Turkish Citizenship by Government Bonds

Av. Serkan KARA, Serka Law Firm (Istanbul Bar, no. 53770)

Last reviewed: 20 October 2026 · Reviewed by Av. Serkan Kara

Turkish citizenship by government bonds requires at least USD 500,000, or its equivalent in foreign currency, sold to a bank in Türkiye and by that bank to the Central Bank, with the Turkish lira from that sale held in lira-denominated Turkish government debt instruments for three years (Article 20(2)(d) and 20(10) of the Regulation on the Implementation of the Turkish Citizenship Law). The Ministry of Treasury and Finance determines the investment, and it reads the file only when the bank sends it; the spouse and the children who are minors or dependants come in on the same holding. The route suits an investor who wants a sovereign instrument rather than a property or a bank balance, and it is decided at the bank before any money moves: which bank will buy the currency, buy and hold the bonds and write to the Ministry, in which currency the funds arrive, and in whose name.

Serka Law Firm runs government bond files from the bank’s first compliance question to the passport, as set out on our Turkish citizenship by investment lawyer page, and writes to the investor and the family in their own language.

The requirements: what the regulation says

Article 20(2)(d) of the Implementing Regulation, as amended on 6 January 2022, grants the route to a foreigner “determined by the Ministry of Treasury and Finance to have bought government debt instruments of at least USD 500,000 or its equivalent in foreign currency, on condition of holding them for three years” (our translation). Article 20(10), as amended on 13 May 2022, fixes how the money travels: the foreign currency is sold, before the transaction, to a bank operating in Türkiye and by that bank to the Central Bank, and “the Turkish lira obtained under (d) is held in Turkish lira denominated government debt instruments for three years”. The Central Bank’s Implementation Instruction of 16 May 2022 repeats the same lira holding for this route in its Article 6(1).

Article 20(9) leaves the method of the determination to the institution that makes it. For this route the Ministry’s Directorate General of Public Finance has issued a revised procedure, Türk Vatandaşlığını Devlet Borçlanma Araçlarını Satın Alarak İstisnai Olarak Kazanmak İsteyen Yabancı Kişilerin Başvuru Süreçleri İçin Uygulanacak Usul ve Esaslar, whose Article 8(2) repeals the procedure of 14 February 2020. We work from the copy a state bank’s foreign investments desk sent us on 24 September 2026. The 2020 text is still on the Ministry’s website, and two of its rules no longer hold: it counted bonds issued in foreign markets, and it let the instruments move between banks.

How the Ministry determines the investment

1. The currency is sold to the bank for sale on to the Central Bank, and with the lira from that sale the bank buys lira government bonds or lease certificates on the same day or the next working day, for no less than the lira equivalent of USD 500,000. The bank that sells the currency and the bank that holds the instruments must be the same (Article 4(2) and 4(3)).
2. The investor undertakes to keep the instruments in the account for three years and signs the declaration and the petitions annexed to the procedure, with identity documents; the information in them has to match, and where a petition is signed in another language the Turkish one is signed as well (Article 4(4) and 4(6), Annexes 2 to 4).
3. The bank sends the Ministry an official letter in PDF with the details of the instruments, the declaration and the petitions in English and Turkish, the Central Bank’s currency sale form, the passport, the account statement and, where a representative acts, the power of attorney and the representative’s identity. The letter is signed by two senior officers of the bank, addressed to the Ministry’s Investor Relations Department and sent by registered electronic mail (KEP) or registered post. A file sent by e-mail or any other channel, or filed with the Ministry by the investor or his lawyer directly, is not considered (Article 5(1) to 5(4)).
4. The Ministry makes a preliminary assessment and asks the bank for any correction; what is not completed within twenty working days of the Ministry’s written notice needs a new application (Article 6(1)).
5. On a positive finding the Ministry writes its conformity letter to the Ministry of Interior so the citizenship file can go on, and a copy reaches the investor or his lawyer through the bank. The Ministry contacts neither the investor nor his lawyer directly at any stage, and once the file is approved the bank reports to it every month whether the three-year holding continues (Article 6(2) to 6(4)).

Choosing an instrument with three years or more to maturity is the responsibility of the bank and the investor, and the procedure says in terms that the Ministry has no power to guide that choice (Article 4(4)). On the table a state bank gave us on 21 September 2026, one of the seven lira issues it offered had the maturity the route needs. Where a lawyer acts, the power of attorney has to carry every act of the application, and the procedure itself sends the reader to the authorities for its wording (Article 5(6)).

The undertaking is yours to lift, and lifting it ends the file

The procedure calls the holding voluntary and leaves the coupons to the investor (Article 4(5)). For the three years the amount must not be reduced by the investor’s own act, whether by a full or partial sale, an assignment or a transfer; if it is, the bank tells the Ministry and the Ministry of Interior in writing by the next working day (Article 4(7)). The investor may lift the undertaking and sell or assign the instruments to have the citizenship process canceled, and the bank reports that, and any measure restricting the use of the instruments or the account, by the next working day; the same applies if the investor dies (Article 4(8)). Any legal restriction placed on the instruments or the account is reported the same way (Article 4(9)). The investor’s own declaration to the bank accepts that an attachment, a pledge, a transfer or an injunction notified to the bank will be processed and that the amount may be blocked or reduced by it (Annex 2), so a creditor in Türkiye is a citizenship question as much as a debt question.

The currency: what is sold, and what cannot be undone

The Central Bank buys only US dollars, euros, pounds sterling and Swiss francs; a transfer in any other currency is converted by the Turkish bank into one of those four and then sold (Article 5(2) of the Central Bank’s instruction). A ruble, yuan or dirham transfer is therefore a foreign currency transfer that works, and money that is already in Turkish lira has nothing to sell. A guide published on this route gives the amount as USD 500,000 “or the equivalent in other foreign currencies or Turkish Lira”, and the lira half of that does not hold. Article 20(10) of the Regulation has the foreign currency sold to a bank in Türkiye, and by that bank to the Central Bank, before the transaction, and only the lira that sale produces is put into the instruments, so lira the investor already holds, or sends from abroad, count toward no part of the threshold. Once the Central Bank has completed its purchase, the sale cannot be abandoned or canceled for any reason, and the bank has to tell the investor so before the transaction (Article 7). The documents of the sale, including the Foreign Exchange Purchase Certificate, are prepared by the bank and given to the investor, and the duty to supply them rests on the bank alone (Article 8(2)).

The dollar value is measured at the Central Bank’s effective selling rate or cross rate on the date of determination (Article 20(6) of the Implementing Regulation), and a later fall in the instrument’s price does not cost the right (Article 4(10) of the procedure). That protects the citizenship, not the money: for three years the capital sits in lira instruments, and their value in dollars moves with the lira and with the bond market. No regulation or procedure prices that risk, and we give no yield figure for a three-year holding. What the lira principal will be is fixed on the day of the sale: since 1 October 2026 the Central Bank buys at the buying rate it announces at 11:00 on the day the currency is turned into lira (Article 3(1)(b) of its Instruction, as amended that day). On its list of 23 October 2026 the dollar’s buying rate was 49.5647, at which USD 500,000 would come to TRY 24,782,350, and the instruments are bought with that lira the same day or the next working day; the 11:00 rate of the day of the sale, not this list, sets the figure.

What the banks told us in 2026

In August and September 2026 three branches of two banks told us in writing that for citizenship they run only the three-year lira deposit or participation account, not government debt instruments. The foreign investments desk of a state bank confirmed in writing on 21 September 2026 that it handles the bond route, opens the investment account under a verified power of attorney, sets up no internet banking under a power of attorney, and wants every banking act named in the power. Because the procedure lets neither the investor nor his lawyer reach the Ministry, and allows no move between banks, the bank is the whole route: it is chosen and its written terms obtained before the currency is sent, and the power of attorney is drafted to its list rather than to a template. Where the money comes from Russia, one branch wrote on 31 August 2026 that a Russian citizen’s investment could not arrive by SWIFT; how that played out on our files is set out in the Russia and Belarus section of our Turkish citizenship by investment lawyer page.

Does the government bond route still work in 2026?

Yes, at the banks that run it. Article 20(2)(d) and Article 20(10) of the Regulation stand as amended on 13 May 2022, the Ministry of Treasury and Finance’s revised procedure replaces its procedure of 14 February 2020, and the state bank’s foreign investments desk confirmed the route to us in writing on 21 September 2026, as above. What is true is that it runs at fewer banks than the deposit: three branches of two banks told us in writing that they offer only the deposit. A guide that says the bond route does not work in practice is contradicted by that written confirmation, and a guide that says the money may now be held in dollars is contradicted by Article 20(10) itself, which holds the lira from the sale “Türk Lirası cinsinden Devlet borçlanma araçlarında”, in lira government debt instruments, for three years.

Three other statements published about this route do not hold either. Treasury bills cannot carry it: Law No. 4749 on Public Finance and Debt Management defines a Treasury bill (Hazine bonosu) as a domestic borrowing instrument issued with a maturity of less than one year, up to 364 days (Article 3), and the procedure keeps out every instrument with less than three years to maturity (Article 4(4)), so only lira government bonds or lira lease certificates with three years or more to run can be bought. A brokerage house cannot carry it either: the procedure defines the bank as a deposit or participation bank under Article 3(1) of Banking Law No. 5411, at its head office or a branch in Türkiye, and the bank that bought the currency buys the instruments (Articles 3(1)(d) and 4(2)). And the three years are not annotated in a register as they are on a title deed: the investor undertakes in writing to keep the instruments in his account, the bank places a three-year block on them and writes to the Ministry, and it reports every month whether the holding continues (Articles 4(4), 4(6) and 6(4), Annexes 1 and 2). The title-deed annotation belongs to the property route (Article 20(2)(b) of the Regulation).

Moving between routes, but not between bonds

Article 20(8) of the Implementing Regulation allows an investor to move between the investment routes to complete the three years, and the procedure keeps that for the deposit, property, fund, pension, fixed capital and employment routes; where the move is into bonds, the bank tells the Ministry by the next working day and a conformity letter is obtained from the Ministry once the steps are done (Article 7(1)). A move from one government debt instrument to another is not allowed. The one exception is an early redemption by the Ministry: the bank reports it, and within two working days a new instrument is bought whose remaining term is at least that of the redeemed one (Article 7(1)). A move out of bonds into another route is reported at once by the bank to the Ministry, to the institution responsible for the new route and to the Ministry of Interior (Article 7(2)).

Government bonds, a bank deposit or real estate

The deposit route is set out on our Turkish citizenship by bank deposit page and the property route under Turkish citizenship by buying property.

From the conformity letter to the passport

The Ministry’s conformity letter opens the rest of the file. The investor applies for a short-term residence permit under Article 31(1)(j) of Law No. 6458 on Foreigners and International Protection, then files the citizenship application with the Directorate General of Civil Registration and Citizenship Affairs, and citizenship is granted by Presidential decision under Article 12(1)(b) of Turkish Citizenship Law No. 5901, which brings in the foreign spouse and the children who are minors or dependants. The Directorate’s own answer to whether an investment file can run on a power of attorney is that the certificate of conformity, the short-term residence permit application, the collection of the residence card and the citizenship application have to be made by the foreigners in person. The documents of the citizenship file are those of Article 20(3) of the Implementing Regulation, and the Directorate’s own list adds a criminal record certificate from the applicant’s home authorities issued within the last six months.

No regulation and no procedure sets a time for the Presidential decision, so we give no date for the passport. The Ministry’s assessment begins only when the bank’s letter reaches it in the required form, which is why the bank is settled first.

Before the bank is chosen

The decision point on this route is before the money moves. Once the Central Bank has bought the currency the sale cannot be undone, and the bonds stay at the bank that bought it for the three years.

The texts this page rests on

• Regulation on the Implementation of the Turkish Citizenship Law, Article 20, consolidated text
• Ministry of Treasury and Finance, Directorate General of Public Finance, the revised procedure for foreigners acquiring Turkish citizenship by buying government debt instruments, Articles 1 to 10 and Annexes 1 to 5, in the copy a state bank sent us on 24 September 2026
• Central Bank of the Republic of Türkiye, Implementation Instruction of 16 May 2022
• Turkish Citizenship Law No. 5901

This article provides general information on Turkish law and is not legal advice. No attorney-client relationship is formed by reading it; such a relationship arises only through a signed engagement with Serka Law Firm.