The Turkish citizenship valuation report rule changed on 28 September 2026. The report behind the TTB, the land registry’s document that confirms the investment amount in a citizenship-by-property file, may now come from any valuation firm authorized by the Capital Markets Board of Türkiye (Sermaye Piyasası Kurulu, SPK), and a TTB now stays usable for twelve months before the citizenship application at the land registry, where the limit was six. From 4 March 2024 until that day the report for a citizenship sale had to be issued by GEDAŞ Gayrimenkul Değerleme A.Ş. alone.
The source is TKGM Circular 2024/4 as amended by the Makam Oluru of 28 September 2026 no. 21914825, in the e-signed consolidated text on the land registry’s own server (cms-api.tkgm.gov.tr/media/101815), read on 30 September 2026.
What changed on 28 September 2026?
The Makam Oluru of 28 September 2026 no. 21914825, issued on the Ministry’s approval of 18 September 2026 no. 21900458, rewrote three passages of Circular 2024/4 of the Land Registry and Cadastre General Directorate (Tapu ve Kadastro Genel Müdürlüğü, TKGM) and repealed one instruction.
- The TTB is now built from a valuation report issued by any valuation firm the Capital Markets Board has authorized; in the circular’s words, “Sermaye Piyasa Kurulu tarafından yetkilendirilmiş herhangi bir Değerleme Kuruluşu tarafından düzenlenen” report. From 4 March 2024 until 28 September 2026 only GEDAŞ, the affiliate of the Housing Development Administration (TOKİ), could issue a report for a citizenship sale (TKGM Circular 2024/2).
- The gap between the TTB and the application for the citizenship transaction at the land registry may not exceed twelve months (“oniki ayı geçmeyecektir”), and a TTB older than that needs a new report. The earlier text of the same sentence said six months (“altı ayı geçmeyecektir”).
- A real estate investment trust (gayrimenkul yatırım ortaklığı, GYO) selling to a foreigner for citizenship must now either present the valuation report of the unit that it had made before the deed under its own rules and published on the Public Disclosure Platform (KAP), or request a new report for a TTB through WebTapu and TADEBİS (“ibraz etmeleri veya WEBTAPU/TADEBİS üzerinden TTB’ye esas yeni bir değerleme raporu talebinde bulunmaları gerekmektedir”); where the KAP report is presented, the registry puts the question to TKGM’s Foreign Affairs Department (Yabancı İşler Dairesi Başkanlığı) and acts on the answer. The earlier text only let the General Directorate ask an exempted seller for a TTB where it saw fit.
- The same approval added TKGM’s instruction (Talimat) of 6 January 2026 no. E-66840836-125.01.01-18933034 to the instructions the circular repeals.
What stays as it was?
The amount rule does not move. For a property bought after 18 September 2018, the price declared in the title deed and the money transferred to the seller must each reach USD 400,000, and the TTB must confirm it; for a purchase made from 12 January 2017 to 18 September 2018 the figure is USD 1,000,000. The report is still ordered through WebTapu and TADEBİS, under the request for a valuation made for citizenship; the TTB still travels only through the registry’s system, and a TTB presented on paper is refused. The circular still states that the amount in a TTB does not bind the title-deed fee (tapu harcı).
Transactions to which a public body or one of its companies is party, and sales made by a real estate investment trust (gayrimenkul yatırım ortaklığı, GYO), need no TTB.
What does the change mean for a purchase in progress?
The circular sets no transitional clause. On its words, the twelve-month test runs between the TTB and the date on which the citizenship transaction is applied for at the land registry, so an application made on or after 28 September 2026 is measured against twelve months, including one whose TTB was issued before that day. A file that stopped only because its TTB had passed six months is read again on the new text, date by date.
The wider circle of valuers changes the practice more than the paperwork. Any SPK-authorized firm may now issue the report, and the question moves from waiting for one firm to checking the report before it becomes a TTB: the value in the report has to carry the declared price, because the TTB confirms only what the report supports, and the file stands on the amount the TTB confirms.
What we check before a report is ordered
Before a valuation is requested we read the title deed and its annotations, since a mortgage or a restrictive annotation stops the file; confirm that the seller is a Turkish natural or legal person and that the unit has not been used in another citizenship application; set the declared price against the transfers and the foreign exchange purchase certificate (DAB); and fix the date by which the land registry application must be made, so that the TTB is still inside its twelve months on that day. Where the seller is a GYO, its KAP report of the unit is read first.
Have your purchase read under the new rule
A signed written opinion by Av. Serkan Kara on your purchase under the rule of 28 September 2026 costs EUR 500 and is credited in full against the fee if you instruct us; a consultation costs EUR 250 and is credited the same way. The opinion reads the title deed, the contract, the valuation report or the KAP report, the transfers and the DAB, and tells you whether the file stands, what has to be corrected and by which date. Agencies and developers who bring buyers find our terms on the page for agencies.
The full role of the valuation in a citizenship file is set out in SPK valuation report risk in Turkish citizenship by investment, and every route with its amount in the Turkish citizenship by investment guide.
This page reports TKGM Circular 2024/4 as read on 30 September 2026. It is general information about Turkish law and not advice on a particular file; representation begins only under a signed engagement.