Can I purchase it through my spouse’s/relative’s company? No, you cannot. If the immovable property is registered in the name of a company in which the foreign national himself or his first-degree relatives are partners/managers, the acquisition is not accepted. The purchase must be made in your own name.

Would it be an issue if I pay in cash or hand it over directly? Yes. Payment must be made in foreign currency through a bank, documented with a DAB (Document of Foreign Exchange Purchase), and confirmed by receipt between the buyer’s and seller’s accounts.

Can I buy more than one house? In a purchase, multiple immovable properties (even if at different times/locations) can be assessed with their total value. However, in a promise to sell agreement, the threshold must be met with a single contract; furthermore, it is not possible to make up for a sales shortfall with a promise to sell.

Can I buy with a loan? When purchasing with a foreign currency loan, the remaining amount after deducting the loan from the sales price must meet the threshold. Furthermore, as of 2026, foreigners cannot acquire real estate with a loan from a savings finance company; nor can a purchase with a legal mortgage be subject to citizenship.

I have met all the conditions, is acceptance guaranteed? No. Meeting the conditions is necessary but not sufficient; rejection is possible within the scope of the administration’s discretionary power and security/public order assessment.

Why is expert lawyer support necessary? — 2M Law Office

The success of a citizenship application often lies in technical details not mentioned in a promotional brochure: compatibility of each asset type, GEDAŞ/TTB schedule, DAB and receipt consistency, avoiding pitfalls of shared/related company ownership, correct property qualification and legitimate source. An error in one of these points results in a rejected application and a $400,000 risk. Therefore, legal review (due diligence) conducted before the purchase is more valuable than any subsequent correction.

Tuzla-based 2M Law Office (Founder: Attorney Meryem Günay) provides legal consultancy to foreign investors in real estate and citizenship processes in the Istanbul Anatolian Side — Tuzla, Pendik, Kartal, Maltepe — and Gebze/Kocaeli regions. The firm’s expertise in real estate, commercial, and company law ensures that the entire process, from property selection to the citizenship application, is managed seamlessly and without errors.

Support that 2M Law can offer in this process:

Pre-acquisition due diligence: Title deed/annotation/mortgage review, seller’s authority, share status, and prior verification that all types of value will be provided.

Valuation and process management: Management of the GEDAŞ report/TTB process and the 6-month timeline.

Payment and DAB structure: Payment through the bank, correct account flow and planning of DAB/receipt consistency; avoiding inappropriate financing.

Property and contract structure: Structuring the acquisition in the name of a foreign real person, as a suitable immovable property; a single contract for the promise to sell.

Eligibility certificate + citizenship file: Complete file, management of formal deficiencies, and concurrent processing of family applications.

Eliminate the risk of rejection before acquisition. For the legal review and management of your citizenship process, contact 2M Hukuk Law Office.

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