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MisakLex | Foreigners and citizenship law | Updated: 17 September 2026
You have received your Turkish identity card and passport. You now want to move to another home, use the money in your bank account or change your investment. The fact that a citizenship decision has been issued does not mean that every obligation you assumed on account of the investment has ended. First, you must establish your investment route, the date on which the undertaking began and how the proposed transaction would affect compliance with its conditions. Calculating the three-year period from the passport's issue date, in particular, could lead to the wrong conclusion.
The general answer is this: releasing the investment may become possible once the relevant holding period and other conditions have been fulfilled. A sale or withdrawal before that time may affect the citizenship file. But it would also be wrong to say that every transaction is “absolutely prohibited” or that “citizenship is cancelled immediately”. A land registry or banking transaction and an administrative decision concerning citizenship must be assessed separately. This article explains that distinction chiefly through real estate, bank deposits and fund investments.
1. Why are the citizenship decision and the investment undertaking different?
Citizenship by investment is based on the framework in Article 12 of Law No. 5901 and Article 20 of its Implementing Regulation. In addition to meeting the prescribed investment amount, the continuing obligations attached to the chosen route matter. Even if the citizenship application has been decided, a holding obligation may remain unfulfilled. Delivery of the identity card is not, in itself, a document releasing the investor from that obligation.[1,2]
For example, citizenship may have been acquired while the undertaking registered against a property remains in force. The investor then has two distinct dates: the date citizenship was acquired and the date the investment undertaking is fulfilled. The latter must be checked when planning a sale. For a bank or fund investment, one should likewise not assume that the date the application is decided is also the date the restriction on the investment ends.
Instead of treating the file as closed when the citizenship procedures are complete, draw up a short timetable of the obligations still to be performed. Support it with land registry records, the bank undertaking or the competent authority's eligibility documents. Identifying the written basis for a proposed transaction, rather than relying on an oral assurance that “you may now proceed”, reduces the risk of later disputes.
2. Which investment routes are subject to the three-year requirement?
Under the Regulation, acquiring real estate entails a threshold of USD 400.000, or the equivalent in foreign currency, and an undertaking not to sell for three years. For bank deposits, government debt instruments, eligible real estate or venture-capital investment fund units, and the private pension route, the relevant USD 500.000 threshold or its foreign-currency equivalent is accompanied by conditions to retain the investment or remain in the system for three years. Each route also has its own requirements as to documents, monitoring and the nature of the investment.[2,3,4,5]
The fixed-capital and employment routes should not be forced into the same pattern as those investment instruments. This does not, however, mean that they carry no continuing obligations. For example, the employment rules published by the Ministry of Labour and Social Security state that an eligibility request requires at least 50 Turkish citizens to have been employed continuously for at least six months before the application, and that the employment must continue for at least two years after it.[6]
It may therefore be misleading to choose an investment route solely on the basis of the shortest lock-in period. The reality of the company's operations and employment, the nature of the investment and the competent authority's assessment criteria must be considered together. The three-year timetable described here for real estate or bank deposits should not be applied unchanged to a different investment route.
3. From which date should I calculate the three-year period?
For real estate, the purchase date, the date the undertaking was entered in the register and the date of the citizenship decision must each be identified. The three-year obligation should be checked against the date the citizenship undertaking was registered at the land registry and the transaction documents. If the undertaking was entered after the purchase, relying on the earlier acquisition date alone is unsafe. Where an application involves several properties, it must also be established which property is covered by which undertaking.[7]
For example, someone who buys an apartment in March but registers the citizenship undertaking in June may encounter problems if they plan an exit solely by reference to the March purchase date. The exact end date should be confirmed from the land registry record and the relevant directorate's file. Believing that three years have passed on a calendar does not guarantee that the sale can be completed while existing entries remain in place.
For fund investments, the Capital Markets Board rules require uninterrupted retention from the date the minimum investment amount is met. For bank deposits, both the deposit of the citizenship-qualifying amount and the restriction and undertaking records must be examined. The role played by each date—the transfer of funds, issuance of the eligibility certificate and filing of the citizenship application—should be clear in the particular file. There is no single common starting date for every investment type.[4,2]
4. Does the entry in the land register disappear automatically after three years?
When the period of the citizenship undertaking attached to a property expires, the entry is cancelled on the owner's application; cancellation means removing that particular entry from the land register. Preparations for a sale can begin when the period ends, but the current registry entry and the necessary application procedures must still be dealt with. A mortgage, attachment or other restriction may affect the transaction independently of the citizenship undertaking.[8,9]
Files pursued through a promise of sale require particular care. According to the General Directorate of Land Registry and Cadastre (TKGM), where citizenship was acquired through a registered promise of sale, the citizenship undertaking entry is not removed before the sale to the beneficiary of that promise is completed. Thus, “three years have passed, so I can cancel the notarised agreement and leave the investment” does not produce the same result as in a direct acquisition of title. Establish at the outset whether the file concerns a completed purchase or a promise of sale.[8]
Before finding a buyer, accepting a deposit and promising transfer on a particular date, check whether the land registry transaction can actually be completed. Undertaking a firm transfer date while an entry that cannot yet be removed remains in force may create a contractual dispute with the buyer as well as a citizenship issue. The legal preparations for an exit should proceed alongside the commercial negotiations.
5. What happens if I want to sell before three years have passed?
The guide annexed to TKGM Circular No. 2024/4 provides that, after the Taşınmaz Yatırımı Tespit Belgesi (TYTB; real estate investment assessment certificate) is issued, an application by the entitled person to cancel the entry before three years have elapsed is to be processed and reported to the provincial directorates of Population and Citizenship Affairs and Migration Management. The crucial distinction is that the possibility of cancelling the land registry entry does not mean that an early release of the investment has been approved for citizenship purposes. The applicable procedure must be checked against the file's date and the relevant current instructions.[9,7]
For that reason, an older guide's statement that “a letter proving that citizenship has first been cancelled is always required” should not be applied automatically to every file. Equally, it is unsafe to assume that “if the land registry directorate processes the transaction, my citizenship cannot be affected”. Cancellation of the entry, notification, assessment of the investment conditions and a decision on citizenship are separate steps.
If retaining citizenship is particularly important, examine whether a switch to another investment route is possible before requesting an early exit. Selling the property first and then looking for an alternative investment may make it harder to prove uninterrupted compliance. Where the application has not yet been decided, an early release may also affect the investment basis needed for admission to citizenship.
6. Can I complete the remaining period by changing the type of investment?
Paragraph eight of Article 20 of the Regulation permits a switch between investment types for the purpose of completing the prescribed period. It does not, however, allow an investor to withdraw funds on any chosen day and move them freely to another investment instrument. Release of the old investment, acceptance of the new one, preservation of the required amount and the authorities' documentation procedures must be planned together.[2,5]
For example, someone wishing to move from real estate to another route must also meet the new route's own minimum amount. The USD 400.000 threshold for real estate does not automatically satisfy the USD 500.000 condition of another route. How the elapsed period will be credited, and which documents and dates will govern the switch, should be clarified with the competent authorities.[2,3]
The Insurance and Private Pension Regulation and Supervision Agency's (SEDDK) rules on switching to private pensions require earlier eligibility letters to be submitted and the path of the invested money to be traceable. This illustrates that a switch is more than moving money between accounts. A sale, redemption of fund units or withdrawal made without a documented sequence of steps should not be treated as a minor defect that a later petition will necessarily cure.[5]
7. What happens if the dollar equivalent of my bank deposit falls?
Under the bank-deposit route, the foreign currency required for citizenship is sold to the Central Bank through a bank under the relevant rules; the resulting amount in Turkish lira is retained on deposit for three years. The Central Bank's instruction also requires the bank that sells the foreign currency to be the same bank that holds the Turkish lira deposit. The investor should therefore not assume that “I deposited USD 500.000, so the same dollar account will remain untouched for three years”.[2,10]
Two matters are distinct here: maintaining the conditions for the citizenship-qualifying investment and preserving its economic value. The rules on selling foreign currency do not, by themselves, guarantee the principal or return of every account in US dollars. The terms of the particular banking product and the scope of any special protection mechanism must be checked separately. Features of one banking product should not be presented as features shared by all citizenship investments.
The ability to use interest or profit distributions must also be distinguished from reducing the principal counted for citizenship. Ask the bank in writing which amount is restricted, which returns may be used freely and whether the proposed transaction affects the eligibility notification. Renewing a term deposit, moving an account to another bank and withdrawing even a small amount are different transactions; the effect of each on the undertaking should be checked.
8. Is a fall in a fund's value the same as selling fund units?
No. The Capital Markets Board's rules for real estate investment fund (GYF) and venture-capital investment fund (GSYF) units state that a fall below USD 500.000 in value caused by exchange-rate movements does not affect the citizenship application or acquisition. That situation is different from an investor voluntarily selling restricted units or reducing the investment. The fund-specific rule should not be read as a general exchange-rate exemption for every investment instrument.[4]
For example, the file of an investor who retains the units cannot be assessed in the same way as that of an investor who converts some of them into cash. Records should distinguish a currency or market movement from the investor's own transaction and from a change arising from the fund's operation. Check that any explanation obtained from the fund manager is consistent with the eligibility and restriction records.
An attachment, interim measure or other encumbrance over fund units may also have consequences under the Capital Markets Board rules. Retaining an investment involves more than simply refraining from placing a sell order. In a debt dispute in particular, the fact that an investment is being held for citizenship purposes should be included in the legal assessment from the outset.[4]
9. How do divorce, death or a forced sale affect the file?
Investors should not treat every change in family or property circumstances as an ordinary voluntary sale. Transfer of property to heirs, a transfer following division of marital property, a sale in enforcement proceedings and a disposal made by the investor's choice arise from different legal grounds. In whose name and under which entry the transaction will take place, and whether the undertaking continues, must be examined separately.
The guide annexed to TKGM Circular No. 2024/4 provides for the undertaking entry to pass to the heirs upon inheritance; where ownership changes without the investor's volition, such as by court judgment, forced sale or expropriation, the transaction is to proceed in accordance with the General Directorate's opinion. The current instructions applicable to the particular file must also be confirmed. There is no general rule that “death ends every obligation” or that “property may be transferred freely on divorce”.[7]
A change within the family does not alter the legal route by which citizenship was acquired. Acquisition dependent on an investor and citizenship through marriage are not the same route. To assess the position of a spouse or child, consider their own citizenship decision, the family relationship and the proposed property transaction together.[1]
10. Does a breach of the conditions automatically annul citizenship?
Annulment of citizenship and withdrawal of a citizenship decision are governed by different provisions. Article 31 of the Law addresses acquisition resulting from a false declaration or concealment of significant facts relevant to acquiring citizenship. Article 40 concerns withdrawal of decisions issued when the legal conditions had not been met or issued more than once. It would be wrong to characterise every early sale automatically as fraud; the basis of the transaction and the specific facts must be investigated.[1]
Conversely, the removal of a restriction at the land registry or bank does not guarantee that citizenship is secure. Following notification, the competent authority may carry out an assessment and issue a separate decision. The decision's legal basis, the investor's conduct, the documents and the procedure followed must be examined when considering an administrative application or court proceedings.
Completion of the three-year period does not, by itself, eliminate separate problems such as forged documents or concealment of significant information at the outset. Article 32 of the Law also regulates the effects of an annulment decision on a spouse and children who acquired citizenship through the person concerned. Their position must therefore be examined by reference to the basis on which each acquired citizenship; no single automatic outcome should be assumed for every family member.[1]
11. Final checks before a sale or withdrawal
Before proceeding, establish five matters in writing: which investment formed the basis of citizenship; when the obligation began and ends; which registry entry or restriction will be removed; how the proposed transaction will be notified to the authorities; and whether it will affect family applications or pending proceedings. Have the answers before accepting a buyer's deposit or instructing a withdrawal.
Keep the land registry records, undertaking and cancellation documents, eligibility letters, foreign-exchange purchase and payment documents, account statements, citizenship decision and any correspondence about switching investments in an orderly file. The tax and contractual consequences of a sale after the investment ends must also be assessed separately. Fulfilment of the citizenship undertaking does not mean that every financial and private-law obligation has ended.
If the application has not yet been decided or has been refused, the related article in this series, “I Made the Investment, but My Turkish Citizenship Application Was Refused: What Can I Do Now?”, may also be useful. A legal review of the investment documents before deciding to sell or withdraw makes it possible to assess both citizenship status and the proposed transaction together. This text is for general information; it offers no guarantee of an outcome or return on investment.
Sources
Sources checked on 17 September 2026. The numbers in the text refer to the sources below.
[1] 5901 sayılı Türk Vatandaşlığı Kanunu (Law No. 5901), in particular Articles 10, 12, 31–32 and 39–41 (consolidated statutory text) Access source
[2] Türk Vatandaşlığı Kanununun Uygulanmasına İlişkin Yönetmelik (Implementing Regulation for the Turkish Citizenship Law), Article 20 (2010/139; consolidated legislative text) Access source
[3] Presidency's Investment and Finance Office, Real Estate and Acquisition of Citizenship Access source
[4] Capital Markets Board, Exceptional Acquisition of Turkish Citizenship by Foreigners Through Investment; conditions and monitoring rules for GYF/GSYF units Access source
[5] SEDDK, Circular on the Private Pension System, section on acquisition of citizenship by foreign nationals and the “Switching” provision Access source
[6] Ministry of Labour and Social Security, Exceptional Turkish Citizenship; published procedures and principles for the employment route Access source
[7] TKGM, guide annexed to Circular No. 2024/4 dated 9.12.2024; sections on obtaining undertakings, cancellation of entries and transactions involving properties subject to an undertaking Access source
[8] TKGM / Your Key Türkiye, Frequently Asked Questions, Section 7: property acquisition for citizenship, TTB and cancellation of undertaking entries Access source
[9] TKGM, official explanation entitled “Taahhüt (Şerh) Terkini nasıl yapılır?” (“How is an undertaking/annotation cancelled?”) Access source
[10] Central Bank of the Republic of Türkiye, Implementation Instruction on Foreign-Currency Sales Under the Citizenship Regulation, text amended on 16.5.2022, Articles 4 and 6–8 Access source