Immigration and Citizenship Law
Revocation and Withdrawal of Turkish Citizenship (2026 Current Legal Assessment)
The revocation and withdrawal of Turkish citizenship is one of the most frequently encountered issues in the field of immigration law. In recent years, regarding foreign nationals who acquired Turkish citizenship through the acquisition of real estate in Turkey, decisions on the withdrawal and revocation of citizenship have significantly increased in administrative practice. Particularly as a result of the review of applications made through certain projects, administrative proceedings are being instituted against many individuals for the revocation of Turkish citizenship . As reflected in public news reports, within April 2026, pursuant to the investigation conducted by the Istanbul Chief Public Prosecutor's Office, a seizure decision was issued regarding all real estate offered for sale by the company named Hayatpark Gayrimenkul A.Ş. as the basis for the acquisition of Turkish Citizenship by foreign nationals, and the Turkish Citizenship decisions of approximately 1,100 individuals who acquired Turkish Citizenship through the relevant real estate were withdrawn.
In this article, the legal basis for the withdrawal of Turkish citizenship, the limits of the administration's authority, problems in practice, and particularly the legal validity of revocation decisions based on real estate valuation are addressed in detail.
Legal Basis for the Revocation and Annulment of Turkish Citizenship
the revocation of decisions regarding Turkish citizenship, pursuant to Article 40 of the Turkish Citizenship Law No. 5901 (TVK Art. 40) has been regulated.
According to this provision:
- Decisions concerning the acquisition or loss of Turkish citizenship,
- if issued without the fulfillment of legal conditions,
- or if established in a duplicate or erroneous manner,
may be revoked by the administration.
Furthermore, pursuant to the provisions of the relevant regulation, such decisions:
- shall be revoked by the administrative authority that rendered the decision.
- And the revocation procedure produces nullification effects as of the date of the initial decision.
In this respect, the revocation of citizenship is technically "the revocation of an administrative act" under administrative law .
Under Which Circumstances Can Citizenship Be Revoked?
The legislator has exhaustively regulated the grounds for revocation. Accordingly, for a citizenship decision to be revoked:
- The conditions stipulated by law must not have actually been fulfilled
- The decision must contain a clear violation of law
- One of the elements of authority, form, ground, subject matter, or objective must be flawed
is required.
At this point, the critical issue is:
Not every administrative error or debatable situation justifies the revocation of citizenship.
The administration's power of revocation is not unlimited and is bound by the principles of proportionality, legal certainty, and vested rights.
The Most Critical Issue in Practice: Real Estate Valuation
The vast majority of recently issued citizenship revocation decisions are based on the following allegation:
The allegation is that the declared value of the real estate was lower than it should have been in reality. In other words, Turkish Citizenship decisions are being revoked on the grounds that the real estate sale price declared to the Land Registry Offices during the acquisition of Turkish Citizenship was higher than the actual value of the real estate. However, there is a serious legal issue in practice at this point:
1. Subsequent Valuation Is Not a Reliable Criterion
As is known, the relevant real estate was purchased by the foreign applicant in the years 2021-2022-2023. In the examinations conducted by the Administration:
- In 2025 or in subsequent years,
- According to current market conditions,
- A revaluation is being carried out.
This approach is legally problematic because:
Considering the economic conditions, inflation, exchange rates, and market fluctuations in Turkey, the past value of a real estate property and its value in subsequent years will not be the same . Therefore, it is already a natural and expected outcome that a residential property purchased in any region of Turkey in 2021, 2022, and 2023 will have a lower value in 2025 than its value at the time of purchase. For this reason, revocation and cancellation decisions based solely on this allegation are not lawful. This situation violates the principle of legal certainty and the administration's obligation of proportionality.
3. Even GABİM Authorized Valuation Experts Cannot Issue Retrospective Reports
One of the most critical technical realities overlooked in practice is as follows:
👉Even experts authorized by GABİM (Real Estate Appraisers Association) cannot issue a reliable retrospective valuation report.
Because:
- Valuations are conducted based on prevailing market conditions.
- Retrospective hypothetical valuations are not objective.
- Such reports lack scientific and technical certainty.
Therefore:
The reliance on such reports obtained during the investigation stage
as the basis for the revocation of Turkish citizenship
constitutes a disproportionate and erroneous practice under law.
Is There Any Fault on the Part of the Real Estate Buyer?
Another significant issue drawing attention in practice:
- The vast majority of foreign investors acquiring real estate
- conduct the process through official institutions and authorized companies.
In this case:
Even if there is a potential irregularity,
it is highly likely that this stems from the project developer or intermediary firms rather than the investor.
Therefore:
Revoking the citizenship of faultless individuals is incompatible with the principle of the rule of law.
Legal Remedy Against Revocation Decisions
Decisions regarding the withdrawal of Turkish citizenship:
- are administrative acts
- are subject to judicial review
In this context:
The concerned parties may file an annulment lawsuit in the administrative judiciary.
During the litigation process, the court reviews:
- the legality of the act
- the sufficiency of the evidence
- the validity of the valuation reports
- Examines the fault of the person
in detail.
Conclusion: Not Every Revocation Decision Complies with the Law. Immigration law for detailed information about our services, you can visit our Immigration Law page.
In summary;
- Revocation of Turkish citizenship is an exceptional procedure
- Each specific case must be evaluated on its own merits
- Particularly, revocation decisions based on real estate valuation are a matter of serious legal debate.
And the most critical finding:
A subsequent low valuation cannot, by itself, serve as the basis for the revocation of citizenship. Decisions rendered based on retroactive valuation reports may be legally weak and subject to annulment. For current legislation Legislation Information System‘s can be reviewed.
Contact and Legal Support
Processes regarding the revocation or cancellation of Turkish citizenship require a technical and multidimensional legal assessment. Examining each specific case within its own circumstances is of great importance to prevent loss of rights.
In this context, it would be beneficial to consult a law firm specialized in immigration and foreigners law to evaluate your legal situation regarding the matter and to obtain information on legal remedies.
Contact:
📞 +90 (532) 669 34 90
📞 +90 (532) 732 34 90
📧 info@batinyilmaz.av.tr
This article is for general informational purposes and does not constitute legal advice. Legislation and practice may have changed after the publication date; you may consult us for an evaluation specific to your file.