A scope note first. The general mechanics of the citizenship-by-investment route — the USD 400,000 threshold, the valuation report, the currency conversion, the application sequence — are covered in our Turkish citizenship by real estate guide and our note on the threshold itself. This page stays on one question those pages do not exhaust: who you are allowed to buy from.
It is the right question to isolate, because it is where prepared applications actually fail. A buyer can clear the threshold, commission the valuation, route the money correctly through the banks — and still be refused the real-estate investment determination certificate (Taşınmaz Yatırımı Tespit Belgesi, TYTB) because the person or company on the other side of the contract belongs to a disqualified category. The land registry's guidance on the implementation of the Citizenship Regulation, in its current version dated 9 December 2024, devotes a dedicated section to "conditions relating to the parties", and every item in it is a way for a seller to sink a buyer.
The structural economics of why the eligible pool prices the way it does are in our citizenship premium analysis. This page is the operational companion: the map of who is out, and how each exclusion is checked before money moves.
The disqualified sellers, mapped
Any foreign natural person. The property must not be registered in the land registry to foreign persons — full stop. Not "foreigners of your nationality", which is how an older version of the rule survives in secondhand advice: the current guidance excludes foreign-owned stock as such. The listing marketed internationally by a foreign owner is, for citizenship purposes, not inventory.
Anyone who naturalised through the same door. Property registered to a person who acquired Turkish citizenship exceptionally under Article 12(1)(b) of the Citizenship Law is excluded — whether they bought it before or after naturalising. The previous cohort of investor-citizens cannot supply the next one.
Your own family, in three configurations. The property must not be registered to the buyer's Turkish-citizen first-degree relatives — a category the guidance defines to include kinship by contract, blood and marriage. Second-hand property must not be property that the buyer themselves, or their first-degree relatives, previously transferred to a Turkish citizen or Turkish company — the round trip through a cooperative relative is closed in both directions. And the property must not be registered to a company in which the buyer or their first-degree relatives are partners or managers, which closes the same loop run through a corporate vehicle.
Recently recycled foreign stock. Second-hand property transferred to a Turkish citizen or Turkish company within the last three years by any foreign natural person, or by an Article 12(1)(b) citizen, is excluded. The wash cycle — foreigner sells to a Turkish intermediary, intermediary sells to the applicant — has a three-year cooling period built into it. Acquisitions arising from construction contracts sit outside this rule, which matters for the developer fork below.
A property that has already produced a citizenship. One property, one citizenship: the guidance states that a property may be the subject of citizenship acquisition only once, and once a TYTB has been issued over it, it cannot support a certificate for another foreigner. Eligibility is consumed, permanently, by first use.
| Seller on the title | Eligible source? | What the check looks at |
|---|---|---|
| Foreign natural person, any nationality | No | Nationality of the registered owner in the land registry |
| Person naturalised under Article 12(1)(b) | No — holdings before and after naturalisation alike | Registry history against naturalisation records |
| Buyer's first-degree relatives, or a company they partner in or manage | No | Kinship by contract, blood or marriage; company shareholding and management |
| Turkish owner who received the property from any foreigner within the last three years | No | Transfer history of the parcel over the preceding three years |
| Property already used for a citizenship application | No — eligibility is consumed once | TYTB records for the parcel |
| Turkish citizen with clean recent history | Yes | Standard title and transfer checks |
| Foreign-capital Turkish company under Article 36 of the Land Registry Law | Only on the developer conditions below | Permit chain, condominium establishment, first transfer |
The company fork: when a foreign-capital developer is, and is not, a lawful seller
The most commercially important nuance in the whole section concerns Turkish companies with foreign or international capital — the vehicles through which much of the coastal and Istanbul new-build stock is actually developed and sold.
Property registered to such a company can support a citizenship purchase, but only inside a narrow gate: condominium ownership or easement must be established in the owner company's own name, the unit must never have been transferred before, and the construction investment must demonstrably be the company's own — evidenced by a permit chain showing the company as owner and contractor from the first building permit, or by a service contract establishing that the owner company financed the whole build.
Where the build ran on a land-for-flats arrangement — the classic kat karşılığı construction contract — the guidance splits the project down the middle: units registered to the contractor can support a citizenship purchase, while units remaining with the landowner company cannot. Two apartments in the same building, identical in every respect a buyer can see, can sit on opposite sides of the eligibility line because of how the developer and the landowner divided the project years earlier.
The practical consequence is that "you are buying from the developer, so citizenship is guaranteed" is not a statement anyone can responsibly make until the permit chain and the registry history of the specific unit have been read. The verification is documentary and entirely feasible before signing — it is part of ordinary property due diligence in Turkey — but it is unit-specific, not project-level.
The undertaking you sign, and its two tripwires
At the transfer itself, the buyer gives a written undertaking recorded in the official deed. Its current template, as set out in the guidance, contains three commitments a buyer should read before the day of signing rather than at the counter.
First, the expected one: not to sell the property for three years, mirrored by an annotation on the title record.
Second, an acknowledgment with teeth: that if the information and documents underlying the application prove incomplete, wrong or misleading, Article 31 of the Citizenship Law applies — the provision under which a citizenship decision obtained on false statements or concealment is annulled by the authority that made it. The seller-side rules above are exactly the kind of "important matters" that provision reaches. A defect in who you bought from is not merely a rejected application; discovered late, it is an annulment ground travelling with the citizenship itself.
Third, the tripwire almost nobody prices: the undertaking accepts cancellation of the TYTB if the property is made the subject of a promise-to-sell contract during the three-year period — or if, even after the three years expire, the property is transferred back to the previous owner or the previous owner's first-degree relatives. The anti-recycling rule outlives the annotation. A quiet exit arranged with the original seller for year four is not a loophole; it is a documented cancellation trigger that the buyer has personally signed.
A worked example
Assemble the rules into one file and their interaction becomes visible. A buyer finds a resale apartment in Istanbul at USD 450,000, owned by a Turkish citizen — first condition satisfied. The transfer history shows the current owner bought it two years ago from a Russian national: excluded, because a foreign natural person put it into Turkish hands within the last three years. The agent proposes a second unit in the same building, owned since 2015 by the same Turkish seller: the three-year rule is satisfied — but the registry shows a TYTB issued over that unit in 2022 for a previous applicant, and eligibility is consumed once, so it is excluded too. The third candidate is a new unit held by the project's foreign-capital developer: eligible only if condominium title stands in the developer's own name, the unit was never transferred before, and the permit chain shows the developer built it — and if the project ran on a land-for-flats contract, only if this unit fell on the contractor's side of the split.
Three plausible purchases, one eligible — and every step of that triage was documentary, free of speculation, and available before any deposit moved. The same checks apply where the acquisition runs through a notarised promise-to-sell with the three-year no-transfer annotation instead of an immediate transfer: the seller-side conditions are examined for the property under the promise on the same terms.
Why this checklist is rarely volunteered
None of the checks above is secret, and all of them are run — at the latest — by the registry's own systems when the determination certificate is examined. The reason a buyer should run them first is timing and incentive, stated factually: by the time the official check fails, the buyer has typically signed, paid at least in part, and structured their family's plans around an application that cannot proceed, while every intermediary's economic interest in the transaction was realised at signing. The checklist kills ineligible deals early, which is precisely its value to the buyer and its cost to everyone paid on completion.
Run in order, it is short: the registered owner's identity and nationality; the parcel's transfer history for the last three years; whether a TYTB has ever issued over the property; for a corporate seller, the shareholding, the permit chain and whether this specific unit was ever transferred before; and the kinship map between buyer and seller. Every item is documentary. Every item is checkable before signature.
Send us the title record and the draft contract before you sign or transfer anything, and tell us the purchase is intended for a citizenship application — and who the seller is. We will read the seller's side of the file against the current conditions and tell you plainly whether this property can carry the application at all. That work sits with our Turkish citizenship service.
