Revocation and Withdrawal of Turkish Citizenship Acquired Through Investment

Turkish citizenship acquired through investment may be subject to cancellation or revocation by the administration if it is subsequently understood that the investment conditions were not genuinely met, false statements were made in the application, material information effective in the acquisition of citizenship was concealed, or the citizenship decision was rendered without the legal conditions being fulfilled. However, just like the requirement of making an investment, the administration's authority to revoke citizenship is not unlimited. The legal basis, material grounds, competent authority, and justification of the decision interfering with citizenship must be amenable to judicial review.

Rejection of the citizenship application through investment, the cancellation of acquired citizenship, and the revocation of a citizenship decision are distinct legal proceedings. This distinction directly affects the scope of the lawsuit to be filed, the grounds of unlawfulness to be asserted, the evidentiary strategy, and the request for a stay of execution.

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How to Acquire Turkish Citizenship by Investment?

Turkish citizenship through investment, under Article 12 of the Turkish Citizenship Law (TVK) No. 5901, is one of the application areas of the exceptional citizenship regime. Unlike acquisition of citizenship through the general pathway, exceptional citizenship is a special acquisition method that can be applied to foreigners who are assessed to contribute economically, socially, scientifically, technologically, or athletically to Turkey.

For the investor, the process mostly relies on economic activities such as real estate acquisition, capital investment, job creation, deposit investment, acquisition of state debt instruments, or participation in certain investment funds. It is determined by a conformity certificate issued by the competent institution that the relevant investment meets the conditions required by the legislation. Subsequently, the residence permit and citizenship application process are carried out on behalf of the foreigner.

However, obtaining a conformity certificate does not mean that citizenship will be acquired absolutely and under all circumstances. Pursuant to TVK Art. 12, the absence of any impediment in terms of national security and public order is among the fundamental conditions additionally required for exceptional citizenship. After citizenship is acquired, the accuracy of the statements made during the application process, the genuine economic substance of the investment, and the compliance of the decision with legal conditions may once again become a subject of dispute.

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The Difference Between Annulment, Revocation, and Rejection of Application

The most critical starting point in citizenship disputes is the correct characterization of the administrative act. The provision upon which the administration bases its action, the factual allegations attributed to the individual, and the resulting conclusion must be carefully examined.

Type of Action	Legal Basis	Substantive Grounds	Legal Consequence
Annulment of the Decision to Acquire Citizenship	TVK art. 31	False statements or concealment of material facts essential to the acquisition of citizenship	The decision to acquire citizenship is annulled
Revocation of the Citizenship Decision	TVK art. 40	Issuance of the decision without the fulfillment of legal conditions, duplicately, or erroneously	The citizenship decision is revoked
Rejection of Citizenship Application	TVK Art. 12	Failure to meet investment conditions or national security/public order impediment	The applicant cannot acquire citizenship

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Annulment of Citizenship Decision: False Statement and Concealment

Pursuant to TVK Art. 31, the decision to acquire Turkish citizenship shall be revoked if it was granted as a result of the concerned party's false statements or concealment of essential matters constituting the basis for the acquisition of citizenship.

For this provision to be applied, it is not sufficient for the administration merely to raise suspicions. The administration must clearly specify which statement was contrary to the facts or which information was concealed. Furthermore, it must be demonstrated that the information alleged to have been concealed was genuinely influential, that is, an essential matter in the acquisition of citizenship.

For instance, it may be alleged that the bank movements showing the applicant's investment amount were contrary to the facts, that the transfer of immovable property was made pro forma, that the investment price was not paid by the applicant, that misleading documents were used during the valuation process, or that essential information required to be disclosed during the security investigation was intentionally withheld. With respect to each of these allegations, the administration must rely on concrete information and documents that establish a direct connection with the individual.

Key Issues Evaluated in the Annulment Action

• What is the information that the administration claims was concealed?
• Did this information exist as of the application date?
• Has it been proven that the applicant knew the information and intentionally concealed it?
• Is the information truly decisive with regard to the acquisition of citizenship?
• Would the citizenship decision have been different if the administration had known the information in question?

Not every piece of information omitted from the application form is automatically considered a “concealed material fact”. The information must be of a nature that should have been disclosed in the application, the applicant must have been aware of it, and it must have had a bearing on the citizenship decision.

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Revocation of Citizenship Decision: Absence of Legal Conditions

TVK art. 40, governs the revocation of decisions concerning the acquisition or loss of citizenship if it is subsequently understood that they were granted without the legal conditions being met or were issued in duplicate.

In revocation proceedings, the allegation of the administration is not necessarily that the applicant lied. The administration may assert that a legally required condition was not present at the time the citizenship decision was rendered, that the transaction was erroneously executed, or that a duplicate decision was issued on the same matter. Therefore, in an action to be filed against the revocation, it is examined in particular whether the investment conditions actually existed as of the application date.

With respect to real estate investments, the title deed registration, official deed, valuation report, records regarding the payment of the sales price through the banking system, encumbrances on the real estate, and the commitment not to sell are of significance. As for capital or employment investments, trade registry documents, bank statements, capital increase records, Social Security Institution (SGK) declarations, tax documents, and certified public accountant reports may be decisive.

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Citizenship Annulment and Revocation Lawsuits in Light of Council of State (Danıştay) Decisions

Ruling	Approach	Brief Rationale	Implications in Practice
Council of State 10th Chamber, E. 2022/7637, K. 2025/3313, D. 26.06.2025	In Favor of the Plaintiff	It was accepted that abstract intelligence reports alone are insufficient and that concrete, verifiable information and documentation are required	The element of cause must be clearly established in the revocation proceedings
Council of State 10th Chamber, E. 2022/4251, K. 2022/4767, D. 26.10.2022	Against the Plaintiff	The annulment action was found to be lawful in the context of the concealment of material facts and the security assessment	If concealment or false statement is proven with sufficient evidence, the administrative act may be upheld
Council of State Plenary Session of the Administrative Law Chambers, E. 2021/3322, K. 2022/438, D. 14.02.2022	Mixed	The method of acquiring citizenship and personal circumstances necessitated a different evaluation	A separate legal review is required with respect to family members
Council of State 10th Chamber, E. 2024/4005, K. 2024/5686, D. 02.12.2024	Against the Plaintiff on Procedural Grounds	The petition was dismissed as the claims regarding the spouse and children were deemed indefinite.	The intent to sue and the requested relief must be clearly established for each individual.
Council of State 10th Chamber, E. 2024/6205, K. 2024/5687, D. 02.12.2024	Against the Plaintiff on Procedural Grounds	It was evaluated that the claims and representation relationship regarding the children were not sufficiently clear.	In lawsuits filed on behalf of minors, parental authority and representation power must be demonstrated.

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Abstract Intelligence Information Alone Is Not Sufficient

Council of State 10th Chamber, E. 2022/7637, K. 2025/3313, D. 26.06.2025 in its numbered decision, examined the proceedings regarding the revocation of Turkish citizenship acquired through exceptional pathways. It was understood from the case file that there was intelligence information concerning one of the plaintiffs regarding a specific school affiliation.

The Council of State evaluated that, apart from this intelligence data contained in the file, there was no sufficient concrete information and documentation demonstrating that the plaintiffs posed an obstacle in terms of national security or public order. The decision emphasized that administrative acts being based on grounds and reasoning is one of the general principles of law, and that the administration is obligated to present accurate and meaningful facts.

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If Concealment and Misrepresentation Are Proven, the Annulment Proceedings May Be Found Lawful

Council of State 10th Chamber, E. 2022/4251, K. 2022/4767, D. 26.10.2022 in its numbered decision, examined the revocation of Turkish citizenship acquired through exceptional pathways by plaintiffs who are citizens of the Russian Federation.

In the decision, it was accepted that the concealment of crucial matters affecting the acquisition of citizenship, along with the assessment made in terms of national security and public order, supported the annulment action in the specific case file. The lawsuit was dismissed; the administration's annulment action was found to be lawful.

This decision demonstrates that in citizenship revocation lawsuits, the defense cannot be based solely on the determination that “an investment has been made„. Which information the administration considers to have been concealed, whether this information is accurate, whether the applicant knowingly withheld the information, and its impact on the citizenship decision must be further debated.

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Procedural Rules in Lawsuits Regarding Family Members Hold Special Importance

Council of State 10th Chamber, E. 2024/4005, K. 2024/5686, D. 02.12.2024 and Council of State 10th Chamber, E. 2024/6205, K. 2024/5687, D. 02.12.2024 decisions numbered, pertain to the revocation of citizenship of individuals who have acquired exceptional citizenship through investment.

In these case files, before proceeding to the substantive examination, the Council of State evaluated whether the petition had sufficient clarity regarding the parties and the claims. Since it was not clear which administrative act was requested to be annulled with respect to the spouse and children, by what method each person acquired citizenship, and how representation authority was established regarding minors, it was decided to reject the petitions.

The fundamental conclusion demonstrated by these decisions is this: Although citizenship status is an act affecting family members, the legal standing, standing to sue, manner of acquiring citizenship, and claims of each family member must be determined separately.

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Statute of Limitations to File a Lawsuit Against an Annulment or Revocation Decision

Revocation, forfeiture of citizenship or rejection of citizenship application; are individual administrative acts established based on public authority. Lawsuits to be filed against these acts are, as a rule, within the jurisdiction of the administrative judiciary.

Pursuant to Article 2 of the Administrative Litigation Procedure Law (İYUK) No. 2577, persons whose interests have been violated may file an annulment lawsuit on the grounds that administrative acts are unlawful in terms of authority, form, reason, subject, and objective.

Pursuant to Article 7 of the İYUK,, unless a different period is prescribed in a special law, the statute of limitations for filing a lawsuit in the administrative courts and the Council of State is sixty days. This period begins to run on the day following the written notification.

In calculating the filing period, the following points are particularly important:

• The date of service of the decision,
• The notification record in the electronic notification system,
• The date the decision was learned through e-Government or other electronic systems,
• Whether the notification was made in due form,
• When the administrative act was served with respect to each family member,
• The effect of an administrative application on the filing period.

Making an administrative application does not stay or restart the filing period in every case. Therefore, the remedy and time limit indicated in the text of the decision must be carefully examined.

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How to Determine the Competent and Authorized Court?

The competent and authorized judicial authority in citizenship proceedings is determined according to the nature of the authority issuing the act, whether the act is a Presidential decree, the role of the Ministry of the Interior or the Directorate General of Population and Citizenship Affairs in the act, and the judicial remedy instruction in the decision text.

Since a significant portion of citizenship proceedings are connected to the central administration organization, the jurisdiction or venue of the administrative judicial authorities in Ankara may come into question. However, it is not appropriate to draw a single general conclusion for every file in this regard. The issuing authority, the date of the act, the application information contained in the notification, and special jurisdiction rules must be evaluated together.

Mandatory mediation is not a condition precedent in annulment lawsuits concerning the revocation, withdrawal, or rejection of citizenship applications. This is because the essence of the dispute is not a private law claim, but the legality of an administrative act.

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Why Is the Request for Stay of Execution Important?

A decision to revoke or withdraw citizenship may immediately and severely impact an individual's legal status. Civil registry records, passport procedures, residency status, employment life, family structure, children's education, real estate transactions, and commercial activities may be affected by this decision.

Pursuant to Article 27 of the İYUK two conditions must be met concurrently for a stay of execution to be granted:

• The administrative act being clearly unlawful,
• The execution of the act causing damages that are difficult or impossible to compensate.

Therefore, the request for a stay of execution is not structured in an abstract manner. The applicant's residency arrangement in Turkey, family ties, children's school enrollments, work permit or employment relationship, active commercial activities, investment documents, health status, and travel necessity must be demonstrated with concrete documents.

In the event of the rejection of a citizenship application, the assessment of damages that are difficult to compensate is conducted differently. The rejection act alone does not lead to the revocation of the residence permit or deportation in every case. Therefore, in the request for a stay of execution against the rejection decision, the direct effect of the rejection act on the applicant's current status must be explained.

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Which Documents Are Important in Citizenship Cases?

Subject Matter of the Dispute	Main Documents
Fulfillment of the investment condition	Certificate of conformity, official institutional correspondence
Genuineness of the real estate investment	Title deed record, official deed, sales contract, valuation report
Payment of the investment amount	Bank receipts, account statements, international wire transfer records
Legal status of the real estate	Encumbrance certificate, mortgage and pledge records, land registry office correspondence
Compliance with the non-disposal undertaking	Land registry annotation, current title deed record
Authenticity of the capital and employment investment	Trade registry, SSI declarations, bank records, certified public accountant report
Accuracy of application statements	Application form, passport, civil status documents, criminal record records
Insufficiency of the administration's justification	Cancellation or revocation decision, notification, administrative application and responses
Irreparable harm	Documents regarding residence, employment, school, family, health, and commercial activities

Relying solely on the title deed transfer in real estate investments is often insufficient. The source of payment, bank transactions, valuation process, relations with the seller, the transfer history of the real property, and encumbrances on the property may be evaluated together.

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Potential Defenses of the Administration and Legal Evaluation

1. “Naturalization is Within the State's Discretionary Power” Defense

Exceptional citizenship is an area associated with the sovereign powers of the state. It is accepted that the administration has a discretionary scope. However, discretionary power is not an unlimited authority that can be exercised outside legal boundaries or without concrete justification.

Whether the discretionary power has been exercised in compliance with the public interest and service requirements is subject to judicial review in terms of the elements of reason, subject matter, and objective of the administrative act. Council of State 10th Chamber, E. 2022/7637, K. 2025/3313, D. 26.06.2025 numbered decision also demonstrates that the facts forming the basis for the revocation of citizenship must be concrete and verifiable.

2. “The Investment Was Not Actually Made” Defense

This defense may be asserted on the grounds that the investment amount was not actually paid, the value of the real estate was artificially inflated, or the transactions were collusive. In such cases, the conformity certificate, title deed record, and banking documents are examined not individually, but in terms of their material consistency with one another.

The applicant's defense must be supported by the official valuation report, the payment chain within the banking system, title deed documents, and tax and commercial records. The harmony of dates, amounts, and parties among the documents is crucial in demonstrating that the investment possesses genuine economic substance.

3. “Material Information Was Concealed” Defense

This allegation, TVK art. 31 forms the basis of the annulment proceedings within the scope of. The administration must determine what the concealed information is and why it affected the citizenship decision.

It is important for the applicant to make a separate assessment regarding each piece of information put forward by the administration. It must be investigated whether the information actually exists, whether it gave rise to a disclosure obligation as of the application date, whether the applicant knew this information, and whether the citizenship decision was affected by this information.

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Frequently Asked Questions

1. Can Turkish Citizenship Acquired Through Investment Be Revoked?

Yes. TVK art. 31 false statements or concealment of material facts within the scope of; TVK art. 40 within the scope of, however, if it is understood that the citizenship decision was granted without the legal conditions being met, or that it was granted duplicatively or by mistake, annulment or revocation proceedings may come to the agenda.

2. Why is the Citizenship of a Person Who Purchased Real Estate Subsequently Revoked?

If it is alleged that the real estate investment was not actually made, that the sale price was not paid, that the valuation or payment documents are forged, that the investment conditions were not met as of the application date, or that the transaction is collusive, the revocation process may be initiated.

3. Does Obtaining a Certificate of Conformity Absolutely Protect Citizenship?

No. The Certificate of Conformity is significant evidence; however, other conditions of the citizenship application, the accuracy of the statements, and the evaluation of national security and public order may be separately examined.

4. Are Annulment and Revocation of Citizenship the Same Thing?

No. Annulment is predominantly based on false statements or the concealment of material information. Revocation, on the other hand, is based on the claim that the citizenship decision was granted without the legal conditions being met, or that it was granted duplicatively or by mistake.

5. What is the Period of Limitation to File a Lawsuit Against a Citizenship Revocation Decision?

Unless otherwise provided by a special regulation, pursuant to Article 7 of the İYUK, the filing period is 60 days starting from the day following the written notification.

6. Can a Stay of Execution Be Requested in a Citizenship Cancellation Lawsuit?

Yes. A stay of execution can be requested if it is demonstrated with concrete documents that the administrative act is clearly unlawful and that its enforcement would cause damages that are difficult or impossible to compensate.

7. Does the Revocation of Citizenship Affect the Spouse and Children?

It may affect them. However, how the spouse and children acquired citizenship, whether the decision applies to them, and whether a lawsuit will be filed for each individual must be evaluated separately.

8. How Is a Citizenship Cancellation Lawsuit Filed on Behalf of Children?

When filing a lawsuit on behalf of minor children, custody or representation authority must be clearly indicated. The petition must state the child's identity, the manner in which citizenship was acquired, how they are affected by the act, and the claim relief in a manner that leaves no room for ambiguity.

9. Can a Decision to Reject Citizenship Based on National Security Grounds Be Subject to Litigation?

Yes. Rejection acts established on the grounds of national security and public order are of an administrative nature and are subject to judicial review. The court examines whether the act is based on concrete facts and whether its grounds are subject to judicial review.

10. Which Documents Must Be Submitted in a Citizenship Cancellation Lawsuit?

Certificate of conformity according to the investment type, title deed and valuation records, bank receipts, account statements showing the payment chain, trade registry and SGK records, application documents, cancellation or revocation decisions, and family, education, residence, and commercial activity documents demonstrating damages that are difficult to compensate must be submitted.

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Conclusion

The revocation and cancellation of Turkish citizenship through investment is not a dispute that can be resolved solely by whether the investment amount has been met. The review requires the joint assessment of the true economic substance of the investment, the accuracy of the application declarations, the statutory provision on which the administrative action is based, the concreteness of the security assessment, and the impact of the decision on family members.

In actions for the revocation of citizenship, the administration must act not upon abstract suspicions, but upon sufficient, verifiable material facts connected to the individual. For the applicant, establishing the complete documentary chain proving the authenticity of the investment, directly responding to each allegation of the administration, preserving the statutory limitation period for filing a lawsuit as of the date of notification, and clearly formulating the claims regarding family members are of decisive importance.

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About Us – Contact Information

Atty. Batın YILMAZ

Bar Association Information:

• Istanbul Bar Association No. 1: 77008
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