The USD 400,000 Real Estate Requirement for Turkish Citizenship: The Appraisal Report and the 3-Year No-Sale Undertaking

The minimum investment threshold required for Turkish citizenship by real estate investment was raised from USD 250,000 to USD 400,000 under the regulation dated 12 June 2022, and as of August 2026 this threshold remains in force. Even so, in practice a significant share of applications are delayed or rejected not because the amount is insufficient, but due to procedural shortcomings such as missing appraisal reports and payment documentation.

In this guide, we walk through, step by step, how the USD 400,000 requirement operates under Article 20 of the Implementing Regulation of the Turkish Citizenship Law, why the appraisal (valuation) report is the pivotal document in the process, and what the 3-year no-sale undertaking actually means.

What Is the USD 400,000 Requirement, and What Law Is It Based On?

The route most commonly used by foreign investors seeking citizenship is to purchase real estate worth at least USD 400,000, or the equivalent in foreign currency, and have a 3-year no-sale annotation recorded in the title deed registry. The legal basis is Article 20 of the Implementing Regulation under Law No. 5901 on Turkish Citizenship; citizenship acquired through this route is formally known as “exceptional citizenship” (istisnai vatandaşlık).

Let’s start with a concrete example. An investor from a Gulf country took a liking to an apartment in Beyoğlu listed at a sale price of USD 450,000. But here is the critical point: the seller’s stated price is not enough on its own, the official appraisal report must also confirm a value of at least USD 400,000. If the report comes in below the threshold, the process can stall right at the title deed stage.

Step 1: Obtain an Appraisal (Valuation) Report

The appraisal report, formally known as the real estate valuation report, is the backbone of the process. It must be prepared by a valuation firm licensed by the SPK (Capital Markets Board) and must be current at the time of the title deed application; in practice, keep in mind that a report is considered valid for three months from its issue date (as of August 2026).

Consider this scenario: a buyer looking to purchase an apartment in Galata paid a deposit on the strength of the seller’s assurance that “the value comfortably covers it,” but the valuation report came in below expectations. At that point there are two options: purchase an additional property to bring the combined total above USD 400,000, or withdraw from the transaction. The correct order of operations is to obtain a preliminary valuation before paying any deposit.

Step 2: Document the Payment Through a Bank

The purchase price must be paid through a bank, by wire transfer from the buyer to the seller, with both parties clearly identified on the transfer receipts. Cash payment is not valid for citizenship applications. In addition, a Foreign Exchange Purchase Certificate (Döviz Alım Belgesi, DAB) must be issued showing the sale of the foreign currency to the Central Bank through a Turkish bank; the USD equivalent of the amount is calculated on the basis of this certificate.

How does this play out in practice? Take a typical question we get at our office in Taksim: “Can I pay part of the price from abroad in cryptocurrency?” The answer is clear: no. Any portion paid without a traceable bank transfer and a DAB is not counted toward the USD 400,000 total. The payment plan must be structured around this rule from the contract stage onward.

Step 3: Title Deed Transfer and the 3-Year No-Sale Undertaking

At the time of the title deed transfer, the buyer gives an undertaking not to sell the property for 3 years, and this undertaking is recorded as an annotation in the remarks section of the title deed registry. Any sale carried out before the annotation period expires puts the acquisition of citizenship at risk; the period is calculated from the date the annotation is recorded.

A typical real-life situation: an owner who purchased an apartment in Cihangir through this route wanted to sell the property at the end of the second year. The framework we explained to them was this: selling before the annotation period expires can expose the acquired status to challenge; renting the property out, however, is possible, because the undertaking restricts only the transfer of ownership. This distinction should shape your investment plan from the very start.

Step 4: Certificate of Conformity, Residence Permit and Citizenship Application

Once the title deed and payment documents are complete, the General Directorate of Land Registry and Cadastre issues a certificate of conformity confirming that the property meets the citizenship requirements. The applicant then obtains a short-term residence permit specific to investors under Law No. 6458, and the citizenship file proceeds through the Provincial Directorate of Population and Citizenship Affairs. For official announcements, you can follow tkgm.gov.tr and goc.gov.tr.

Let’s clarify a frequently asked question here: “Will my family also acquire citizenship?” Yes, the applicant’s spouse and children under the age of 18 can also apply for exceptional citizenship under the same file. For example, the file of an investor who purchased office floors in Karaköy would include their spouse and two children; identity and civil status documents are prepared separately for each family member.

Common Mistakes and Points to Watch

The mistakes that most often delay files in practice are well known: purchasing from a foreign-national seller (which does not count toward citizenship), paying a deposit before obtaining a valuation report, paying part of the price in cash, and the report’s three-month validity period expiring before the title deed appointment. Each of these can restart the process from scratch, even where the threshold amount has otherwise been met.

A word of caution regarding intermediaries: be wary of consultants who work on a “guaranteed citizenship package” promise. No legal process can guarantee an outcome; each file is assessed individually based on the nature of the property, the payment flow and the applicant’s circumstances. In a typical file we reviewed last month, for instance, the property’s eligibility ran into additional scrutiny because of a foreign shareholding in the selling company’s ownership structure, details of this kind only come to light through preliminary legal due diligence.

To sum up, the path to follow for citizenship through USD 400,000 real estate:

• Due diligence first: Confirm the property’s and the seller’s eligibility for citizenship before paying any deposit.
• Report: Obtain a current valuation report from an SPK-licensed firm and track its three-month validity period.
• Payment: Pay the price only through a bank, and keep the transfer receipts and the Foreign Exchange Purchase Certificate.
• Annotation: Verify that the 3-year no-sale undertaking has been recorded on the title deed; do not plan a sale before the period expires.
• File: Handle the certificate of conformity, residence permit and citizenship application as a single, integrated file.

Because every file differs in terms of the property, payment structure and family situation, having the process assessed individually is the soundest approach.