Turkish Citizenship by Investment Fund Units

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

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

Turkish citizenship through investment fund units 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 lira from that sale used to buy units of a real estate investment fund (gayrimenkul yatırım fonu, GYF) or a venture capital investment fund (girişim sermayesi yatırım fonu, GSYF), held for at least three years (Article 20(2)(e) and 20(10) of the Regulation on the Implementation of the Turkish Citizenship Law). The Capital Markets Board (SPK) determines the investment and issues the Certificate of Conformity, on the record that the Central Registry Agency (MKK) keeps of the units. Two things decide the file before any money moves: these units are sold only to qualified investors, and for three years MKK reads the holding every week.

Serka Law Firm runs fund-route files from the qualified-investor documents and the fund’s issuance contract to the passport, as part of the work set out on our Turkish citizenship by investment lawyer page.

Qualified investors only, and the figure that applies to these funds

Units of both kinds of fund are sold only to qualified investors (“Katılma payları sadece nitelikli yatırımcılara satılabilir”, Article 13(1) of the Communiqué on Real Estate Investment Funds, III-52.3, and of the Communiqué on Venture Capital Investment Funds, III-52.4), and the firm that sells them must obtain and keep the documents that show it (Article 16(5) and Article 16(9) respectively). A qualified investor is a professional client under the Board’s rules on investment firms, including one accepted as professional on request (Article 4(1)(m) of Communiqué II-5.2). For a private individual the test that matters is the second of the three in Article 32(1) of Communiqué III-39.1: financial assets, cash deposits and capital markets instruments included, above TRY 1,000,000. Meeting that one test is enough to be a qualified investor (Article 32(3), and the Board’s Guide on investment services, section BB).

On 18 December 2025 the Board raised that figure to TRY 10 million, and said in the same decision that the new amounts do not apply to the qualified investors who buy real estate and venture capital fund units, for whom the earlier figures continue (Principle Decision i-SPK.37.7, SPK Bulletin 2025/64; the Guide, section BB, as updated on 10 March 2026). The lira that the sale of USD 500,000 to the Central Bank produces, held in the investor’s own account before the purchase, is itself far above that figure (about TRY 24.7 million at the Central Bank’s buying rate of 20 October 2026). What the seller of the units needs is the investor’s written request and the document that shows his assets on the day, and both are prepared before the transfer, not on the day of the purchase.

The block is the investor’s own, and lifting it ends the file

The units are blocked in MKK’s citizenship sub-account on the date they reach the investor’s account, at his request made through the investment firm that holds them. SPK’s procedure says plainly that this block is optional and does not take away his right to dispose of the units: he can lift it himself and sell or transfer them, or end the citizenship process (procedure (c)(i)). What follows from lifting it is written in the same procedure. MKK checks the holdings every week, and a lifted block, a sale or transfer that lowers the balance, or any attachment (haciz), interim injunction or other encumbrance on the units is reported to SPK within three working days; SPK then notifies the migration authority, the Directorate General of Civil Registration and Citizenship Affairs and the investor at once (procedure (c)(viii)). An encumbrance within the three years counts as failing the three-year condition itself (procedure (c)(vii)), so an attachment a creditor places on the units ends the file as surely as a sale the investor chooses.

Two things do not end it. A fall of the units’ value below USD 500,000 because the exchange rate has moved affects neither the application nor the citizenship (procedure (c)(iv)). And a fall in the fund’s value or in the number of units that is not of the investor’s own will, a cash dividend, a return of units under the fund’s own rules or its liquidation, does not count as losing the minimum (procedure (c)(v)).

What the fund’s own documents decide

The units are bought under a fund issuance contract, which the seller must sign with the investor before the sale (Article 13(13) of each Communiqué, added in 2024), and three of its terms matter to a citizenship investor more than the fund’s past returns.

• When the units can be returned. Units are returned to the fund on the contract’s terms, and a fund set up for a fixed term may provide that they are returned only at the end of that term (Article 16(3) of the GYF Communiqué; Articles 4(2) and 14(6) of the GSYF Communiqué). The three years of the citizenship rule and the fund’s own term are two different clocks, and the second is read before the purchase.
• How often the units are valued. The unit value is calculated and reported at least once a year (Article 15(2) of each Communiqué), so the holding is not priced day by day like a deposit balance.
• Whether the units can be passed on. Units may be transferred between qualified investors, but the contract may make a transfer subject to approval or bar it altogether (Article 16(9) and 16(10) of the GYF Communiqué; Article 16(6) of the GSYF Communiqué).

What the fund holds is fixed by its Communiqué: at least 80 per cent of a real estate investment fund’s total value in real estate investments, and at least 80 per cent of a venture capital investment fund’s in venture capital investments (Article 19(1)(a) of each).

How SPK determines the investment

SPK’s procedure for the Certificate of Conformity, published on 21 December 2022, runs in four steps.

1. The application. The investor writes to SPK with his name, date of birth, foreign identity number, address and contact details, his MKK registry number, the fund units he holds and the document showing them blocked in the citizenship sub-account, with a copy of his passport. Where a representative files it, the power of attorney must carry the authority for every act of the application.
2. SPK to MKK. Within two working days of a complete file SPK asks MKK whether the investor holds units of the required scope and amount, giving his registry number and identity so that the beneficial owner is established.
3. MKK’s check. MKK confirms that the currency was sold to a bank in Türkiye and by it to the Central Bank before the units were bought from the fund, and that they were bought with the lira from that sale, and reports to SPK within three working days.
4. The certificate. Within two working days of MKK’s letter SPK issues the Certificate of Conformity and sends it at once to the investor, to the migration authority and to the Directorate General of Civil Registration and Citizenship Affairs; a refusal is notified to the investor.

SPK’s procedure applies the same investment to the investor’s short-term residence permit under Article 31(1)(j) of Law No. 6458 and to a long-term residence permit under Article 43(2), on the Migration Policies Board’s decision 2017/02. The Directorate General names four steps the investor takes in person: obtaining the Certificate of Conformity, applying for the short-term residence permit, collecting the residence card and applying for citizenship.

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 foreign currency is converted by the Turkish bank into one of them and then sold on (Article 5(2) of its Implementation Instruction of 16 May 2022). A transfer in Turkish lira leaves nothing to sell. Once the Central Bank has completed its purchase the sale cannot be abandoned or cancelled (Article 7). On this route the lira does not stay in a deposit: it buys the units, and that purchase is what MKK traces back to the sale.

Fund units, government bonds or a bank deposit

All three take USD 500,000 sold to the Central Bank and three years. On the bank deposit route the three years are held in a lira balance; on the government bond route in lira government debt instruments held at the bank that bought the currency. On the fund route they are held in units whose value moves with the fund’s real estate or companies, reported at least once a year, and whose exit is set by the fund’s own contract rather than by the end of the three years. The investor who wants his capital back in hand at a known date reads the fund’s term first.

Before the fund is chosen

The fund route is decided by documents the investor signs before the money moves: the request to be treated as a qualified investor with the proof of his assets, the fund’s issuance contract with its term, its rules on returning units and its limits on transfer, and the instruction for the block.

The texts this page rests on

• Regulation on the Implementation of the Turkish Citizenship Law, Article 20, consolidated text
• Capital Markets Board, the procedure for the Certificate of Conformity on the fund route, 21 December 2022
• Communiqué on Real Estate Investment Funds (III-52.3) and Communiqué on Venture Capital Investment Funds (III-52.4), consolidated texts
• Communiqué II-5.2 and Communiqué III-39.1, Articles 31 and 32
• SPK Bulletin 2025/64, Principle Decision i-SPK.37.7 of 18 December 2025
• Central Bank of the Republic of Türkiye, Implementation Instruction of 16 May 2022

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.