Turkey's Social Security Agreements for Foreign Employers and Expatriates: Which Countries Have One, What the UK, German and Canadian Texts Say About Posted Staff, the Three-Month Rule for Everyone Else, and How Pensions Are Totalised

A foreign company that sends an employee to Turkey pays Turkish social security from the first day of work unless a treaty says otherwise, and whether a treaty says otherwise depends on the passport of the employer's country, not of the employee. Turkey has bilateral social security agreements with thirty-seven states and territories on the Social Security Institution's list, including the United Kingdom since 1961, Germany since 1965 and Canada since 2005, and none with the United States, Australia, Israel, the Gulf states or the Baltic republics. In my files the consequences are concrete: a German engineering firm keeps its site staff under German insurance for the whole of a two-year project on a certificate, a Canadian firm does the same for twenty-four months and can extend to sixty, a British firm's manager stays under National Insurance for as long as the posting is temporary, and an American company pays twice from the fourth month because the exemption in Turkish law runs out at three. This page sets out the Turkish default rule, the list, what the three texts most often in front of me actually say, the position of the countries without an agreement, and how the pension years are added together at the end.

Sources, checked 9 September 2026. Social Insurance and General Health Insurance Law No. 5510, Articles 4, 6(1)(e) and 60(1)(d); the Social Security Institution's list of social security agreements (page dated 6 January 2026); the Convention on Social Insurance between the United Kingdom and Turkey of 9 September 1959 (Statutory Instrument 1961 No. 584), Articles 2, 3, 4, 7, 14 and 17; the Agreement between the Federal Republic of Germany and Turkey on Social Security of 30 April 1964 as amended by the supplementary agreement of 2 November 1984, Articles 5, 6, 8, 9, 38 and 56, and the German liaison body's guidance on postings to Turkey; the Agreement on Social Security between Canada and Turkey of 19 June 1998 (SI/2004-164), Articles II, V, VI, VIII, XI and XII; the United States Social Security Administration's programme manual list of totalization agreements; the Bundestag research service note WD 6-007/25 of 2025.

The default: Turkish insurance attaches to work in Turkey

Article 4(1)(a) of Law 5510 insures everyone employed under a service contract by one or more employers, without any reference to nationality, and the employer registers the workplace and the employee and pays the contributions described on the employment law page. The single domestic exception for posted staff is Article 6(1)(e): a person sent to Turkey by an establishment set up in a foreign country, in that establishment's name and for its account, for a job not exceeding three months, who documents that he or she is subject to social insurance in the foreign country, is not treated as insured, and the same applies to a self-employed person resident abroad and covered by that country's scheme. The article opens with the words "without prejudice to the provisions of international social security agreements", which is the door through which the treaties enter. A posting from a country with no agreement is therefore free of Turkish contributions for three months and insured in Turkey after that, whatever the home country continues to charge. Health insurance follows a separate track: under Article 60(1)(d) a foreign national with a residence permit who is not insured under a foreign scheme is within general health insurance on a reciprocal basis.

Who has an agreement: the Institution's list

The full list of thirty-seven entries adds Libya, Northern Cyprus, North Macedonia, Albania, Azerbaijan, Georgia, Romania, Bosnia and Herzegovina, Czechia, Luxembourg, Croatia, Slovakia, Serbia, Montenegro, Tunisia, Hungary, Moldova, Kyrgyzstan, Mongolia and Iran, and covers Spain and Portugal through the European Convention on Social Security applied since 1977. What is not on it decides many of my files: the United States, Australia, New Zealand, Ireland, Israel, the United Arab Emirates and the other Gulf states, and Estonia, Latvia and Lithuania have no agreement with Turkey, and neither do Greece or Finland. Where a partner appears with "No" under health, the posted employee keeps home pension and accident coverage but needs private or home-country health cover in Turkey, or general health insurance under Article 60.

United Kingdom: the 1959 convention, still in force

The convention was made on 9 September 1959 and given effect by the National Insurance and Industrial Injuries (Turkey) Order 1961. Article 2 ties it to the National Insurance Acts and the industrial injuries legislation on the British side and to the insurance laws of the time on the Turkish side, and the Institution lists it as in force for long-term and short-term insurance with a revision of 20 December 1999, not for health and not for unemployment. Article 3 gives each state's nationals equal treatment under the other's legislation.

The coverage rule is Article 4. Paragraph 1 applies the legislation of the state where the work is done, even if the employee is ordinarily resident in the other state and the employer is there. Paragraph 2 is the posting rule: a person in the service of an employer whose principal place of business is in one state, sent in the course of that employment to work temporarily in the other, and who is not a national of that other state nor ordinarily resident there, stays under the legislation of the sending state as if employed there, and the legislation of the host state does not apply. The text sets no number of months; "temporarily" is the only limit, and the British certificate of coverage, issued by HM Revenue and Customs, is what the Turkish employer files; HMRC's guidance on social security abroad still lists Turkey among the reciprocal agreement countries. Paragraph 3 goes further for one group: a United Kingdom national ordinarily resident in the United Kingdom who is employed in Turkey outside a posting is not subject to Turkish invalidity, old-age and survivors' insurance unless he or she chooses to be, and may choose instead to remain under United Kingdom legislation as a voluntary contributor from abroad. Article 7 keeps cash sickness, maternity and industrial injury benefits payable for a posted person, and Articles 14 and 17 deal with pensions: each state assesses entitlement taking account of insurance periods completed under the other's legislation, and an old-age pension due under one state's law is paid while the pensioner is in the other's territory. The wider British position on property and pensions is on the UK treaty page.

Germany: the 1964 agreement and its open-ended posting

The German agreement of 30 April 1964 entered into force on 1 November 1965 and was amended in 1969, 1974 and by the supplementary agreement of 2 November 1984, in force since 1 April 1987; the Institution lists it as covering health, long-term and short-term insurance. Article 5 applies the legislation of the state of employment even where the employer is established in the other state. Article 6(1) then provides that an employee of an undertaking with its seat in one state who is temporarily sent to the other to perform work for that undertaking remains under the first state's legislation for the duration of the employment in the second state, as if employed at the undertaking's seat, and Article 6(4) applies this regardless of the employee's nationality. Unlike most German agreements the text sets no maximum period. The German liaison body's guidance adds the practical limits: the posting must be limited in time in advance, a new posting is recognised only after a gap of more than two months, and proof of continued German coverage is the certificate T/A 1, applied for electronically from the health insurance fund that collects the pension contributions or from the liaison body itself. Article 8 keeps public employees under their own state's law with a right to opt for the host law within three months, and Article 9 allows the competent authorities, on a joint application by employer and employee, to exempt a person from the legislation that would otherwise apply and place him or her under the other state's law, having regard to the nature and circumstances of the employment. On the pension side Article 38 converts Turkish contribution days into German insurance months, with a ceiling of twelve months for any calendar year, and the Bundestag's research service recorded in 2025 that the agreement also extends accident insurance to postings and gives posted staff and their families benefits in kind in the host state through the local institution. Article 56 makes the final protocol part of the agreement. German staff sent to a Turkish site still need the work permits on the work permit page; the certificate settles contributions, not immigration.

Canada: the 1998 agreement with a sixty-month ceiling

The Canadian agreement was signed at Ankara on 19 June 1998 and entered into force on 1 January 2005, with a separate understanding for Quebec in force the same day. Article II applies it, on the Canadian side, to the Old Age Security Act and the Canada Pension Plan, and on the Turkish side to the schemes for industrial accidents, occupational diseases, invalidity, old age and survivors; the Institution lists it as covering long-term and short-term insurance and not health. Article VI(1) applies the law of the state where the work is done, and for a self-employed person the law of the state of ordinary residence. Article VI(2) is the posting rule: an employee subject to the legislation of one state who performs services in the other for a period not expected to exceed twenty-four months, for the same or a related employer, remains subject only to the first state's legislation, and with the prior consent of both competent authorities the twenty-four months may be extended to a total not exceeding sixty. Article V exports benefits without reduction to a resident of the other state and pays them in third states. Articles VIII to XII do the totalising: where a person lacks sufficient creditable periods under one state's law, periods under the other's are added, Turkish periods count as periods of residence in Canada for Old Age Security purposes, and Canada then pays a partial pension calculated on Canadian periods alone. The Canadian individual's tax position, and the fact that Australia has no such agreement, are on the Australians and Canadians page.

The United States, Australia and the other states without an agreement

The Social Security Administration's programme manual lists the thirty countries with which the United States has a totalization agreement, from Australia to Uruguay, and Turkey is not among them; nor does the United States appear on the Institution's list. Australia's absence is the same on the Turkish side. For an American or Australian employer the consequences follow from Article 6(1)(e) alone: a posting of up to three months with proof of home coverage is outside Turkish insurance, and from the fourth month the Turkish subsidiary or the Turkish workplace of the branch registers the employee and pays Turkish contributions while the home scheme continues to charge under its own rules. An American self-employed person working in Turkey is insured under Article 4(1)(b) of Law 5510 and remains liable to United States self-employment tax, with no certificate to present on either side. Years worked in Turkey and years worked at home are never added together for either country's pension, and each state pays only what its own record supports. The tax side of the American position is on the US treaty page; the choice between a branch and a subsidiary as the Turkish employer is on the branch and subsidiary page.

How the pension years are added together

The Institution describes the common mechanism of its agreements: where entitlement under one state's law depends on completing an insurance period, that state's institution treats periods completed under the other's law as if completed under its own, provided they do not overlap; where that still leaves the person short, periods in a third state with which both have agreements are added; where a benefit depends on service in a particular scheme or occupation, only comparable periods count; and where entitlement depends on being insured at the moment the risk occurs, being insured in the other state satisfies the condition. Each state then pays its share of the pension in proportion to the periods completed under its own law, and some agreements, the British one among them, allow the claimant to choose between the totalised pro-rata pension and a pension calculated under one state's law alone. The totalised pension does not need residence in the paying state: the export clauses in Article 17 of the British convention and Article V of the Canadian agreement pay it in the other state, and under the Canadian text in third states as well.

Six situations, in one table

Whose side we are on, and how we are paid

The payroll provider is paid per payslip whether or not a certificate would have removed the Turkish contributions. The relocation firm is paid on the move. The home-country adviser knows the home certificate and not the Turkish three-month rule. None of them is paid to tell you that the American posting became insurable in month four, or that the German certificate had to be issued before the engineer arrived.

We take no commission or referral fee from payroll providers, relocation firms or insurers, in any form, on any file. The fee you pay us is our only income from your matter, and it does not depend on how many staff you post or which structure you use. Because our position does not move with the headcount, telling you that a short posting needs no structure at all, or that a local hire is cheaper than a posting for a long assignment, costs us nothing to say.

One boundary, stated plainly. We are lawyers, not licensed investment advisers and not your home-country social security office. We do not tell you what your own scheme will charge or pay. What we protect is the Turkish legal position: whether Turkish insurance attaches, which agreement applies and what its text requires, the documents the Turkish employer must hold, and the pension record that the totalisation will later depend on.

Before you post the first employee

Send us the employer's country and the employee's nationality and residence, the planned duration and whether it may be extended, whether the employee will be on the Turkish company's payroll or remain on the foreign one, and the health cover in place. We will tell you whether Turkish insurance attaches and from when, which certificate or exemption applies and who issues it, what the Turkish company must register, and how the posting interacts with the work permit. Our corporate work is described on the corporate law page, and the company that will act as host or employer is set up under the rules on the company set-up page.

What this page does not settle

The detailed benefit chapters of each agreement, including healthcare in kind for family members, the other thirty-odd agreements not summarised above, unemployment insurance, the rules by which Turkish citizens abroad buy back foreign years, the coordination decision between Turkey and the European Union, and income tax on salaries and pensions are separate subjects. Agreements are revised and new ones enter into force; the list above is the Institution's on the date checked.