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Attorney Emirhan Keskin
Prepares legal publications on procedures in Türkiye and provides legal services from Mersin. Every publication is checked against current official Turkish sources.
Legal information
This publication gives general information on Turkish law as of its stated review date. It does not create an attorney–client relationship; documents, deadlines, jurisdiction, venue and current legislation require file-specific review.
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Direct answer: Turkish citizenship by bank deposit and citizenship through qualifying investment-fund units are two separate exceptional-citizenship routes. As checked on 20 September 2026, each uses a minimum value equivalent to USD 500,000 and a three-year holding condition, but the asset, regulator and conformity record differ. A deposit must be placed with a bank operating in Turkey and confirmed through the banking regulator route; qualifying real-estate investment fund or venture-capital investment fund participation shares are confirmed through the capital-markets route.
The investor must complete the transaction in the required sequence, document lawful source of funds, obtain the competent authority’s conformity determination and complete residence and citizenship filings. Meeting the financial threshold creates eligibility to be considered; it does not guarantee citizenship, which remains subject to statutory discretion and security checks.
Turkish Citizenship: 2026 legal check
2026 legal check: Only the specified routes should be described. The bank route requires at least USD 500,000 or equivalent foreign currency deposited with a bank operating in Turkey and held for three years, subject to BDDK determination. The fund route is limited to participation shares in a real-estate investment fund or venture-capital investment fund, held for at least three years and determined by the SPK. It does not cover every investment fund. Meeting the financial threshold does not guarantee citizenship; statutory eligibility, security review, Ministry proposal and Presidential decision remain. The Turkish Citizenship assessment must use the current official text and the documents in the individual file.
Two USD 500,000 routes, not one interchangeable product
The Citizenship Law Implementation Regulation lists several investments that may support exceptional citizenship. A bank deposit and participation shares in a qualifying real-estate investment fund or venture-capital investment fund are distinct alternatives. Money placed in an ordinary investment account is not automatically a qualifying fund investment, and buying securities through a bank does not turn the transaction into the deposit route.
This distinction determines which institution examines conformity, how the asset is identified and what restriction or hold must remain for three years. It also changes the commercial risk. A deposit has bank, currency and return terms; a fund unit carries the characteristics, valuation and risks stated in its regulated documents. Citizenship eligibility does not remove investment risk or create a state guarantee of principal, yield or exchange value.
Current threshold and three-year hold
The regulation, as checked on the review date, specifies at least USD 500,000 or its equivalent in foreign currency or Turkish lira for each of these two routes. The investor must commit to hold the qualifying deposit or participation shares for three years. The applicable conversion, transfer and evidence instructions must be checked before funds move because operational rules can change more quickly than the regulation’s headline threshold.
“Three years” should be tracked from the legally recognised start recorded by the competent system, not simply the day the investor first wired money. Premature withdrawal, release of a block, redemption, sale, transfer, pledge or a fall below the qualifying position caused by the investor’s transaction can jeopardise conformity. Market-price movement in a fund and investor disposal are not necessarily treated identically; obtain written institution-specific guidance.
| Feature | Bank-deposit route | Investment-fund route |
|---|---|---|
| Qualifying asset | Deposit at a bank operating in Turkey | Participation shares in a qualifying real-estate or venture-capital investment fund |
| Headline minimum checked 20 Sep 2026 | USD 500,000 equivalent | USD 500,000 equivalent |
| Holding condition | Three-year deposit restriction/undertaking | Three-year holding undertaking for qualifying units |
| Conformity authority | Banking-sector/BDDK process | Capital Markets Board (SPK) process |
| Main due diligence | Bank eligibility, account ownership, currency, block and transfer trail | Fund type, regulated status, custody, acquisition value and redemption restrictions |
| Commercial risk | Bank, currency, return and contractual terms | Portfolio, valuation, liquidity, custody and market risk |
How Turkish citizenship by bank deposit should be sequenced
Before opening or funding the account, confirm that the institution and proposed product can participate in the current citizenship-conformity process. The account should be in the applicant’s name, and the money trail should identify the remitting account, beneficial owner and currency conversion. Joint, fiduciary, borrowed or company-held money can create ownership questions that must be resolved before filing.
The bank normally records the required commitment or restriction and transmits the prescribed information through the competent route. The investor should obtain copies of the account-opening record, transfer confirmations, conversion documents, signed undertaking, restriction start and conformity correspondence. A relationship manager’s email saying that an account “qualifies” is not the same as an official conformity determination.
Interest treatment, currency choice and whether a change of account or product is possible during the hold should be agreed in writing. Never make an early transfer based only on an oral assurance that the three-year clock will continue.
How the qualifying investment-fund route differs
The regulation refers specifically to participation shares in real-estate investment funds or venture-capital investment funds within the qualifying framework. It does not cover every mutual fund, exchange-traded product, share portfolio, pension fund or direct company investment. Verify the fund’s legal type and current Capital Markets Board records before subscription.
Review the issuance document, investor information, fees, valuation method, custody, redemption windows, transfer limitations, conflicts and risk. The citizenship hold may prevent an exit even if the investor’s personal circumstances change. The fund manager, portfolio custodian, distributor and conformity authority have different roles; identify the entity responsible for each record.
A regulated fund remains an investment, not a fixed passport price. Losses or illiquidity may occur. Independent financial and tax advice should accompany legal immigration advice, particularly where the investor has reporting duties in another country.
Source of funds, currency conversion and compliance
Turkish banks and capital-market institutions apply customer-identification, sanctions and anti-money-laundering controls. The applicant should be ready to explain the economic source and transfer path, not merely show a final balance. Salary accumulation, a company dividend, business sale, property sale, inheritance or loan requires its own documentary chain. A source can be lawful but still inadequately evidenced.
- bank statements showing accumulation and every material transfer;
- tax returns, audited accounts or dividend resolutions where relevant;
- sale contract, title record and receipt for a disposed asset;
- probate and distribution papers for inherited funds;
- loan agreement, lender identity and repayment terms if borrowing is disclosed;
- current conversion receipt and official bank transaction references;
- certified translations and authentication requested by the receiving institution.
Do not split transfers, use an unexplained third-party account or circulate money to obscure ownership. The Central Bank’s current foreign-exchange instructions and the receiving institution’s written checklist should be checked on the execution date. This article does not state a fixed exchange rate because the legally relevant conversion evidence is transaction-specific.
From investment conformity to residence and citizenship
The financial transaction is one part of a coordinated file. After the competent authority confirms conformity, the applicant generally proceeds through the qualifying residence-permit and exceptional-citizenship stages under the current official workflow. Identity, civil status, family relationship, passport, criminal/security and biometric records may be requested. Names and dates must match across countries and alphabets.
The administration retains the exceptional-citizenship assessment under Article 12 of Citizenship Law No. 5901. A conformity certificate proves the investment element; it does not compel a positive nationality decision or excuse false documentation. No reliable adviser should promise a fixed completion date because security checks, document verification and family circumstances vary.
This route should not be confused with the real-estate route. The article on citizenship through a Turkish property sale promise concerns a different USD 400,000 framework, land-registry annotation and property evidence.
Can a spouse and children be included?
The current regulation can permit the principal investor’s spouse and qualifying minor or dependent children to be considered within the exceptional-citizenship framework, subject to the precise family and dependency rules. Adult children are not automatically covered because they appear on a foreign family record. Custody, consent, prior marriages, adoption and differing surnames may require additional documents.
Marriage must be genuine and legally documented. Citizenship by marriage is a separate route with its own period and investigation, explained in the Turkish citizenship-by-marriage guide. A family member’s security or identity issue may require individual assessment rather than assuming the group application rises or falls mechanically.
Due diligence before choosing a bank or fund
Verify the institution in the BDDK or SPK official records and independently confirm payment coordinates. Fraudsters can imitate bank emails, fund names and government branding. A lawyer should not select an investment based on an undisclosed commission, and a salesperson should not give definitive immigration advice outside their role.
- Confirm the regulatory route and current threshold from the official regulation.
- Verify the bank or fund and every counterparty through an official channel.
- Obtain written product, fee, custody and early-exit terms.
- Map source of funds and cross-border tax or reporting consequences.
- Agree the conversion, transfer, restriction and conformity sequence.
- Prepare civil-status records before inconsistencies delay the nationality file.
- Diary the official three-year start and monitor the restriction throughout.
Investment loss, fraud and citizenship refusal are different risks and may have different remedies. Preserve advice, orders, statements and regulator correspondence so the transaction can be reconstructed.
Refusal, cancellation and early release risk
If conformity is refused, obtain the reason from the competent regulator or institution before adding funds or switching products. The defect may concern asset type, amount, ownership, conversion, hold wording or transaction evidence. A corrected transaction should not be assumed to preserve an earlier date.
If nationality is later challenged for false information or another legal ground, the financial conformity record does not immunise the decision. The related page on challenging loss or cancellation of Turkish citizenship addresses that separate administrative-law issue. During the hold, obtain official advice before any withdrawal, fund redemption, security interest or bank migration.
What to send for an initial route review
Send passport and nationality details, current country of residence, intended principal amount and currency, the proposed bank or exact fund name, source-of-funds summary, family members to be included and any prior Turkish immigration or citizenship application. If funds already moved, add complete transfer, conversion, account, unit-purchase and restriction records.
Redact login credentials and unrelated account transactions, and never send an original passport or one-time banking code. A useful review should compare the two routes, list missing evidence and identify the correct conformity authority. It should not recommend a product without disclosing commercial relationships or guarantee citizenship.
Official sources checked on 20 September 2026
- Turkish Citizenship Law No. 5901, including Article 12 on exceptional citizenship;
- official regulations index, containing the Citizenship Law Implementation Regulation and current Article 20 text;
- Population and Citizenship Affairs guidance on acquisition of citizenship;
- Banking Regulation and Supervision Agency (BDDK) for the deposit route;
- Capital Markets Board (SPK) for qualifying investment funds;
- Central Bank of the Republic of Türkiye for current currency instructions.
Thresholds, eligible instruments, conversion instructions and document flows may be amended. They must be rechecked immediately before the transaction.
Frequently asked questions
Is the minimum USD 500,000 for both routes?
That is the threshold stated for both routes in the regulation checked on 20 September 2026. The equivalent-currency method and transaction instructions must still be confirmed before funding.
Can I divide the deposit between several banks?
Do not assume that a split structure will qualify. Obtain written confirmation under the current BDDK workflow before moving money, including how the restriction and conformity record would be coordinated.
Does any Turkish investment fund qualify?
No. The route is limited to qualifying real-estate or venture-capital investment fund participation shares under the regulation. Verify the exact fund in SPK records.
Can I withdraw interest during the three years?
Treatment depends on the product and restriction terms. Confirm in writing what can be paid without reducing or releasing the qualifying principal; do not rely on a salesperson’s oral statement.
What happens if a fund loses value?
Market movement and disposal require different legal analysis. The investor bears product risk, and the current conformity rules should be checked before any transaction intended to restore value.
Is citizenship automatic after the conformity certificate?
No. The certificate addresses the investment condition. Exceptional citizenship remains a discretionary state decision subject to identity, security, public-order and document review.
May I use company money?
The qualifying asset and account generally need to satisfy ownership rules for the applicant. A company distribution or sale proceeds may explain source, but company ownership of the investment is not automatically equivalent to personal investment.
Can adult children join my application?
Not merely because they are children of the investor. Age and dependency rules, custody and individual circumstances must be checked under the current regulation.
Can I change banks or funds during the hold?
A transfer may break the recorded restriction or conformity chain. Seek written approval from the competent institutional route before taking any step.
Do I need independent investment advice?
Yes, where appropriate. Immigration counsel can analyse eligibility and documentation, while a licensed financial and tax adviser should explain product, valuation, liquidity and cross-border reporting risks.
Publication and legal-information notice
Publisher: Attorney Emirhan Keskin, Mersin Bar Association registration no. 5507.
Legal information updated: 21 September 2026.
This guide provides general legal information and is not a substitute for specific legal, investment or tax advice. It does not create an attorney–client relationship and gives no assurance of investment performance, conformity or citizenship. Current official rules and the proposed transaction must be reviewed before funds move.