A foreign national applying for Turkish citizenship typically waits months, sometimes years, for a decision on their file. Yet under Turkish administrative law, if no response arrives within 60 days of the application, that silence itself produces a legal consequence: the application is deemed to have been implicitly rejected. As of 2026, this rule remains unchanged under Article 10 of the Administrative Procedure Act (IYUK), yet many applicants lose their rights simply because they are unaware this deadline exists.
What Implicit Rejection Means
Implicit rejection occurs when the administration is deemed to have rejected a request purely through silence, without issuing any express decision. Under Article 10 of the IYUK, an applicant may ask an administrative authority to act on their request; if the authority fails to respond within 60 days, the request is considered rejected. This principle is not unique to citizenship applications, it is a general rule of administrative law, but because citizenship files pass through so many institutional layers and take so long, it is one of the areas where the rule is encountered most often in practice.
Consider a concrete example: a foreign national residing in Beyoglu who applies for citizenship through the ordinary route under Turkish Citizenship Law No. 5901 may submit their file to the Provincial Directorate of Migration Management and then wait for months without receiving any written notice. During this wait, the applicant usually assumes the file is “still under review”. Legally, however, once the 60-day period lapses, an already-rejected decision exists, whether or not anyone has said so.
When and How Does Implicit Rejection Arise?
The clock starts on the date the application is properly submitted to the administration. Suppose an applicant completes their file in the first week of March; the 60-day period then begins running from that date and expires in the first week of May. If the administration remains silent after that date, a rejection has legally arisen, and the applicant’s right to file a lawsuit is triggered.
One point worth noting is that the period can be interrupted in situations such as missing documents or a request for additional evidence from the administration. If the administration has asked the applicant for further information and that request has gone unanswered, the starting point of the 60-day period itself can become disputed. For this reason, it is essential that every applicant carefully record the dates of all correspondence exchanged with the administration.
Why Is Implicit Rejection Controversial in Citizenship Cases?
The purpose of the implicit rejection mechanism is to prevent the administration from leaving individuals in indefinite limbo through unlimited silence. Even so, legal scholars disagree on how this mechanism should operate in citizenship applications. One view holds that because citizenship applications involve an exceptional degree of administrative discretion, treating 60 days of silence as an outright rejection risks prematurely closing an evaluation that is still, in substance, ongoing. The opposing view holds that applicants should never be forced into indefinite waiting, and that allowing otherwise would strip the administration of accountability altogether.
In our assessment, the second view sits better with the principle of legal certainty. Take, for example, an investor who applies for Turkish citizenship by investment and has received no response after 14 months: denying that person the ability to sue would only encourage the administration to stay silent indefinitely. The implicit rejection rule exists precisely as a safeguard for situations like this. Choosing not to exercise this right should not mean losing it, yet in practice, simply not knowing the deadline has exactly that effect.
Deadline and Procedure for Challenging an Implicit Rejection
Once an implicit rejection has arisen, the applicant likewise has 60 days to file an annulment action before the administrative court (IYUK Art. 7). This period begins running from the date the initial 60-day waiting period ends, meaning that, in total, the window to sue can close roughly four months after the original application date.
A common mistake in practice is applicants letting this deadline slip while thinking “perhaps the administration will respond soon”. For instance, if an applicant whose file is deemed implicitly rejected still has not filed suit eight months later, and the administration has not issued an express rejection in the meantime, there is a real risk that the deadline to sue has already been missed. Calculating this period correctly is decisive for the legal fate of the file.
It should also be noted that if the administration issues an express rejection before the implicit rejection period expires, the matter becomes an express rejection rather than an implicit one, and the deadline to sue starts running afresh from the date that express decision is notified. A similar timing issue arises in objections to residence permit rejections; in both processes, correctly establishing the notification date is critical to whether the lawsuit will be admissible.
What Should Applicants Track During This Process?
First, the date of application and any correspondence exchanged with the administration should be kept on record with dates and in writing. This matters both for proving when the period started and for documenting any interruptions. Second, once the 60-day waiting period expires, the applicant should mark that date and understand that the deadline to file suit begins running from it.
Third, some applicants choose to reapply to the administration instead of filing suit once an implicit rejection has arisen. While legally permissible, this does not automatically restart the deadline to sue, and it can increase the risk of missing it. For example, an investor applying for citizenship through the exceptional route based on the USD 400,000 real estate requirement, whose file is implicitly rejected, is usually better served by filing suit within the deadline than by submitting a new petition, since a fresh application to the administration does not automatically reset the clock.
Finally, because the specific circumstances of each file (application date, missing-document process, correspondence with the administration) can produce different outcomes, the deadline calculation should always be assessed against the facts of the individual case.
Conclusion: What to Do, and in What Order
The implicit rejection of a citizenship application is a mechanism that converts the administration’s silence into a legal consequence rather than leaving it as mere uncertainty. The path an applicant should follow is clear: first, keep a record of the application date and all correspondence; then determine the date the 60-day waiting period expires; then track the 60-day deadline to sue and file with the administrative court within that period.
Although this process may look technical, it ultimately rests on simple calendar arithmetic. The real risk is waiting for months without knowing the deadlines, assuming a response will eventually arrive. Because the facts of each case, missing-document processes, additional correspondence with the administration, the type of application, can directly affect how the deadline is calculated, every applicant is advised to track the stage of their own file closely.
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