Change of employer regarding work permits, does not take place by transferring the existing work permit card to the new employer. A timed work permit tied to a specific employer is issued for a specific employer, workplace, job, and in most cases, address. In order for a foreign national to work for a different real or legal person, a new work permit application must be submitted by the new employer and this application must be approved.

Although the application for transitioning to a different employer is referred to in daily practice as a "work permit transfer," it is legally neither an automatic transfer nor a permit extension. Pursuant to the International Labour Law No. 6735 and the Regulation on the Implementation of the International Labour Law, the application made to work under a different employer, according to the initial application procedures and principles is evaluated. Therefore, the ongoing validity of the former work permit card does not grant the foreigner the right to start working at the new workplace.

In case of an employer change, it is necessary to jointly plan the termination of the former employment relationship, the notification to the Ministry, the determination of whether the new application will be made from within or outside the country, the evaluation criteria of the new employer, and the residence status of the foreigner. For the general structure of work permits our foreign work permit guide you may review.

Short Answer: Employer Change in Work Permits

Question	Short answer
Can the existing permit be transferred to the new employer?	No. Dependent work permits are tied to the employer and the scope of the permit.
Does the new employer make an extension application?	No. An application for a different employer is subject to the initial application procedures and principles.
Can one work at the new workplace once the application is filed?	No. Actual work must not commence before the new work permit is granted.
Must the termination of the former employment relationship be reported?	Yes. The 15-day statutory notification obligation must also be fulfilled.
Does SGK deregistration replace the Ministry notification?	No. Employment and social security transactions and the e-Permit notification are separate obligations.
Is it necessary to leave Turkey upon every employer change?	No; however, the right to apply from within the country and the legal residence status must be verified on a case-by-case basis.
Is a transfer to another branch of the same company also considered a new employer?	Not always. If the legal entity is the same, the provisions of the Regulation regarding branch or assignment changes may apply.

What Does "Work Permit Transfer" Mean?

Regarding dependent work permits, the legislation does not provide for an independent "transfer" mechanism that allows a work permit issued for one employer to be transferred directly to another employer. The term used in practice refers to the foreigner leaving their former job and obtaining a work permit through a new employer. Legally, the process consists of the termination of the former employment relationship and its associated permit status, followed by a new work permit application.

This distinction is not merely terminological. If a transfer is assumed to be an extension, the new employer may overlook the conditions of employment, financial adequacy, salary, professional competence, and pre-approval that would be examined in an initial application. Furthermore, the right to continue working for up to 90 days under certain conditions while the application is being evaluated—granted in actual extension applications with the same employer—cannot be exercised in the case of a new employer if the job and workplace have changed.

Employer Change Is Not an Extension Application

Article 10 of Law No. 6735 stipulates that the initial definite-term work permit may be issued for a maximum of one year to work in a specific workplace and for a specific job, not exceeding the duration of the employment or service contract. For the first extension with the same employer, a permit for a maximum of two years may be granted, and for subsequent extensions, a maximum of three years. Conversely, applications made to work under a different employer are evaluated within the scope of an initial application.

Therefore, the fact that a foreigner has a two- or three-year work permit with a previous employer does not mean they will obtain a permit for the same duration from the new employer. In applications involving a new employer, the permit duration is determined within the framework of initial application rules and by taking into account the duration of the employment contract. For the conditions regarding the extension of duration with the same employer, work permit extension application you can review our article.

Proceeding	Employer	Nature of the application	Working while the application is pending
Extension of the permit period with the same employer	Unchanged	Application for permit extension	It may continue under statutory conditions for a maximum of 90 days.
Transition to a different employer	Changes	Procedures and principles for the initial application	Employment with the new employer cannot commence before a new permit is granted.
Branch or assignment change with the same employer	Legal entity remains unchanged	Application for modification pursuant to Article 26 of the Regulation	Ministry approval and the scope of the permit shall apply.
Change of employment by the holder of an indefinite work permit	Subject to change	It differs from the employer-bound fixed-term permit regime.	The notification obligation must be observed prior to commencing new employment.

How is the Employer Change Process Carried Out?

1. Determination of the Manner of Termination of the Former Employment Agreement

The employment relationship may be terminated by resignation, employer termination, expiration of a fixed-term contract, mutual termination (ikale), or another legal ground. The existence of a work permit for the foreign national does not eliminate the termination rules arising from Labor Law No. 4857 and the employment agreement. Notice periods, severance and notice compensation, unused annual leave, wages, and overtime claims are evaluated separately based on the specific circumstances of the case.

To securely manage the employer change, the date of termination or resignation and the foreign national's actual last working day must be clearly documented in the same file. Inconsistencies between the date on the SSI (SGK) termination declaration, the e-Permit notification, the employment agreement, and any notary public notices may complicate the review of the new application.

2. Fifteen-Day Ministry Notification is Made

Pursuant to Article 22 of Law No. 6735, employers employing foreign nationals and foreign nationals holding independent work permits are obligated to notify the Ministry within 15 days of the commencement or termination of work, and of any matters requiring the revocation of the work permit. The former employer must timely complete the process regarding the termination of the employment relationship via the e-Permit system.

This notification is not the same process as the SSI (SGK) employment termination declaration. The SSI notification arises from social security legislation, whereas the Ministry notification arises from international labor legislation. The fulfillment of one does not imply that the other is automatically completed. Furthermore, there is no "15-day waiting period"; this timeframe indicates the deadline by which the notification must be made at the latest.

3. Verification of the Foreign National's Legal Stay and In-Country Application Status

In order for the new application to be made from within the country, the foreign national's legal status as of the application date and eligibility for application in the system must be checked. According to the Ministry's general statements, for in-country applications, an application may be filed by the employer for foreign nationals who hold a residence permit issued for at least six months in Turkey and valid as of the application date; certain foreign nationals determined by the General Directorate may apply without a valid residence permit.

Although a valid work permit generally replaces a residence permit, the termination of the former employment relationship, the timing of the cancellation record, and whether the foreign national holds an additional residence or protection status may affect how an in-country application is processed. Therefore, the assumption that "my previous work permit card is still valid, so I can definitely apply from within the country" should not be automatically drawn. If in-country requirements are not met, the out-of-country application procedure through the Turkish diplomatic mission in the country where the foreign national is a citizen or legally resides comes into question.

4. The New Employer Completes the E-Permit Application

The dependent work permit application is submitted by the new employer who will employ the foreign national or by a person authorized in the electronic system. The employer's e-Government account, electronic signature authority, workplace registration, and application details must be up to date. Depending on the type of file, the employment contract, the foreign national's passport, documents evidencing qualifications, and the employer's financial and commercial documents are submitted during the application. For a detailed checklist, documents required for foreign work permit you may review our guide.

The inclusion of documents demonstrating the termination of the former employment relationship in the employer change file becomes important, particularly if there are discrepancies among system records. However, the same documents are not required for every file. The foreign national's profession, educational status, sector, pre-permit requirement, and the legal nature of the employer may alter the document list.

5. Ministry Decision is Awaited and Post-Permit Procedures are Carried Out

The evaluation of duly submitted applications with complete documents is completed within 30 days in accordance with the Ministry's announcements; if additional information or documents are requested, the period runs from the completion of the request through the system. The upload of the application to the system or the generation of a tracking number does not mean that the foreign national may start working for the new employer.

Actual work at the new workplace must commence after the work permit is granted and taking into account the validity start date of the permit. The delivery of the card by cargo should not be regarded solely as the constitutive element of the right to work; the positive decision in the system, the permit start date, and social security obligations must be checked collectively. For permits issued from within the country, the foreign national must start working by fulfilling social security obligations within one month from the permit start date.

What Criteria Must the New Employer Meet?

Since the application for transition to a different employer is subject to initial application rules, the Ministry evaluates the new employer independently. The fact that the previous employer met the criteria does not exempt the new employer. The review covers employment, financial sufficiency, the wage to be paid to the foreign national, the nature of the work, the qualifications of the foreign national, and sector-specific conditions, if any. For current figures and exemptions, work permit evaluation criteria 2026 you may review our article.

Employment and Financial Sufficiency Criteria

The fundamental rule for workplaces subject to the balance sheet system is the employment of at least five Turkish citizens for each foreign national. The operating workplace must also meet one of the predetermined capital, net sales, or export criteria. However, these rules are not absolute and without exception. The sector, the nature of the workplace, the status of the foreign national, and the special criteria published by the Ministry may alter the outcome.

In particular, pursuant to the general exemption entering into force on August 3, 2026, it is essential that employment and financial sufficiency criteria shall not be applied in in-country applications made on behalf of foreign nationals who have legally resided in Turkey under a work permit, residence permit, or international protection for at least one year within the last three years as of the application date, limited to a maximum of three foreign nationals at the same workplace. In addition, there are limits such as the number of foreign employees not exceeding the number of Turkish citizens and the general criteria being reapplied starting from the fourth foreign national. Therefore, both statements—"the new employer must definitely employ five Turkish citizens" or "no employer is subject to the five Turkish citizens requirement anymore"—are incomplete.

Wage Criterion

The gross salary indicated in the new employment contract cannot be below the minimum wage multiplier determined by the Ministry for the duties to be performed by the foreigner. Different rates apply for top-level executives, engineers, architects, other executives, jobs requiring expertise or mastery, and other positions. Determining the foreigner's title contrary to the facts merely to facilitate the application may result in discrepancies among the diploma, job description, salary, and actual duties. For current rates wage criteria for foreign employees you can review our article.

Prior Permit and Professional Qualifications

In fields such as education and healthcare, obtaining a prior permit from the relevant institution may be required. The fact that the foreigner has obtained a permit with the same title under a previous employer does not mean that the prior permit required for the new institution continues automatically. Furthermore, work permits cannot be issued in the name of a foreigner for professions reserved exclusively for Turkish citizens. Even if the new assignment is identical to the previous one, it does not eliminate these checks.

What Happens to the Previous Work Permit?

A fixed-term work permit is tied to the employer indicated on the permit document. The termination of the former employment contract may constitute a ground requiring the cancellation of the permit within the scope of Article 15 of Law No. 6735. Registration and cancellation procedures in the Ministry's system are completed in due form. Therefore, neither of the two extreme interpretations—namely, 'the card legally ceases to exist the second the resignation letter is submitted' or 'it remains valid everywhere until the date on the card expires'—is safe.

What is definitive is that the permit tied to the former employer cannot be used with the new employer. Even if the validity date on the old permit card continues, the foreigner actually working under the command and organization of the new company may be deemed as working outside the scope of the permit. For detailed information on the termination and cancellation grounds of the permit The termination of the former employment relationship, the employer's notification obligation, and the cancellation of the existing work permit are interrelated yet distinct procedures. For cancellation grounds, the 15-day notification period, and the effect of permit cancellation on the right of residence revocation of work permit 2026 you may review our guide.

Can One Work Before the New Application is Concluded?

No. The new employer making an application, uploading documents to the system, waiting for the fee notification, or having the file appear under evaluation does not grant the right to work on its own. Under Law No. 6735, the foreigner must hold a valid work permit or exemption before commencing work in Turkey.

There is a specific rule regarding timely extension applications made with the same employer, allowing continued work for a maximum of 90 days following the expiration of the permit period, provided that the job and workplace remain unchanged. If the employer has changed, this rule cannot be applied with respect to the new employer. The employer should not assume that opening an SSI (Social Security Institution) registration or employing the individual for a few trial days prior to the issuance of the new permit will eliminate the violation.

Consequences of Working for a New Employer Without Authorization

Administrative Fines for the Employer and the Foreigner

Administrative fines may be imposed separately on the foreigner working without a valid permit and on the employer employing them. The breach of the notification obligation may also entail separate sanctions. Since administrative fines vary annually based on the re-valuation rate, rather than memorizing fixed amounts in the article, the Ministry table applicable as of the audit date should be checked.

Notification to the Migration Management and Deportation Risk

Foreigners found to be working without a work permit are reported to the Ministry of Interior for deportation. However, this notification and the deportation decision are not the same procedure. A deportation decision is separately enacted and served by the competent authority by evaluating the foreigner's status pursuant to Law No. 6458. If such a decision has been issued regarding the foreigner deportation decision and annulment lawsuit special time periods regarding this matter must be tracked separately.

Employment Claims and Work Accidents

The lack of a work permit does not automatically nullify the work actually performed and all kinds of employment rights. Wages, working hours, occupational health and safety, and the nature of the work accident are examined in accordance with separate legal rules. In the decision of the 10th Civil Chamber of the Yargıtay, dated December 6, 2023, and numbered E. 2023/10744, K. 2023/12501, an evaluation was also made regarding the determination of the incident experienced by a foreigner without a work permit and SSI notification at the workplace as a work accident. This precedent demonstrates that unauthorized employment does not automatically exempt the employer from work accident and social security liability.

Employing a foreigner with a new employer before the new work permit application is finalized may lead to administrative sanctions for both the employer and the foreigner. For current penalty amounts and other consequences penalty for employing unauthorized foreigners 2026 you may review our guide.

Transfer to Another Branch of the Same Employer

The transfer to another branch belonging to the same legal entity must be distinguished from the transition to a legally different company. According to Article 26 of the Implementing Regulation, in order for a foreigner to work in a different position at a workplace belonging to the same employer or in another branch of the employer in the same line of business, the change request must be submitted by the employer to the Ministry via the system. It is required that the new branch is registered in the employer's trade registry, that the new position meets the necessary conditions, and that the application is approved by the General Directorate.

In the event of an approved change regarding a branch in another province, the permit document may be renewed by the Ministry. Therefore, it is not correct to view a branch change belonging to the same employer as a simple human resources decision requiring no procedures. Especially if the new position requires a prior permit or professional qualification, the scope of the existing permit may not be sufficient.

Change of Duties, Title, or Profession

Even if the employer remains the same, the foreigner's duties may change. If the change is similar and compatible with the current job, a change application can be submitted to the Ministry via the system with the required documents. However, if the new task requires a different professional qualification, diploma, or prior permission from a public institution, the simplified change conditions of the Regulation may not be met.

For instance, the actual execution of engineering services by a foreigner permitted as a marketing specialist cannot be regarded merely as an intra-company title change. The wage criteria, diploma, and professional legislation must be re-examined. We will elaborate on this issue further in the article titled “Workplace, Duty, or Profession Change” in our upcoming content plan.

Does the Transfer of a Company or Workplace Constitute a Change of Employer?

The transfer of company shares and the change of the employer's legal entity are not the same thing. Even if the partners of a joint-stock or limited liability company change, as long as the company's trade registry number and legal personality continue, the employer on the work permit is not always considered to have changed. However, in cases of company mergers, demergers, workplace transfers, or the transfer of activities to another legal entity, the identity of the actual employer must be examined in detail.

Title changes, address changes, and legal entity changes should not be subjected to the same procedure. The old permit should not be utilized solely based on the fact that companies belong to the same group without comparing the trade registry gazettes, tax number, SSI workplace registry, and work permit record. Even if two companies within a holding are economically connected, if they are separate legal entities, they are, as a rule, different employers.

Change of Employer by an Indefinite Work Permit Holder

An indefinite work permit differs from a timed work permit tied to a specific employer. A foreigner holding an indefinite permit may work for one or more employers or engage in independent activities, provided that they comply with the relevant occupational legislation and fulfill the notification obligation before starting to work at a new workplace. Therefore, the rule of “a new dependent permit for a new employer” in timed permits does not apply in the same manner to the holder of an indefinite permit.

Nevertheless, an indefinite work permit does not grant the foreigner the right to practice professions reserved exclusively for Turkish citizens; obligations regarding social security, taxes, professional chambers, and labor law continue. The rule of notifying the Ministry at least 10 days before starting to work at the new workplace must also not be disregarded.

For detailed information on whether the indefinite work permit is contingent upon the employer, the rights it grants, the eight-year period requirement, and document renewal procedures indefinite work permit 2026 you may review our guide.

How Does a Change of Employer Affect Residence Rights?

As a rule, a valid work permit replaces a residence permit. If the foreign national’s sole legal basis for stay in Turkey is the former work permit, the termination of the employment relationship and the associated permit also poses risks regarding their residency status. The application by the new employer should not be interpreted as granting the foreign national an automatic and unlimited right of residence during the application process.

The foreign national may additionally hold a valid residence permit, international protection application, temporary protection registration, or another legal basis for stay. Furthermore, work permits issued to international protection applicants, conditional refugees, and foreigners under temporary protection do not replace a residence permit. Therefore, the residence status cannot be determined in a single sentence merely by looking at the work permit card.

Before the previous permit is revoked, whether the domestic conditions for the new application have been met and the timeline between the two transactions must be planned. However, showing a terminated employment relationship as ongoing in a misleading manner solely to make a domestic application also creates legal risks. For the general relationship between a work permit and residence, can a work permit be obtained without a residence permit? you may review our article.

What Can Be Done If the New Employer's Application Is Rejected?

The rejection of a work permit application made on behalf of the new employer does not confer the right to work at the new workplace with the former permit. The grounds for rejection may include employer criteria, salary, documents, professional qualifications, preliminary authorization, public order, or another reason. An appeal against the rejection decision can be filed via the e-Permit system within 30 days as of the notification date. In case the appeal is rejected, the administrative judiciary is available.

The appeal does not automatically stay the rejection procedure and does not grant the right to work with the new employer. If the ground for rejection can be remedied, it is also possible to make a new application; however, it must also be verified whether the foreign national’s right to an in-country application and legal status of stay continue at that date. For reasons of rejection rejection of the work permit application you can review our article.

Required Documents for Change of Employer

Although the document list varies depending on the sector and the status of the foreign national, the following documents are significant in practice:

The foreign national’s valid passport or document replacing a passport,
Biometric photograph complying with the application requirements and foreign identification information,
The employment or service contract signed with the new employer,
Diploma, professional qualifications, and translation/approval documents if required,
The preliminary permit document from the relevant institution in areas requiring a preliminary permit,
The new employer's trade registry gazette, balance sheet, income statement, and capital documents,
Up-to-date SGK records showing the workplace and employee numbers,
The resignation, termination, mutual termination (ikale), or expiration document showing that the previous employment contract has ended,
SGK employment termination declaration and Ministry notification record,
Documents regarding residence, work, or protection status upon which the domestic application is based,
Additional documents explaining the job description, wage, and occupation code,
Other information and documents requested by the Ministry specific to the file.

Most Common Mistakes in Practice

Assuming the change of employer is a transfer of the work permit card or a simple extension.
Thinking that work can be continued at the new workplace because the dates on the old work permit card are still ongoing.
Starting to work de facto under the guise of a probationary period before the new application is concluded.
Applying the 90-day work opportunity provided for extensions with the same employer to a different employer.
Assuming that the SGK termination notification also completes the Ministry notification.
Failing to notify the Ministry of the termination of the former employment relationship within 15 days.
Failing to verify the right to apply domestically and the legal basis for the foreigner's residency.
Failing to examine the new employer's compliance with the five Turkish citizens requirement, financial sufficiency, or current exemption conditions.
Failing to verify whether the salary in the assignment and the contract complies with the Ministry's wage criteria.
Accepting the prior work permit belonging to the former employer as sufficient for a profession requiring a pre-permit.
Mistaking separate legal entities within the same corporate group for a single employer.
Executing a branch transfer without making an application to the Ministry.
Assuming that the right to work continues automatically upon appealing a rejection of the application.
Treating the work permit revocation and the deportation decision as a single administrative act.

Change of Employer Checklist

Check	Why is it important?
Was the legal entity of the former and new employer compared?	Distinguishes between an employer change and a branch change.
Have the final employment and termination dates been documented?	Determines the timing for notification and residence.
Has the 15-day e-Permit notification been made?	Fulfills the statutory notification obligation.
Was the SSI (SGK) termination processed with the correct date and code?	Prevents contradictions in social security records.
Is there a right to apply domestically?	Prevents the rejection of the file due to an incorrect application type.
Does the new employer meet the current criteria?	Required for the review of employment and financial sufficiency.
Can the 2026 criteria exemption be applied?	It may change the outcome with respect to the first three foreigners.
Are the salary, title, and diploma compatible?	Prevents rejections based on salary and professional qualifications.
Is a preliminary permit required?	It may be mandatory in fields such as healthcare and education.
Was work initiated before the new permit was granted?	Prevents penalties for unauthorized employment.
Has the residence or protection status of the foreigner been examined?	Determines the risk of unlawful stay between the two permits.

Frequently Asked Questions

Can a foreigner with a work permit work for any employer they choose?

No. A definite and dependent work permit is valid for a specific employer, workplace, and job scope. A new work permit is required to work for another employer.

Is a change of employer considered an extension application?

No. An application to work with a different employer is evaluated according to the procedures and principles of the initial application.

Can the foreigner submit the new application themselves?

Dependent work permit applications are completed via e-Permit by the employer who will employ the foreigner or by an authorized person in the system.

Can employment begin before the new permit is issued?

No. The submission of the application or the fact that it is under review does not confer the right to work. Working for the new employer must commence only after the permit is granted and the permit start date is verified.

If the validity period of the old permit card is still ongoing, can it be used for the new job?

No. The card is tied to the previous employer and the scope of the permit. The remaining validity period does not grant the right to work with a different employer.

What is the deadline for notification by the former employer?

The termination of employment and circumstances requiring the cancellation of the permit must be reported to the Ministry within 15 days. The SGK (Social Security Institution) termination notification must also be made separately.

Is it mandatory to leave Turkey when changing employers?

It is not mandatory in every case. However, if the requirements for an in-country application are not met, an out-of-country application may be required. The foreigner's valid residence, work permit, or protection status must be concretely verified.

Is the new employer required to employ five Turkish citizens?

The employment of five Turkish citizens is a fundamental criterion; however, with the general exemption dated August 3, 2026, there may be other exemptions specific to the sector and the status of the foreigner. The current criteria for the new employer must be examined on a case-by-case basis.

Is a new permit required when transferring to another branch of the same company?

If the legal entity remains the same and the conditions set forth in Article 26 of the Regulation are met, an application for a branch or duty change can be made. This should not be considered a simple transfer without formalities; the approval of the Ministry must be obtained.

Is a transition to another company within the same holding considered a branch change?

As a rule, no. If group companies have separate legal entities and employer registrations, it constitutes a different employer, and a new work permit must be obtained.

Can an appeal be filed if the new employer application is rejected?

Yes. An appeal can be filed with the Ministry via the system within 30 days from the notification of the rejection decision. In case the appeal is rejected, legal recourse to the administrative judiciary may be sought.

Does a change of employer cause the work permit to be revoked?

The termination of the former employment relationship may constitute grounds requiring the cancellation of the existing permit. However, the date and procedure of the cancellation process in the system must be separately monitored. Under no circumstances does the old permit automatically transfer to the new employer.

Can a holder of an indefinite work permit change employers?

Yes. An indefinite work permit is not tied to a specific employer. Nevertheless, prior to commencing new employment, notification must be made to the Ministry, and SGK (Social Security Institution) and professional legislation obligations must be fulfilled.

Official Sources

Conclusion

Changing employers in a foreign work permit does not mean transferring the existing permit card to the new employer. A new work permit application is made subject to the procedures and principles of an initial application on behalf of a different employer. The termination of the former employment relationship and the 15-day Ministry notification, SSI deregistration, the foreigner's residence status, the right to apply domestically, and the new employer's evaluation criteria must be planned within the same calendar.

Working de facto with a new employer before a new work permit is granted may lead to administrative fines for both the foreigner and the employer, notification to the Directorate General of Migration Management, and other legal consequences. Even when transitioning to a branch or a similar position of the same company, the Regulation's modification procedure must not be disregarded. For other information in the field of immigration and aliens law, our immigration law service page you may review.

Author Information

Attorney Batın YILMAZ
Istanbul Bar Association Bar Registry No: 77008

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