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Turkish Citizenship by Investment Revoked: The 2026 Review of 6,134 Cases and How to Challenge It

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Turkish Citizenship by Investment Revoked: The 2026 Review of 6,134 Cases and How to Challenge It

Turkish citizenship acquired by investment is not a permanent, untouchable status. In August 2026, the Turkish Ministry of Interior announced that the citizenship decisions of 6,134 people, meaning 1,413 investors and their family members, had been cancelled or withdrawn.

In most cases the legal basis is "withdrawal" under Article 40 of Turkish Citizenship Law No. 5901. A withdrawn decision becomes void from the original grant date and also affects the investor's spouse and children. It can be challenged before the Council of State (Danıştay) within a 60-day time limit.

What Happened in 2026? The Revocations in Numbers

According to the Ministry of Interior's statement of 4 August 2026, the measures stem from two sources. The first is investments made with forged or false documents. The second is public order and national security reviews carried out after citizenship was granted. The reviews were conducted jointly by the National Police, the National Intelligence Organisation (MİT), the Directorate General of Population and Citizenship Affairs, the Land Registry and Cadastre Directorate (TKGM) and the Tax Inspection Board.

DateMeasureInvestorsPeople affected (incl. family)
4 August 2026Suitability certificate and citizenship decision cancelled due to irregular transactions1,1505,391
4 August 2026Cancelled following public order and national security review263743
Total1,4136,134
21 September 2026Istanbul Chief Public Prosecutor's investigation into fictitious property sales1,070 people identified

The irregularities highlighted by the Ministry include forged and inaccurate valuation (appraisal) reports, fictitious property sales and attempts to forge documents before filing applications. This is therefore not only a matter for people who acted with criminal intent. It directly concerns good-faith investors who bought through an agent, developer or citizenship consultant.

Cancellation or Withdrawal? Two Different Legal Routes

Law No. 5901 provides two separate mechanisms for removing a citizenship decision, and the consequences differ depending on which one is used. In citizenship-by-investment cases, the authorities rely mainly on Article 40.

Cancellation of citizenship (Art. 31) means revoking the grant because the person made false statements or concealed material facts on which the grant was based. Withdrawal of a citizenship decision (Art. 40) applies when it later emerges that the decision was issued without the legal conditions being met, or was issued twice. Withdrawal does not require fault or intent.

CriterionCancellation (Law 5901, Arts. 31–33)Withdrawal (Law 5901, Art. 40; Regulation, Art. 66)
GroundFalse statements or concealment of material factsLegal conditions never met (e.g. suitability certificate annulled)
Fault of the personRequiredNot required; an objective defect is sufficient
Legal effectFrom the date of the cancellation decision (prospective)Void from the original grant date (retroactive)
Spouse and childrenAlso applies to family members who acquired citizenship through the investor (Art. 32)In practice the family is also affected, since the basis of their derivative acquisition falls away
AssetsIf stated in the decision, assets must be liquidated within 1 year (Art. 33)No specific liquidation rule; the rules on property acquisition by foreigners apply

What decides a withdrawal is whether the investment genuinely met the legal requirements, not what the investor intended.

Which Investments Are at Risk?

The risk depends on whether the real estate investment suitability certificate (tapu uygunluk belgesi) behind the citizenship remains valid. If the Land Registry annuls that certificate, the ground for withdrawing citizenship effectively exists. Article 20 of the Regulation on the Implementation of the Turkish Citizenship Law sets two conditions for citizenship through real estate. The investment must reach a minimum amount, which a 2022 amendment raised to USD 400,000. A three-year no-sale annotation must also be registered on the title deed.

In practice, the most common reasons for annulment of the suitability certificate are:

  • Inaccurate foreign currency purchase certificates: the price was not actually brought into the bank as foreign currency, or the certificate belongs to a different transaction.
  • Inflated valuation reports: a high value is stated in the report although the real market value is below the threshold.
  • Fictitious or round-trip sales: part of the price is refunded, the property later returns to the seller, or the same property is used for more than one application.
  • Mismatch between declared and actual price: the price declared at the Land Registry, the bank records and the valuation report do not corroborate one another.
  • Breaches of the three-year annotation: the property is transferred before the period ends, or there are side agreements aimed at such a transfer.

Antalya is one of the provinces where foreigners buy the most residential property. Investors who obtained citizenship through property in the region should therefore review their files, especially the valuation report and the payment documents.

Will Family Members Lose Their Citizenship Too?

As a rule, yes. Under Article 32 of Law No. 5901, a cancellation also applies to a spouse and children who acquired Turkish citizenship through the person concerned. The Ministry's figures show this effect in practice: 1,413 investors, but 6,134 people affected.

There is also a procedural point to keep in mind when filing a lawsuit. The Council of State has held that different families cannot bring a single joint action, even where their citizenship was withdrawn by the same Presidential Decision on the same ground. This is because each investor's foreign currency certificate and suitability certificate are separate documents (Council of State, 10th Chamber, Docket 2023/6208, Decision 2025/169, 14.01.2025). Each family's case must be structured separately.

What Happens to the Property and Other Assets?

Losing citizenship does not automatically end ownership of the property. However, the person reverts to foreign national status and holds the property as a foreigner.

  • In a cancellation under Article 31, if liquidation of assets is considered necessary, this is stated in the cancellation decision. The person must then liquidate their assets in Türkiye within one year at the latest. Otherwise the Treasury sells the assets and deposits the proceeds in the person's name at a public bank (Art. 33(1)). If the person challenges the decision in court, liquidation is postponed until the case ends (Art. 33(2)).
  • In a withdrawal under Article 40, the law contains no specific liquidation rule. Because the person is now a foreigner, the restrictions on property acquisition by foreigners in Article 35 of the Land Registry Law become relevant again. This needs separate assessment for nationals of countries whose citizens face restrictions on acquiring property.
  • A person who wishes to stay in Türkiye must obtain a valid residence permit. Otherwise they may face the consequences of unauthorised stay under Law No. 6458 on Foreigners and International Protection.

How to Challenge the Decision in Court

An action for annulment of the Presidential Decision withdrawing citizenship is filed directly with the Council of State, acting as the court of first instance, within 60 days of notification (Administrative Procedure Law No. 2577, Art. 7). The chamber's judgment can be appealed to the Plenary of Administrative Law Chambers within 30 days. A request for a stay of execution can be included in the petition.

The most important strategic step is to file a separate action against the Land Registry's decision annulling the suitability certificate, not only against the citizenship decision. In a 2026 judgment, the Council of State expressly took into account that no action had been brought against the annulment of the suitability certificate:

Council of State, 10th Chamber, Docket 2024/405, Decision 2026/361, 05.02.2026 (unofficial translation)

"…it is undisputed that, after it was subsequently established that the foreign currency purchase certificates underlying the investment had been issued contrary to the truth, the real estate investment suitability certificate was annulled …, and it is understood that the claimant did not bring an action against that decision."

The same judgment also sets limits on withdrawal. The grounds for withdrawal must be established with "concrete, sufficient and serious information". Whether the legal conditions were met is, as a rule, assessed as of the date citizenship was granted. Facts arising after the grant that have no link to the earlier period cannot justify withdrawal. These criteria shape the defence: proving that the valuation report was accurate, proving the payment through bank records, and showing that any irregularity was committed by third parties rather than the investor.

File Checklist for Investors

1. Original suitability certificate and its date of issue

2. Exact match between foreign currency purchase certificates and bank account movements

3. Confirmation that the valuation report was issued by a CMB (SPK) licensed firm and matches comparable sales from the same period

4. Consistency between the sale price declared at the Land Registry and the amount actually paid

5. Review of any side agreements with the seller, agent or developer, such as refunds, buy-backs or rental guarantees

6. Confirmation that the three-year no-sale annotation has remained on the title deed without interruption

Once notification is served, time limits run quickly. Investors who acquired citizenship through property in Antalya are well advised to have a lawyer audit their file before any letter arrives. This makes preparing a defence far easier if proceedings begin.

Frequently Asked Questions About Revocation of Turkish Citizenship by Investment

Can citizenship obtained by investment be withdrawn years later?
Yes. Article 40 of Law No. 5901 sets no time limit for withdrawal. The Council of State also accepts that a decision can be withdrawn at any time if it later emerges that a legal condition was not met from the outset.
If the agent or developer committed the irregularity, will I lose my citizenship too?
Because withdrawal does not require fault, a good-faith investor's citizenship is also at risk if the investment did not meet the legal requirements. However, documentary proof that the payment was genuinely made and of the property's real value can be decisive in a lawsuit against the annulment of the suitability certificate. Civil compensation and criminal complaints against the intermediary should also be considered.
What happens to my Turkish passport if my citizenship is withdrawn?
Because a withdrawn decision is void from the original grant date, the identity card and passport issued on the basis of citizenship also lose their validity. A person who intends to remain in Türkiye must apply for a residence permit.
Does my citizenship continue while the lawsuit is pending?
Filing a lawsuit does not automatically suspend the decision. A stay of execution must be requested in the petition and granted by the Council of State. In cancellations under Article 31, liquidation of assets is postponed until the end of the case.
I sold the property after the three-year period. Does that create a risk?
A sale after the annotation period has expired is not, on its own, a ground for withdrawal. The risk depends on whether the original investment met the legal requirements on the application date. This is why valuation and payment records should be kept.
Can someone whose citizenship was withdrawn apply again later?
There is no absolute statutory bar. However, any new application is subject to a national security and public order assessment in which the earlier withdrawal is taken into account. Where the file involves document forgery or a criminal investigation, a new application is very difficult to succeed.
Which court hears a challenge to the withdrawal of citizenship?
Because the measure is a Presidential Decision, the action is filed with the Council of State acting as the court of first instance. An action against the Land Registry Regional Directorate's annulment of the suitability certificate must be filed with the competent administrative court. For property located in Antalya, the jurisdiction rules should be checked separately.
Legal Notice This article is for information purposes only and does not constitute legal advice. The figures are based on statements by the Turkish Ministry of Interior in August and September 2026. You should consult a lawyer for an assessment of your individual situation.
Attorney Rafet Aslan
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Attorney Rafet Aslan

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Attorney Rafet Aslan provides legal counsel and dispute representation in Antalya across criminal, family, commercial, real estate, labor, and immigration law. These articles explain legal risks and current practice in clear terms.
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