What to Do If You Receive a Notice from the Land Registry Office Stating "Have a Control Report Prepared, Otherwise Your Citizenship Will Be Revoked" for Citizenship Revocation Purposes?

A notice with the following content may be sent by the land registry office to an individual who has acquired Turkish citizenship by purchasing real estate: That a control report must be commissioned within one month for the real estate subject to the acquisition of citizenship, failing which citizenship will be revoked.

Naturally, the first question asked by a person who receives such a notice is: "Has my citizenship been revoked?"

No. A notification requesting a control report and mentioning a potential revocation does not, in and of itself, mean that Turkish citizenship has been revoked. However, the letter indicates that the real estate forming the basis of the citizenship application is being re-examined by the administration. Due to the specified deadline and the stated consequence, it must be addressed without delay.

In this article, we explain the meaning of the control report notification, which questions should be directed to the administration, which documents in the initial investment file will be examined, and which legal issues will come to the agenda if a revocation or annulment decision is actually issued.

What Does the Control Report Notification from the Land Registry Office Mean?

In a notification we reviewed, the land registry office, based on the letter received from the regional directorate, stated that for the real estate used in the acquisition of citizenship, having a control report prepared within one month demands. The notice states that failure to do so will result in the revocation of citizenship.

This text suggests that the administration is conducting a re-examination of the investment file. However, it is not possible to determine the exact reason for the review solely by looking at the notification. Specifically, the following questions need to be answered:

• Which immovable property or properties is the administration examining?
• What exact document is meant by the "control report"?
• Through which procedure and via which institution will the report be obtained?
• Has a concrete discrepancy been identified in the initial valuation report or in the determination of the investment amount?
• Is the issue related to the nature of the real estate, the sale price, payment documents, or another record?
• Whether the administration revocation of citizenship, or withdrawal evaluating?

It should not be assumed that obtaining a new appraisal report from any company before learning these answers will satisfy the request in the notice. First, the regional directorate letter and the initial citizenship file upon which the land registry office relies must be reviewed.

Those who wish to learn how real estate acquisition for citizenship is evaluated at the initial application stage, can review our guide on Turkish citizenship by investment in Turkey . The official statement of the General Directorate of Land Registry and Cadastre regarding the acquisition of citizenship also includes the stages concerning the title deed transaction, payment documents, and the determination of the investment amount.

Does Requesting a Control Report Mean That Citizenship Has Been Revoked?

No. Requesting a document, issuing a warning regarding a potential outcome, and the final decision revoking citizenship are distinct stages.

Article 31 of the Turkish Citizenship Law No. 5901 31. maddesi, governs the revocation of the decision on the acquisition of citizenship in the event that it was granted as a result of the person's false statements or concealment of essential matters forming the basis for the acquisition of citizenship. Article 40 of the same Law 40. maddesi, regulates the revocation of citizenship in the event that it is subsequently understood that the decision regarding the acquisition or loss of citizenship was rendered without the legal conditions being met or concurrently. The legal bases of these two procedures are different. The text of the Turkish Citizenship Law No. 5901 is the starting point of this distinction.

Therefore, the statement in the notification reading 'if the report is not commissioned, the citizenship shall be canceled' does not mean that citizenship will automatically terminate automatically at the end of the one-month period. The concrete determinations of the administration, the applied statutory provision, and the decision to be rendered subsequently must be evaluated separately.

We have discussed the differences between cancellation and revocation, their consequences, and the litigation process revocation and cancellation of Turkish citizenship in detail in our article.

Why Is Real Estate Investment Re-examined Later?

In citizenship by real estate investment, not only the sales price appearing on the title deed is considered. The sales transaction, payment records, value of the real estate, determination of the investment amount, and other documents used in the citizenship file constitute a whole.

The administration may wish to re-examine the accuracy of the real estate information in the previous report, the valuation method, or the consistency among documents in a file. However, these are merely potential subjects of examination. It cannot be stated definitively which issue exists in the file of the person who received the notification without reviewing the relevant administrative correspondence.

The procedures regarding valuation reports have also changed over time. The General Directorate of Land Registry and Cadastre's General Circular No. 2024/2 on valuation reportssets forth the procedures and authority concerning reports issued for citizenship purposes. However, in the review of a previously completed real estate acquisition, the acquisition date and the rules applicable at that time must also be evaluated. It cannot be automatically assumed that the new report issuance procedure applies to a prior file.

Does the Prior Issuance of a Certificate of Conformity Prevent Review?

The certificate of conformity is an essential part of the initial citizenship process. However, the issuance of this certificate does not mean that no information or document in the application file can be subsequently reviewed.

Conversely, the possibility of a re-examination does not imply that the administration can invalidate its previous conformity assessment without justification . It must be concretely demonstrated which factual data in the file has changed or why any initial determination is considered erroneous.

How Should the One-Month Period Be Monitored?

The issue date on the notification and the addressee the date of service may be different. Therefore, the letter itself along with the envelope, return receipt (tebliğ mazbatası), or electronic notification record must be retained.

The start and end dates of the one-month period must be calculated based on the specific service of process. Since preparing the report may take time, the first step should not be left to the final day.

It is essential not to confuse two separate periods here:

1. Period granted in the notification: The period specified in the letter for obtaining the control report or responding to the administration's request.
2. Statute of limitations for filing a lawsuit / Litigation period: The period to resort to legal remedies against an action if a definitive and executory cancellation or revocation decision is issued in the future.

It may not be accurate to calculate the litigation period by treating the letter requesting the control report as the same administrative act as a final citizenship decision that may be issued later.

What Documents Should the Recipient of the Notice Collect?

The file used for the initial citizenship application should be compiled as completely as possible. The following documents are particularly important:

• The notification requesting the control report and the service record;
• The regional Directorate letter referenced in the notification;
• Current and historical title deed records of the real estate properties forming the basis of citizenship;
• Official sales deed or contract for sale;
• Initial valuation report and its annexes, if any;
• Bank receipts and payment transactions;
• Foreign exchange purchase document, if used in the transaction;
• Document regarding the investment amount or eligibility;
• Title deed record regarding the undertaking not to sell for three years;
• Citizenship acquisition decision and application documents of family members.

When these documents are read together, the administration's re-examination at which stage what it targets can be determined more accurately. For example, focusing solely on a new valuation report will not resolve the issue if the actual dispute relates to payment records.

What Explanations Should Be Requested in Writing from the Administration?

If the type and methodology of the report are not clear in the notification, clarification can be requested by submitting a registered petition to the relevant Land Registry Directorate. The petition should specifically inquire about the following issues concretely:

"We kindly request to be informed of the type, scope, and properties included in the requested control report, through which procedure and authorized institution it will be obtained; the concrete deficiency identified in the initial citizenship file, and the official letter underlying the request."

A copy of the petition along with the application registration number or receipt must be retained. Requesting clarification does not mean that the granted one-month period automatically stops or is extended. Therefore, the request for clarification and the necessary steps for the report must be pursued simultaneously.

What Happens If the Report Cannot Be Obtained Within One Month?

The failure to complete the report within the deadline is significant; however, the legal consequence of this does not apply identically to every file. First, the reason why the report could not be obtained must be determined.

Even though an application has been filed, if the report has not been issued, the application record, correspondence, and the reason for the delay must be preserved. If the administration has not explained how to apply for the report, this situation should also be documented through a written application. Actions taken and obstacles encountered before the expiration of the deadline must be reported to the relevant directorate.

The purpose here is not merely to state "we request an extension." It is to demonstrate which concrete steps have been taken to fulfill the procedure requested by the administration and to ensure the clarification of ambiguous matters.

Is a Discrepancy in the Valuation Report Considered Directly a False Statement?

Every discrepancy does not directly constitute a false statement. If the value in one report differs from that of a subsequently prepared report, the report dates, the methodology used, the characteristics of the immovable property at that time, and the data in the report must be examined.

If the revocation of citizenship is based on Article 31 of Law No. 5901, the administration must substantiate which statement is contrary to the truth or and which material information was concealed. If the withdrawal of the citizenship decision is based on Article 40, it must be explained which legal condition was not met at the time the decision was rendered. We further explain the effect of this discrepancy on litigation preparation in our guide on the revocation and withdrawal of citizenship. revocation and withdrawal of citizenship guide we explain separately.

Are the Citizenship Rights of Spouses and Children Affected?

The answer to this question depends on the legal path through which family members acquired citizenship and the nature of the issued administrative act. and the nature of the transaction performed.

Article 32 of Law No. 5901 stipulates that the revocation decision shall also apply to the spouse and children who acquired citizenship through the principal applicant. Therefore, examining only the investor's documents may not be sufficient. The citizenship decisions and application files of the spouse and children must also be reviewed individually.

For an example of how a child's legal status can produce different outcomes in a citizenship application the age of the child in the citizenship application you may review our article.

Can a Lawsuit Be Filed If a Final Annulment or Revocation Decision Is Issued?

Following the review report letter, if an additional revocation of citizenship or withdrawal of the citizenship decision proceeding is established and served, the grounds for the decision and the judicial remedy must be evaluated. Application to the administrative judiciary for the annulment of the proceeding and, if conditions are met, a request for a stay of execution may come into question.

pursuant to the Administrative Procedure Law No. 2577, the general statute of limitations (filing period) for administrative lawsuits where no special period is prescribed is is 60 days. However, which document constitutes the final administrative act subject to litigation and from which notification the period begins must be determined in the specific case file. the official legislation page where Law No. 2577 is published is the source of this general procedure.

Here, additionally rejection of the application with subsequent revocation of acquired citizenship must be distinguished. If the person has not yet acquired citizenship and their application has been rejected, a different procedure applies. For this matter Rejection of Turkish citizenship application our article may be reviewed.

Frequently Asked Questions

Does the official letter from the Land Registry Office indicate that my Turkish citizenship has been revoked?

A letter requesting an audit report and containing a warning regarding the possibility of revocation does not constitute a final revocation decision on its own. The legal basis of the letter and the subsequent decisions must be examined separately.

Does the statement "If you do not have the report prepared within one month, your citizenship will be revoked" produce definitive legal consequences?

This statement serves as a serious warning; however, it does not inherently mean that citizenship will automatically terminate upon the expiration of the deadline. It must be determined upon which legal grounds and concrete findings the administration has based its action.

Can I obtain a report from any appraisal company?

This conclusion cannot be reached based on the term "audit report" in the notification. The scope of the requested report, the application channel, and the authorized issuing institution must be ascertained in writing from the relevant administration.

Can the file of a person who has obtained a certificate of conformity be re-examined?

It is possible for the file to be re-examined. However, if a decision affecting citizenship is to be made as a result of the review, the legal basis and concrete justification of the action shall be evaluated separately.

If the three-year non-resale period has expired, does it mean there are no longer any risks regarding citizenship?

The expiration of the non-sale commitment period and the accuracy of the documents used in the citizenship application, as well as the conditions of the investment at the initial date, are distinct matters. A definitive answer cannot be provided without reviewing the specific allegations.

Does requesting clarification from the administration suspend the one-month period?

It should not be assumed that a request for clarification automatically suspends the limitation period. While making the application, the deadline stated in the notification must be tracked independently, and efforts made to obtain the report should be documented.

Conclusion: What Must Be Primarily Examined in This Notification?

The most critical issue in the audit report received from the Land Registry is to determine which real estate, for which concrete reason, and exactly which report the administration is requesting. Behind two notifications containing the same sentence, there may be different valuation reports, different acquisition dates, and different payment records.

Therefore, instead of providing a general explanation or obtaining an unspecified type of appraisal report within the one-month period, the notification, the underlying institutional correspondence, and the initial citizenship file must be examined together. For the legal evaluation of the documents, from our contact page you may contact our office. During the consultation, the status of the specific file can be addressed, particularly through the date of service, the scope of the requested report, and the initial investment documents .

This article has been prepared for general legal information purposes. No definitive legal conclusion can be reached regarding an individual without examining the notification and the entire citizenship file.

Atty. Batın YILMAZ – Istanbul Bar Association Registry: 77008