Türkiye Updates Citizenship Property Valuation Rules

Approvals dated 28 September 2026 update the TKGM circular framework and rules for property acquisitions used in Turkish citizenship applications. The most practical changes are a wider choice of eligible valuation firms, a longer period between the Amount Determination Document and the citizenship application, and a dedicated review route for sales by real estate investment trusts. The USD 400,000 investment threshold remains unchanged, but purchasers should reassess valuation, payment, and transaction sequencing before completion.

Which valuation firms may prepare citizenship reports?

Citizenship valuation reports are no longer limited to a single provider. A report may now be prepared by a firm that is licensed by the Capital Markets Board, has active TDUB membership, and is registered on TADEBİS. The firm is selected through Web Tapu.

This change gives buyers greater practical choice, but eligibility should be checked carefully before an instruction is placed. A report from a firm that does not satisfy each of the required conditions may create delay or uncertainty at the eligibility-certificate stage.

For a citizenship-driven acquisition, the valuation work should be coordinated with the title deed timetable, the agreed sale price, and the transfer of funds. The valuation report is only one component of a compliant transaction record; it should not be treated as a substitute for broader property and transaction due diligence.

How long is the Amount Determination Document valid?

The period between the Amount Determination Document, commonly referred to as the TTB, and the citizenship application has increased from six months to twelve months. This can give applicants more flexibility in arranging the later stages of their file.

That additional time should not be assumed to cure deficiencies in the underlying purchase. The transaction documents, valuation evidence, title deed records, and payment trail should remain consistent and available when the application is prepared. Buyers should also plan around the practical timing of any mortgage release, annotation, handover condition, or other closing item.

What is the new route for purchases from a GYO?

The exemption from TTB confirmation for transactions involving a real estate investment trust, known as a GYO, remains in place. However, sales and promise-to-sell agreements involving foreigners who intend to seek citizenship are now subject to a more specific valuation procedure.

The GYO must provide either a valuation report prepared before the title deed transaction and published on KAP, or a new valuation report obtained through Web Tapu. Where the buyer relies on a KAP-published report, the matter is referred to the Foreign Affairs Department during review of the eligibility certificate.

This pathway may affect transaction planning, particularly where a purchase is already underway or a promise-to-sell agreement has been signed. The existence of a published report does not remove the need to assess whether it is suitable for the particular transaction and citizenship file. Buyers should confirm the proposed route, documentation sequence, and review implications before funds are committed.

Does the USD 400,000 threshold change?

No. The USD 400,000 threshold remains unchanged. For citizenship purposes, the sale price, the appraised value, and the relevant fund transfers must each independently satisfy that amount.

Accordingly, a transaction should be tested on three separate tracks rather than by reference to a single headline price:

• The contractual and title deed sale price.
• The appraised value shown in the citizenship valuation report.
• The documented transfer of purchase funds.
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A shortfall or inconsistency in any one track can place the citizenship strategy at risk. Currency conversion, payment routing, deposits, instalments, seller-side refunds, and the relationship between any separate furnishings or service arrangements and the property price should be reviewed with particular care.

What should ongoing purchasers do now?

The amendments do not include a transitional provision in the information currently available, and the Implementation Guide has not yet been published. Pending further operational clarification, active files should be evaluated individually rather than assumed to follow the prior practice.

Priority review points include the selected valuation firm’s current eligibility, the TTB timeline, the adequacy of the valuation and payment record, and whether the seller is a GYO. For GYO transactions, the availability and timing of a KAP-published valuation report, or the need for a Web Tapu report, should be addressed before title deed completion or reliance on a promise-to-sell structure.

For citizenship-linked property purchases, the safest approach is to align the valuation, banking, contract, title deed, and application records from the outset rather than attempting to reconcile them after closing.

 

These changes make early coordination more valuable, not less. A focused legal review before signing, paying, or submitting the citizenship file can identify whether the proposed structure is aligned with the revised framework and any further implementation guidance that may follow. Readers considering a wider transaction review may also find our practical guide to Turkish citizenship by investment and our article on property ownership due diligence for foreign buyers in Türkiye helpful.