Can Stateless Persons Acquire Turkish Citizenship Through Real Estate Investment?

The most frequently used route to exceptional Turkish citizenship for foreign investors is the acquisition of real estate above a defined minimum value. Whether this route is also open to persons who hold no nationality of any state — in legal terms, "stateless persons" — is a question that arises periodically in practice but does not have a direct, express answer in the legislation. This article examines the question by reference to Law No. 5901 on Turkish Citizenship, the Regulation on the Implementation of the Turkish Citizenship Law, the relevant Presidential Decrees, the circulars and opinion letters of the General Directorate of Land Registry and Cadastre ("TKGM"), and Law No. 6458 on Foreigners and International Protection, with the date and reference number of each source cited alongside the point it supports.

1. The General Framework for Citizenship by Investment

Article 12(1) of Law No. 5901 on Turkish Citizenship (adopted 29 May 2009, Official Gazette of 12 June 2009, No. 27256), titled "Exceptional cases for the acquisition of Turkish citizenship," provides:

"Provided that no impediment exists on grounds of national security or public order, the foreigners listed below may acquire Turkish citizenship by decision of the President."

This exceptional route, as applied to real estate investment, is set out in Article 20(2)(b) of the Regulation on the Implementation of the Turkish Citizenship Law (Council of Ministers Decision of 11 February 2010, No. 2010/139; Official Gazette of 6 April 2010, No. 27544). The version of this provision currently in force as of 2026 was shaped, in sequence, by Presidential Decree No. 5072 (Official Gazette of 6 January 2022, No. 31711), Presidential Decree No. 5554 (Official Gazette of 13 May 2022, No. 31834), and Presidential Decree No. 7938 (Official Gazette of 12 December 2023, No. 32397), and continues to be applied in that form. TKGM's Guide on the Implementation of the Turkish Citizenship Regulation, dated 9 December 2024 (the "Guide"), reproduces the provision as currently in force as follows:

"A foreigner determined by the Ministry of Environment, Urbanisation and Climate Change to have purchased, subject to an annotation in the land registry prohibiting sale for three years, real estate consisting of an independent unit subject to condominium ownership or floor easement, or a building plot bearing a structure, worth at least USD 400,000 or its equivalent in foreign currency; or to have had the sale of such real estate — worth at least USD 400,000 or its equivalent in foreign currency, paid in full in advance — promised under a notarised sale-promise agreement annotated in the land registry with an undertaking not to transfer or cancel the registration for three years, may acquire Turkish citizenship by decision of the President."

Accordingly, the conditions applicable in 2026 that must be satisfied for an application are:

• The value of the real estate (whether purchased outright or subject to a sale-promise agreement) must be at least USD 400,000, or its equivalent in foreign currency. This threshold was set by Article 1 of Presidential Decree No. 5554 (Official Gazette of 13 May 2022, No. 31834) and remains in force.

• The real estate must qualify as an independent unit subject to condominium ownership (kat mülkiyeti) or floor easement (kat irtifakı) under Law No. 634 on Condominium Ownership, or, if it is a building plot, it must bear a permanent structure holding a valid occupancy permit (yapı kullanma izin belgesi) that complies with applicable regulations. This qualifying requirement was introduced by Presidential Decree No. 7938 (Official Gazette of 12 December 2023, No. 32397) and remains in force.

• An annotation must be entered in the land registry recording that the property may not be sold for three years, or, in the case of a sale-promise agreement, that the notarised agreement may not be transferred or cancelled for three years.

• The purchase price must have been sold to a bank for onward sale to the Central Bank of the Republic of Turkey, evidenced by a foreign-currency purchase certificate (the option of paying the equivalent in Turkish lira was removed from the Regulation's text by Presidential Decree No. 5072, Official Gazette of 6 January 2022, No. 31711).

Information on the periods preceding these rules (the lower thresholds applied between 2017 and 2022) is relevant only to persons who completed transactions during those earlier periods and has no bearing on a new application filed in 2026; for that reason, it is not addressed further in this article.

2. Are Stateless Persons Legally Considered "Foreigners"?

The first link in the analysis is whether a stateless person qualifies as a "foreigner" within the meaning of Law No. 5901. Both Article 3(u) of the Regulation on the Implementation of the Turkish Citizenship Law and Article 3(1)(ü) of Law No. 6458 on Foreigners and International Protection (adopted 4 April 2013, Official Gazette of 11 April 2013, No. 28615) define "foreigner" in identical terms:

"Foreigner: a person who has no bond of nationality with the Republic of Turkey."

Since a stateless person, by definition, has no bond of nationality with any state — including the Republic of Turkey — we take the view that such persons fall within this definition. Indeed, the legislature has expressly contemplated statelessness elsewhere in the same body of rules: Article 15(a) of the Implementing Regulation, titled "General acquisition of Turkish citizenship" (which corresponds to Article 11 of Law No. 5901, governing the general route to citizenship), requires an applicant to satisfy the condition of "having attained majority and possessing the capacity to distinguish right from wrong, under his or her own national law or, if stateless, under Law No. 4721 (the Turkish Civil Code)." This provision demonstrates that the legislation implicitly — and expressly — contemplates that stateless persons, too, may apply for citizenship. Article 12 refers to those eligible for the exceptional route in the general category of "foreigners," without any special provision excluding stateless persons from that scope.

One clarification is necessary at this point: the analysis above concerns only whether a stateless person carries the abstract status of "foreigner" for purposes of Article 12. This does not, as discussed below, mean that such a person necessarily holds the capacity to acquire real estate — that is a separate question requiring independent legal grounding.

3. The Precondition for the Investment Requirement: Capacity to Acquire Real Estate

The principal practical hurdle to a citizenship application based on real estate investment is that the applicant must first be legally capable of acquiring the property in question. The Guide makes this point explicitly under the heading "PRECONDITION FOR APPLICATION":

"In order to acquire Turkish citizenship through real estate acquisition, the conditions of eligibility relating to both the person and the property required under Law No. 2644 on Land Registry and other relevant legislation must first be satisfied in transactions relating to sale and sale-promise agreements."

In other words, before a citizenship application can even be considered, a valid acquisition of real estate must first have taken place, on the same footing as for any ordinary foreign natural person. This general acquisition regime is set out in Article 35 of Law No. 2644 on Land Registry (dated 22 December 1934; Article 35 as re-enacted by Article 1 of Law No. 6302 of 3 May 2012):

"Subject to statutory restrictions, and where required by international bilateral relations and national interest, foreign natural persons who are nationals of countries designated by the President may acquire real estate and limited rights in rem in Turkey. The total area of real estate, and of limited rights in rem of an independent and permanent nature, acquired by a foreign natural person may not exceed ten percent of the privately ownable surface area of a district, nor thirty hectares nationwide per person."

3.1. The Identity and Residence Status of Stateless Persons

Article 50 of Law No. 6458, in the Third Chapter headed "Stateless Persons," provides:

"(1) The determination of statelessness shall be made by the Directorate General. A Stateless Person Identity Document, which grants the right to reside lawfully in Turkey, shall be issued to stateless persons. […] (2) Stateless persons are required to obtain a Stateless Person Identity Document, which shall be issued by the governorships upon the favourable opinion of the Directorate General. This document, which is not subject to any fee, takes the place of a residence permit […]."

Although it is clear that this document takes the place of a residence permit, we were unable to identify, among the source materials available to us, any provision in TKGM's Circular No. 2013/13 (1750) of 16 September 2013, titled "Identity Verification in Land Registry Transactions Involving Foreigners," that expressly and by name addresses stateless persons. That Circular provides that, in land registry transactions, the identity documents or passports duly issued by the competent authorities of the foreign national's own country of nationality are to be relied upon for identity verification; it sets out a special identity-verification procedure for nationals of the State of Palestine and confirms that the Blue Card may be used as an identity document — but it does not separately or expressly refer to stateless persons or to the Stateless Person Identity Document. Accordingly, the conclusion that a stateless person may establish identity in a land registry transaction by means of the Stateless Person Identity Document rests not on an express circular provision, but on an interpretive inference drawn from the function that Article 50 of Law No. 6458 assigns to that document (standing in place of a residence permit) and from general procedural logic. It would be prudent to confirm, in advance of an actual application, how the relevant land registry directorate treats this document in practice.

3.2. Application of the General Foreign-Acquisition Regime to Stateless Persons

The principal basis for stateless persons' capacity to acquire real estate is Article 7 of the Convention Relating to the Status of Stateless Persons (New York, 28 September 1954), to which Turkey acceded by Law No. 6549 of 1 July 2014:

"Except where this Convention contains more favourable provisions, a Contracting State shall accord to stateless persons the same treatment as is accorded to aliens generally."

A concrete instance of how this provision has been applied administratively can be found in an opinion letter issued by TKGM's Directorate of Foreign Affairs on 10 June 2015, reference number 36189470-010.07.01[125.01.04]/503519. It should be emphasised that the subject of this letter is not, in general terms, "acquisition of real estate by stateless persons," but specifically "Acquisition of Real Estate by Stateless Persons Through Inheritance." It was issued in response to a request from the 9th Family Court of Istanbul concerning whether a person who had been stateless as of 7 June 1985 could acquire real estate as an heir. In that letter, TKGM confirmed that, under Article 7 of the Convention, the acquisition of real estate and limited rights in rem by stateless persons is assessed "by reference to the general regime applicable to foreigners," and concluded that inheritance was possible on the facts presented.

This document is a valuable and direct precedent showing that Article 7 of the Convention has actually been applied by TKGM; however, because its subject matter is acquisition by inheritance, it should be relied upon with some caution as direct authority for acquisition by purchase for investment purposes. That the underlying principle (application of the general foreign regime) would extend to purchase transactions as well can reasonably be inferred from the general and categorical wording of the principle itself — but this remains an inference, not a fresh and current TKGM opinion addressing the purchase context specifically; the 2015 letter concerns a different legal footing (inheritance).

3.3. A Further Limitation Within the General Foreign-Acquisition Regime: The Country List

At this point we would highlight an issue that, in our view, deserves separate attention and has not been sufficiently foregrounded in prior treatments of this topic. Article 35 of Law No. 2644 confines the general capacity to acquire real estate to "foreign natural persons who are nationals of countries designated by the President." The list of countries whose nationals may acquire real estate under this framework was announced by Circular No. 2012/12 (1734) of 6 August 2012 and integrated into TAKBİS (the land registry information system). A national of a country not on this list — for example, as our sources concretely confirm, a Syrian national — cannot acquire real estate in Turkey in his or her own name, and consequently cannot apply for citizenship through real estate acquisition either.

Because the system operates on a country-list logic, the question arises of how a stateless person — who, by definition, is a national of no country — is to be classified under that list. The sources available to us do not directly answer this specific question. The principle in Article 7 of the Convention ("the same treatment as is accorded to aliens generally") offers one avenue of interpretation, but how a stateless applicant would in practice be classified within TAKBİS's country-based restriction logic appears to depend on the concrete practice of the relevant land registry directorate and TKGM's central administration. We would therefore strongly recommend that this point be confirmed in writing with the relevant authority before any concrete application is made.

4. Other Points That Remain Unsettled in Practice

The analysis above is a legal assessment drawn from a combined reading of the currently applicable provisions; it does not constitute a guaranteed outcome. In addition, the following points remain matters to be confirmed before a concrete application is filed:

• The President's final discretion. The phrase in Article 12(1) of Law No. 5901 — "may acquire Turkish citizenship by decision of the President" — is understood in legal doctrine and administrative practice as conferring discretionary authority on the President (see DÜLGER, Ahmet, "Obtaining the Valuation Report and the Compliance Certificate in the Exceptional Acquisition of Turkish Citizenship Through Real Estate Purchase," İnönü University Law Faculty Journal, Vol. 16, No. 1, 2025, p. 178). Full satisfaction of the investment requirement does not, by itself, confer an absolute right to citizenship; whether an impediment exists on grounds of national security or public order is assessed separately, on the basis of an archive investigation conducted by the National Intelligence Organisation and the General Directorate of Security.

• The specific procedure for the citizenship file. The final assessment of the citizenship file is conducted by the Directorate General of Civil Registration and Citizenship Affairs and the Ministry of Interior. We were unable to find, among the sources reviewed, any provision distinct from the general rules governing the security review and documentary procedure applied to stateless applicants at this stage.

• The nature of the qualifying property. As of 12 December 2023, real estate acquired for this purpose must either be registered as an independent unit under Law No. 634 on Condominium Ownership, or, if it is a building plot, must bear a permanent structure holding a valid occupancy permit. This requirement applies to every applicant regardless of statelessness and must be taken into account separately when selecting the property.

• The requirement of personal acquisition. The Regulation covers only real estate acquired personally by the foreign natural person; acquisitions made in the name of a spouse, a child, or a corporate entity are not taken into account in calculating the required threshold.

5. General Outline of the Application Process

According to the Guide and the related circulars, the process consists, in summary, of the following stages:

1. The purchase price (of at least USD 400,000 or its foreign-currency equivalent) must be sold — by the buyer, seller, or their attorney or representative — to a bank for onward sale to the Central Bank of the Republic of Turkey, with the resulting foreign-currency purchase certificate submitted to the relevant land registry directorate;

2. Confirmation, through a valuation report issued by an authorised valuation institution (GEDAŞ), that the property satisfies the qualifying-nature requirements (condominium ownership/floor easement, or a building plot with an occupancy permit) and the required value;

3. Entry in the land registry of the three-year non-sale annotation;

4. Following confirmation of these conditions by the relevant Regional Directorate/Directorate General, issuance by the Ministry of Environment, Urbanisation and Climate Change of a Real Estate Investment Determination Certificate (Taşınmaz Yatırımı Tespit Belgesi, "TYTB");

5. On the basis of the TYTB, transmission of the application, through the relevant governorship, to the Directorate General of Civil Registration and Citizenship Affairs, with the final decision issued by decision of the President.

The Guide itself describes the name and function of this certificate as follows: "Applications for the exceptional acquisition of Turkish citizenship based on real estate acquisition are subject to determination by our Directorate General in accordance with the applicable legislation, and a 'Real Estate Investment Determination Certificate (TYTB)' shall be issued in this respect. The acquisition of citizenship on the basis of this certificate is subject to the assessment and decision of the competent Authority."

6. Conclusion

Read together, the definition of "foreigner" in Law No. 5901 and Law No. 6458, and Article 15(a) of the Implementing Regulation (which expressly contemplates statelessness), lead us to the view that stateless persons fall within the definition of "foreigner" for purposes of exceptional citizenship acquisition through real estate investment. Article 7 of the Convention Relating to the Status of Stateless Persons, together with the 10 June 2015 opinion letter demonstrating that TKGM has actually applied this provision (in the context of inheritance), provides supportive grounds for the view that stateless persons' acquisition of real estate is subject to the general foreign-acquisition regime.

Before any concrete application is made, we strongly recommend confirming these three points, (i) how the "country list" mechanism within the general foreign-acquisition regime is to be applied to a stateless applicant; (ii) how the Stateless Person Identity Document is, in practice, accepted for identity verification in land registry transactions; and (iii) whether any procedure specific to stateless applicants exists within the citizenship file review conducted by the Directorate General of Civil Registration and Citizenship Affairs and the Ministry of Interior, and carrying out the process from the outset with the support of a qualified lawyer. This article is intended for general informational purposes only; independent legal advice should be obtained for any specific application.

References

1. Law No. 5901 on Turkish Citizenship (adopted 29 May 2009; Official Gazette of 12 June 2009, No. 27256), Articles 3, 10, 11, 12.

2. Regulation on the Implementation of the Turkish Citizenship Law (Council of Ministers Decision of 11 February 2010, No. 2010/139; Official Gazette of 6 April 2010, No. 27544), Articles 3, 15, 16, 20 — as currently in force as of 2026.

3. Presidential Decree No. 5072 (Official Gazette of 6 January 2022, No. 31711) — one of the instruments underlying the current text.

4. Presidential Decree No. 5554 (Official Gazette of 13 May 2022, No. 31834) — basis for the USD 400,000 threshold, currently in force.

5. Presidential Decree No. 7938 (Official Gazette of 12 December 2023, No. 32397) — basis for the current requirement as to the nature of the qualifying property, currently in force.

6. General Directorate of Land Registry and Cadastre, "Guide on the Implementation of the Regulation on the Turkish Citizenship Law," 9 December 2024.

7. Law No. 6458 on Foreigners and International Protection (adopted 4 April 2013; Official Gazette of 11 April 2013, No. 28615), Articles 3, 50, 51.

8. Law No. 2644 on Land Registry (dated 22 December 1934; Article 35 as amended by Law No. 6302 of 3 May 2012), Article 35.

9. General Directorate of Land Registry and Cadastre, Directorate of Foreign Affairs, Circular No. 2012/12 (1734) of 6 August 2012.

10. General Directorate of Land Registry and Cadastre, Directorate of Foreign Affairs, Circular No. 2013/13 (1750) of 16 September 2013, "Identity Verification in Land Registry Transactions Involving Foreigners."

11. General Directorate of Land Registry and Cadastre, Directorate of Foreign Affairs, Opinion Letter No. 36189470-010.07.01[125.01.04]/503519 of 10 June 2015, "Acquisition of Real Estate by Stateless Persons Through Inheritance"

12. Convention Relating to the Status of Stateless Persons (New York, 28 September 1954), acceded to by Turkey under Law No. 6549 of 1 July 2014.

13. DÜLGER, Ahmet: "Obtaining the Valuation Report and the Compliance Certificate in the Exceptional Acquisition of Turkish Citizenship Through Real Estate Purchase," İnönü University Law Faculty Journal, Vol. 16, No. 1, 2025, pp. 167-180.

This article has been prepared for general informational purposes. For specific applications, confirmation should be sought from the current legislation and from the official records of the General Directorate of Land Registry and Cadastre and the General Directorate of Population and Citizenship Affairs.

Note: The quoted provisions of Turkish legislation reproduced below have been translated into English for the purposes of this article. They are unofficial translations provided for informational purposes; the Turkish originals remain the authoritative texts.