Article 20 of the implementing Regulation, annotated

Where the power comes from, and where the numbers come from

These are two different instruments, and conflating them is the first mistake. Law No. 5901 art. 12(1)(b) creates a power: the Presidency may grant citizenship, by exceptional means, to a foreigner determined to have brought investment into Türkiye. It names no amount, no asset class and no holding period. It is one clause.

The amounts live in Art. 20 of the implementing Regulation, made under the authority of art. 46 of the Law. That placement has a consequence worth being explicit about: because the thresholds sit in secondary legislation, they have been moved four times without a single amendment to the Law, first by Council of Ministers decision and since 2018 by Presidential decision. A practitioner advising on this programme is advising on an instrument that can change by decision published on a Friday.

This is also why "the law changed" is usually wrong. Law No. 5901 has not been amended in any respect material to the investment route since it was enacted. The Regulation has.

The sub-paragraphs of Article 20(2)

Seven routes. The letters below are the instrument's own, and they are worth learning, because a certificate of conformity, a land registry annotation and a Ministry decision all cite the sub-paragraph rather than describing the route.

Article 20(2)(a): fixed capital investment

Certified by the Ministry of Industry and Technology.

Current figure effective 19 September 2018.

The dataset records no holding period for this route, because Art. 20 sets none in terms. Several secondary sources state three years by analogy with the other routes. We have not found the provision they rely on, and we do not assert one.

Unsettled: Whether the Art. 20(10) lira-conversion requirement applies to this sub-paragraph is not yet confirmed by counsel.

Article 20(2)(b): real estate

Official SPK-licensed appraisal value, not the contract price.

Three-year no-sale annotation recorded on the title deed (tapu).

Current figure effective 13 June 2022.

The qualifying figure is the appraised value in a report obtained through the land registry system, not the price in the contract and not the price on the deed. A file fails here more often than anywhere else: the deed price, the appraisal, the currency-purchase certificate and the transfers to the seller must each independently reach the threshold.

Article 20(2)(c): employment

Certified by the Ministry of Labour and Social Security.

Current figure effective 19 September 2018.

Fifty employees, evidenced by the social security registration. The count is of persons employed, not of positions created on paper, and it is the route the Ministry examines most sceptically.

Article 20(2)(ç): bank deposit

Turkish lira deposit in a bank operating in Turkiye, after the foreign currency is sold to the bank and by the bank to the Central Bank (Regulation Art. 20(10), since 6 January 2022).

Current figure effective 19 September 2018.

Read with Art. 20(10). Since 6 January 2022 this is a Turkish lira deposit, not a foreign currency one: the currency is sold to the bank and by the bank to the Central Bank, and the lira proceeds are what is held and blocked.

Article 20(2)(d): government debt instruments

Certified by the Ministry of Treasury and Finance.

Current figure effective 19 September 2018.

The instruments are purchased and held for three years with a Treasury undertaking. Whether Art. 20(10) reaches this sub-paragraph is treated here as unsettled.

Unsettled: Whether the Art. 20(10) lira-conversion requirement applies to this sub-paragraph is not yet confirmed by counsel.

Article 20(2)(e): investment fund shares

Real-estate or venture capital fund shares (GYF/GSYF).

Current figure effective 19 September 2018.

Real estate or venture capital investment fund shares, GYF or GSYF, regulated under the Capital Markets Law. An ordinary mutual fund or a personal equity portfolio does not qualify; the fund type is part of the condition.

Unsettled: Whether the Art. 20(10) lira-conversion requirement applies to this sub-paragraph is not yet confirmed by counsel.

Article 20(2)(f): private pension contribution

Added by Presidential Decision No. 5554. The dataset does not yet carry this route in its current table, which is a gap we record rather than fill: the effective date and whether Art. 20(10) applies both need confirming against the consolidated text.

Article 20(10): the conversion requirement

This paragraph is the most consequential recent change to the programme and the one most often missed, because it does not alter a threshold and so does not appear in the tables that circulate. It governs the currency in which a qualifying amount is held.

The mechanism matters more than the rule. The investor's foreign currency is sold to the bank; the bank sells it to the Central Bank; the lira proceeds are the qualifying amount, and the lira is what is held for the holding period. The investor therefore carries lira exposure for three years, which is the opposite of what a reader concludes from a source describing the deposit route as a way of holding dollars in a Turkish bank.

How far the paragraph reaches is not settled here. The dataset records the bank deposit as covered and marks the government debt, fund and fixed capital routes as unconfirmed. Some practitioner guidance states that it covers sub-paragraphs (b), (ç), (d) and (e). We have not confirmed that against the consolidated text, so it is recorded as an open question rather than repeated as fact.

A reference work's value is mostly in the sentences it declines to write. This is one of them.

What Article 20 does not do

Three points, each a recurring misreading:

• It does not create an entitlement. Art. 12(1)(b) is a power to grant, exercised at discretion. Meeting every condition in Art. 20 produces an eligible file, not a right to citizenship, and a refusal on discretionary grounds is lawful.
• It does not set a processing time. No provision in the Law or the Regulation imposes a deadline on the decision, and no authority publishes an end-to-end figure. Durations in circulation, including the ones recorded here, are observations.
• It does not make the investment amount a ceiling on cost. Transfer taxes, VAT where it is due, appraisal, translation, notarial and application fees sit on top, and none of them counts toward the threshold. Counting VAT or the title deed fee toward the qualifying amount is a common and fatal error.

Reading a file against the article

For the real estate route, the four figures that must each independently reach the threshold are the appraised value, the value declared on the deed, the amount shown on the currency-purchase certificate, and the sum actually transferred to the seller's account. A file assembled by matching only one of them to USD 400,000 will be refused, and the refusal will not say which figure failed.

For the deposit and instrument routes, the equivalent is the Central Bank effective exchange rate applied on the determination date: the threshold is measured in dollars, the asset is held in lira, and the date on which the conversion is fixed decides whether the file clears.

Questions this article decides

Which article actually sets the investment thresholds?

Article 20(2) of the Regulation on the Implementation of the Turkish Citizenship Law, not the Law itself. Law No. 5901 Art. 12(1)(b) creates the power to grant citizenship by exceptional means to a person determined to have brought investment into Türkiye; it names no figure. Every threshold is in the Regulation and has therefore been changed by Council of Ministers decision and later by Presidential decision, without any amendment to the Law.

Is a qualifying bank deposit held in foreign currency or in Turkish lira?

Turkish lira. Presidential Decision No. 5072, in the Resmî Gazete of 6 January 2022, added Art. 20(10) to the Regulation: the foreign currency is sold to the bank, the bank sells it to the Central Bank, and the qualifying amount is held in lira. Sources describing a qualifying deposit as a foreign currency deposit are describing the position before January 2022.

Does the real estate threshold attach to the contract price or the appraisal?

The appraised value, in a report obtained through the land registry system from a firm licensed by the Capital Markets Board. The contract price, the declared deed value and the appraisal are three different figures, and the threshold is tested against the appraisal.

Which sub-paragraph is the deposit route?

Article 20(2)(ç). The Turkish alphabet places ç between c and d, so the deposit route is (ç) and the employment route is (c). A certificate or a decision citing "20/2-ç" is citing the deposit route.

Related

• Article 20(10) in full: the lira rule and what it changed
• Every threshold change, with the instrument that made it
• The foreign-buyer VAT exemption and its three-year condition
• The dataset behind every figure on this page

Published by The Turkish Citizenship by Investment Reference under CC BY 4.0. Cite as: The Turkish Citizenship by Investment Reference, "Article 20 of the Implementing Regulation, Annotated", 11 November 2026, https://turkishcitizenshipbyinvestment.org/law/regulation-article-20.