Türkiye’s 2026 property-law reforms did not change the country’s citizenship-by-investment rules, but they do change the due diligence environment for buyers using real estate to qualify. The US$400,000 property route remains in place, with a licensed appraisal requirement and a three-year no-sale commitment on the title deed, but buyers now need to pay closer attention to title security, developer compliance, and declared purchase price.
Citizenship rules did not change
Türkiye passed two omnibus property-law packages in 2026:
- Law No. 7579, published in Official Gazette No. 33261 on 22 May 2026;
- Law No. 7584, published in Official Gazette No. 33286 on 20 June 2026.
Together, the laws amend statutes covering zoning, building inspection, land registry, cadastre, condominium ownership, and agricultural land.
Neither law changes the citizenship-by-investment framework. The real estate route still requires:
- Property worth at least US$400,000;
- A licensed appraisal report;
- A three-year no-sale commitment annotated on the title deed, or tapu.
No investment threshold, holding period, or eligibility condition changed in 2026.
The practical effect is different: the legal quality of the property used for citizenship now matters even more. For applicants who rely on a single property held for three years, the core question is not only whether the purchase qualifies, but whether the asset is legally sound.
Forest-boundary title issues
Article 14 of Law 7584 adds Additional Article 22 to the Forest Law, No. 6831. It addresses properties privately registered in the land registry but later found to sit partly or fully within state-forest boundaries after a finalized forest cadastre.
Such properties may carry a forest annotation, known as orman şerhi, or face title cancellation, even when the title deed appears normal.
The new rule provides a remedy in some cases. If the property is not registered to the Treasury and the General Directorate of Forestry approves, the title remains valid, no payment is due, and the forest annotation is removed.
Where titles have already been cancelled and registered to the Treasury, former owners and legal successors have a two-year window to apply for restitution, provided they repay any compensation received.
For citizenship buyers, the reform confirms that forest and cadastre checks should be standard pre-purchase due diligence.
There is an important limitation: Article 14 excludes properties within culture-and-tourism protection and development zones and tourism centers designated under the Tourism Encouragement Law. This matters because many foreign investor purchases are in coastal and tourism corridors. In those areas, a property with a forest-boundary defect may not benefit from the new remedy, making upfront title checks more important.
Developer and construction compliance
Many citizenship-by-investment purchases involve new-build or off-plan units bought from developers.
Law 7579 tightens rules for developers and construction compliance. Three changes are especially relevant:
- Building a project using a fake or misrepresented contractor-classification certificate now triggers a sealing order and cancellation of the contractor’s certificate number for five years.
- A periodic fire-safety inspection regime has been introduced, and fire-safety reports are expected to become routine documents in sales and leases.
- Building inspection now extends to ready-mix concrete producers and soil-survey organizations, with administrative fines of up to 500,000 Turkish lira, approximately US$10,750, and mandatory traceability through QR-coded delivery notes and mixer labels.
For citizenship investors, these rules affect both legality and resale. The buyer must hold the property for three years and may later want to sell it.
Properties delivered by non-compliant developers, or buildings lacking expected fire-safety paperwork, may carry higher permit risk and resale discounts. Checking the developer’s contractor certificate and the building’s compliance file is now a more material step than before.
Declared price and citizenship risk
Under-declaring the sale price on the title deed remains a major risk. The practice involves registering a price below the real transaction amount to reduce transfer tax.
Turkish tax law applies a real-essence principle: the title-deed fee is calculated on the genuine transfer price, while the municipal tax value only serves as a floor.
The Revenue Administration increasingly cross-checks declared prices against banking records. Mortgage and appraisal figures are treated as strong evidence of true value.
If the declared price is below the real transaction price, both buyer and seller can face:
- Supplementary tax assessment;
- Tax-loss penalty;
- Late interest;
- Arguments that the registration was simulated, or muvazaa, and therefore voidable.
For citizenship buyers, the risk is greater because the US$400,000 threshold is measured on a licensed valuation and the application depends on a documented, genuine acquisition.
Understating the price to save transfer tax can weaken the evidence supporting the citizenship application and expose the transaction to annulment. The safer approach is to declare a price that matches the appraisal and banking trail.
Practical due diligence for buyers
The 2026 reforms leave Türkiye’s citizenship-by-investment real estate route intact, but they raise the importance of proper checks before purchase.
Buyers should focus on three areas:
- Run forest and cadastre checks before committing, especially for coastal or tourism-zone properties where the new forest-title remedy does not apply.
- Verify the developer’s contractor certificate and the building’s compliance and fire-safety file, especially for new-build or off-plan purchases.
- Declare the genuine appraised value and ensure the banking trail supports the transaction.
The reforms point toward a cleaner and more traceable property market. For citizenship investors, that may improve asset security if the purchase is treated as a serious legal transaction. The risk is higher for buyers who treat the property only as a formality to obtain a passport.
Source article: www.imidaily.com
