SGK registration of a foreign employeeis not a process that concludes with the acquisition of a work permit, but rather a separate procedure that must be carried out thereafter. As a general rule, a foreign national cannot be employed without a valid work permit or work permit exemption. Once the permit is obtained, the employer must submit the SGK notification based on whether the foreign national's work permit was issued from within or outside Turkey, the permit start date, the date of entry into Turkey, and the actual start date of employment.

The most significant mistake in practice is assuming that the work permit and the declaration of employment to the social security institution are the same procedure. However, a work permit is an administrative authorization allowing the foreign national to work for a specific employer and within the scope of a specific job, whereas the SGK declaration of employment is the registration of the actual employment relationship with the social security system. It is not sufficient for the employer to complete only one of these.

Quick Answer for Social Security Institution (SGK) Registration of Foreign Employees

For work permit applications made from within Turkey, the social security obligations of the foreign national must be fulfilled within one month at the latest from the permit start date. Pursuant to the specific regulations under SGK legislation, the declaration of employment for a foreign insured employee is deemed timely if submitted within 30 days from the work permit start date. If the date reported by the employer as the commencement of the employment contract differs from the permit start date, the starting point of the 30-day period must be evaluated together with concrete records.

For applications made from abroad, the foreign national must arrive in Turkey within six months from the validity start date of the work permit; and following entry into Turkey, commence work and fulfill social security obligations within one month at the latest. The SGK notification of termination must be submitted within 10 days following the termination of the employment contract; furthermore, the commencement of work by the foreigner, the termination of employment, or situations requiring the cancellation of the permit must be separately reported to the Ministry of Labour and Social Security within 15 days.

Proceeding	Place of Notification	Base period	Point to consider
Employment Registration Following Domestic Permit	SGK	30 days from the permit start date	Actual employment cannot be initiated before the permit is issued
Resumption of work following abroad leave	SGK and employer records	No later than one month after entry into Turkey	The foreigner must arrive in Turkey within six months from the start date of the permit
Termination of employment	SGK	10 days following the expiration date	UİGM notification does not substitute for this
Commencement or termination of employment	ÇSGB / e-İzin	15 days	SGK notification shall be made separately
Grounds requiring cancellation	ÇSGB / e-İzin	15 days	The employer remaining passive may additionally entail sanctions

Work Permit and SGK Registration Are Not the Same Thing

Pursuant to the International Labour Law No. 6735, it is essential that a foreign national who will work in Turkey obtains a work permit or a work permit exemption prior to commencing employment. Making a social security notification to the SSI (SGK) does not grant the foreign national the right to work. Likewise, the issuance of a work permit does not mean that the employer is deemed to have automatically fulfilled its premium and notification obligations.

Therefore, the process must be managed through three separate checks: the validity of the work permit, the actual commencement date of employment, and the timing of the SSI (SGK) notification. The employer, workplace, duty, or profession information on the permit card must also comply with the actual work. If a change of employer is planned, one should not rely solely on the SSI (SGK) termination and new entry procedures; a new work permit process must be carried out on behalf of the new employer. For details employer change in work permit you may review our guide.

Under which social security coverage is the foreign employee reported?

As a rule, a foreign national working under an employment contract subordinate to an employer in Turkey is reported as insured under Article 4/1-a of Law No. 5510. Foreign nationality alone does not constitute an obstacle to compulsory social security coverage. However, different outcomes may arise in special circumstances such as international social security agreements, temporary assignments, independent work, or company partnership. Therefore, an automatic assumption that "every foreigner is reported under Article 4/a in the same manner" is not correct.

The 30-Day Rule for Work Permits Obtained Within Turkey

If the application made from within the country results in approval, social security obligations must be fulfilled based on the start date of the foreigner's work permit. The current statement of the Ministry of Labour and Social Security specifies that in applications made from within the country, the foreigner must start working within one month from the permit start date. The specific regulation in the Social Insurance Transactions Regulation also accepts the insurance notification made within 30 days from the work permit start date as being made in a timely manner.

This regulation does not mean that the employer can employ the foreigner before the start of the permit. Furthermore, it does not constitute a basis for arranging a backdated employment entry contrary to the facts. The commencement date of employment stated in the notification must comply with the employment contract, payroll, timesheets, bank payments, and actual work records.

What happens if the permit start date and the service start date are different?

According to the Ministry's statement, if the work permit start date and the date reported by the employer as the start date of the employment contract are different, the SSI (SGK) notification made within 30 days from the start date of the employment contract may be considered timely. However, this option is not unlimited. The start of service must comply with the scope of the work permit and the foreigner's legal right to work, and the factual situation must be supported by documents. In case of doubt, obtaining a written opinion from the relevant SSI (SGK) directorate reduces the risk of premiums and penalties that may arise later.

Entry into Turkey and the One-Month Rule for Work Permits Obtained from Abroad

Applications from abroad commence at the Turkish diplomatic mission in the country where the foreigner is a citizen or legally resides, and are completed by the employer via the e-Permit system. After the permit is issued, two separate deadlines must be monitored. The foreigner must arrive in Turkey within six months from the validity start date of the work permit. After entering Turkey, they must commence work within one month at the latest, and social security obligations must be fulfilled.

Therefore, when applying from abroad, it is not sufficient to look only at the start date on the permit card. The passport entry record, the work permit start date, and the actual employment start date must be filed together. Failure of the foreigner to arrive in Turkey within the six-month period may lead to the cancellation of the work permit. For detailed information on the conditions for domestic and international applications work permit application without a residence permit you can review our article.

Dual Notification in Case of Commencement of Work, Termination, and Cancellation

In the employment of foreign nationals, the employer's obligations before the SSI (SGK) and the Directorate General of International Labour are independent of each other. The entry or termination notification submitted to the SSI (SGK) system does not replace the notification required to be made via the e-Permit system. Likewise, the 15-day notification made to the Ministry does not complete the SSI (SGK) registration.

The date on which the foreigner actually starts working must be notified to the Ministry within 15 days.
The termination of employment or the employment contract must be notified to the Ministry within 15 days.
Events requiring the revocation of the work permit must be notified to the Ministry within 15 days.
When the service contract terminates, the SSI (Social Security Institution) termination declaration must also be submitted within 10 days.

If the foreigner does not start working at all after obtaining the permit,

Even though a permit has been issued, if the foreigner does not start working, a misleading SSI record must not be created. The employer must notify the Ministry within the legal period that the foreigner has not started working and of the circumstances requiring the revocation of the permit. Leaving the file inactive may create discrepancies between the permit records, workplace records, and SSI data. Regarding the termination or subsequent invalidation of the work permit, grounds for and consequences of the revocation of the work permit you can benefit from our article.

Is SGK Registration Interrupted During Work Permit Extension?

In the event of a proper and timely extension application, the foreigner may continue to work under certain conditions with the same employer and within the scope of the same job until the application is finalized; this period shall under no circumstances exceed 90 days. If actual work continues, SSI notifications and premium payments must also be maintained without interruption. Processing an SSI termination solely because an extension application has been filed may contradict the actual employment status.

If the extension application is rejected or the permit period expires and the right to work ceases, actual work must be suspended, and the necessary SSI and Ministry notifications must be made. Regarding the timing of the application, the same employer condition, and the 90-day working privilege, work permit extension application detailed explanations can be found in our guide.

Earnings Subject to Premium and the Foreign Employee's Salary

The earnings subject to premiums reported to the SSI must be consistent with the gross wage actually earned by the foreigner. Additionally, there are minimum wage levels that must be paid according to the foreigner's position during the work permit evaluation. Pursuant to the current evaluation criteria for 2026, the wage must not fall below the following thresholds, based on the gross minimum wage in effect as of the application date.

Duty or profession	Minimum wage coefficient
Senior executive and pilot	5 times
Engineer and architect	4 times
Other manager	3 times
Jobs requiring expertise or craftsmanship	2 times
Domestic services and other professions	1 time

These coefficients do not constitute an automatic and immutable payroll calculation for every foreign national; the nature of the application, specific criteria, and exceptions must be examined separately. However, any unexplained discrepancy between the wage declared in the work permit application submitted to the Ministry and the employment contract, bank payments, payroll, and SGK earnings subject to premiums poses risks regarding audits, underpaid premiums, and work permit compliance. For current wage tiers wage criteria for foreign employees refer to our article; and for employment and financial sufficiency conditions work permit evaluation criteria you may review our guide.

Must the premium days always be 30 days for every foreign national?

No. As a rule, 30 days are reported for individuals working continuously for a full month; however, if there is a start of employment, termination of employment, unpaid leave, medical leave, or legal grounds for partial work within the month, general social security rules apply. Being a foreign national does not require reporting 30 days fictitiously. Conversely, misrepresenting actual work as partial can lead to a loss of premiums and sanctions.

Social Security Agreements and Temporary Assignment Exemption

An exemption from being subject to Turkish social security legislation may arise for individuals who are sent to Turkey for temporary work on behalf of an employer established in a foreign country and who document that they are subject to social security in their home country. If there is a social security agreement between Turkey and the relevant country, the scope and duration of the exemption are determined primarily in accordance with that agreement. For countries with no such agreement, the limited temporary assignment rule under Law No. 5510 and secondary legislation shall be evaluated.

A foreign national's declaration alone is not sufficient for the exemption. A certificate of coverage obtained from the competent social security institution in the foreign country or the forms stipulated in the agreement must be submitted to SGK. Since the type of document and its validity period vary by country, a single form name should not be used for all countries. Furthermore, social security exemption does not mean work permit exemption; the foreign national's right to work must be separately verified pursuant to Law No. 6735.

Social Security Rights of Foreigners Without a Work Permit

The absence of a work permit for a foreign national gives rise to the employer's liability for unauthorized employment. However, it is incorrect to state that a foreign national who is actually working has no social security and work accident protection under any circumstances. Actual employment can be proven through witnesses, wage payments, workplace records, camera footage, correspondence, entry-exit logs, and other evidence. If conditions are met, the foreign employee may file a lawsuit for the determination of service.

Registration with the SSI or the retroactive determination of services does not legitimize the absence of a work permit. The sanctions for the two areas are distinct. Unauthorized work may simultaneously entail administrative fines and deportation assessment for the foreign national, and work permit legislative penalties, social security debts, and other liabilities for the employer. Regarding the deportation process deportation decision and annulment lawsuit you can check our guide.

Foreign Employees and SGK in Precedent Judicial Decisions

The following decisions demonstrate that each case must be evaluated based on its own evidence. Although high court rulings serve as a guide in similar disputes, the parties, working arrangements, evidence, and transaction dates of the specific case may differ.

Work accident of a foreign national without a work permit and SSI registration

In the decision of the 10th Civil Chamber of the Court of Cassation, dated December 6, 2023, numbered E. 2023/10744, K. 2023/12501, the injury of a foreign national lacking a work permit and SSI registration while de facto working at the workplace was examined. The Chamber upheld the acceptance that the lack of a permit or registration does not automatically eliminate de facto employment and the nature of the incident as a work accident. For the full text of the decision From the Court of Cassation decision link accessible.

Administrative fines must be based on concrete evidence

In the decision of the 10th Chamber of the Council of State, dated October 18, 2021, numbered E. 2019/4817, K. 2021/4832, the SSI penalty imposed on the grounds that the foreign employee's notifications were not made in a timely manner was addressed. In the concrete dispute, the decision to annul the penalty was upheld on the grounds that the determinations regarding de facto employment and premium accrual could not be demonstrated with sufficient evidence. This result does not mean that the penalty will be automatically annulled in every claim of late notification; it shows that administrative sanctions must be based on concrete and auditable determinations. Decision From the Council of State decision text may be examined.

Obligation of detailed investigation in service determination

In the decision of the 10th Civil Chamber of the Court of Cassation, dated September 21, 2023, numbered E. 2023/9363, K. 2023/8576, the request for the determination of past service periods of a foreign employee was evaluated. Emphasizing that incomplete investigations should not be conducted regarding insured status and de facto employment, the Chamber requested a detailed investigation of the records for the specific period. The essence of the decision is that foreign nationality alone does not eliminate the right to social security; however, the fact of employment must be established through proper evidence. To the text From the Court of Cassation decision link can be accessed.

Notification Violations and Unauthorized Employment Penalties in 2026

Administrative fines under Law No. 6735 are updated annually at the revaluation rate. According to the 2026 schedule of the Directorate General of International Labor, administrative fines are imposed as follows: 102,503 TRY for each foreign national employed without a work permit, 40,977 TRY for a foreign national working dependently without a work permit, and 82,010 TRY for an independent foreign worker. A fine of 6,805 TRY per foreign national is prescribed for employers who fail to fulfill their notification obligations in a timely manner, as well as for foreign nationals holding an indefinite or independent work permit. In the event of a repeat offense, the fines are doubled.

These amounts represent only the sanctions within the scope of Law No. 6735. In the event of violations concerning SGK entry, exit, premium documents, and missing earnings, additional administrative fines, principal premiums, default interest, and late-payment surcharges may arise pursuant to Law No. 5510. Since penalty calculations vary depending on the type of violation, method of detection, workplace records, and whether a voluntary disclosure was made, evaluations should not be based on a single fixed amount. The rejection of a work permit application is different from its revocation; for this distinction, rejection of the work permit application you may review our article.

Documents That Must Be Retained in the SGK File

Whether the SGK notification for a foreign employee was made on time may not be evaluated solely based on the declaration date appearing in the system. Particularly in files where the permit start date, date of entry into Turkey, and commencement of the employment contract differ, it is important for the employer to retain supporting documents of the timeline together. The work permit card or electronic permit document, the Ministry's permit notification letter, the foreigner's passport entry page, entry-exit records, signed employment contract, work commencement minutes, SGK employment entry declaration, and e-Permit notification printout must be kept in the same personnel file.

In terms of wages and premiums, the monthly payroll, bank payment records, attendance sheets, Withholding and Premium Service Tax Return, and the wage committed during the permit application must be cross-checked. If the employee has missing days within the month, documents regarding the reason for the missing days must also be retained. For individuals arriving from abroad, it is particularly important that the date of entry into Turkey and, in the case of exemptions based on international social security agreements, the coverage certificate issued by the competent foreign institution are included in the file.

Why should records be kept together?

The work permit system, SGK records, and the employer's payroll documents serve different purposes, but they are evaluated together during an audit. Unexplained discrepancies between the employer or occupational information on the permit document and the SGK occupation code, payroll wage, or actual duties may raise suspicion of a breach of the scope of the work permit. The regular retention of documents is necessary not only for defense against administrative fines, but also for the correct resolution of future disputes concerning the foreigner's length of service, wage claims, or work accidents.

Implementation Checklist for Employers

Verify the foreigner's valid work permit or exemption certificate.
Compare the employer, workplace, duty, occupation, and duration information on the permit card with the employment contract.
Determine whether the application was made from within Turkey or from abroad.
Record the permit start date, date of entry into Turkey, and actual date of commencement of work separately.
Submit the SGK employment entry declaration within the relevant special deadline; do not wait until the final day.
Additionally, complete the 15-day work commencement notification via e-Permit.
Verify the consistency between the gross salary, bank payment, payroll, and earnings subject to premium.
File country-specific social security formulas in case of an exemption claim.
Upon termination of the employment contract, make the notifications to SGK within 10 days and to the Ministry within 15 days separately.
Employers must not assume that existing leave automatically continues upon a change of duty or workplace.

Common Mistakes

Assuming that the SGK entry substitutes for a work permit.
Interpreting the 30-day special notification period as the freedom to work before the permit is issued.
Failing to document the date of entry into Turkey in overseas applications.
Believing that the 15-day notification to the Ministry is not required simply because the SGK notification has been made.
Declaring payroll and premiums below the salary pledged in the work permit.
Executing an employer change solely through SGK termination and re-entry procedures.
Confusing social security agreement exemptions with work permit exemptions.
Creating a fictitious insurance record for a foreign national who does not commence employment.
Issuing a Social Security Institution (SGK) termination notification that contradicts actual employment while a renewal application is pending.

Frequently Asked Questions Regarding Social Security Institution (SGK) Registration of Foreign Employees

Can a foreign employee's SGK registration be made before obtaining a work permit?

As a rule, no. SGK registration does not grant the foreign national the right to work. A valid work permit or work permit exemption must be obtained before the foreign national is actually employed.

Can a foreign national be employed without social security coverage during the 30-day period?

No. The 30-day regulation pertains to the timely acceptance of certain foreign insured notifications; it does not grant the right to work without insurance or prior to the commencement of the permit. The actual date of commencement of work must be accurately recorded, and premiums must be declared based on this date.

Within what timeframe must a foreign national arriving from abroad commence employment?

The foreign national must arrive in Turkey within six months from the start date of the permit; commence employment within one month at the latest following their entry into Turkey, and social security obligations must be fulfilled.

What is the deadline for submitting the SGK employment termination notification?

The SGK employment termination declaration must be submitted within 10 days following the date of termination of the employment contract. Additionally, since the employment has ended, notification must also be made to the Ministry within 15 days.

Are premiums payable if a foreign national who has obtained a work permit does not commence employment?

If there is no actual employment, a false insured status must not be created. The failure to commence employment must be reported to the Ministry within the statutory period, and the status of the permit must be clarified.

Do SGK premium payments continue during a work permit extension application?

If the foreign national maintains their legal right to work under the same employer and within the scope of the same job, premium notifications shall continue uninterrupted throughout the actual employment. It is crucial that the extension application is made within the prescribed period.

Can the foreign employee's salary be reported at the minimum wage level?

It varies depending on the profession. While the minimum wage level may apply to domestic services and other professions, higher coefficients apply to senior executives, pilots, engineers, architects, other managers, and jobs requiring expertise.

If there is a bilateral social security agreement, is SGK registration omitted entirely?

Not in every case. The exemption depends on the temporary assignment of the foreign national by their employer in the foreign country, the relevant agreement, and the applicable certificate of coverage. A different assessment may be made for individuals who have a local service relationship with a Turkish employer.

Can a foreign national without a work permit file a determination of service lawsuit?

A foreign national claiming actual employment may request a determination of service if the conditions are met. The lack of a permit does not exempt the employer from sanctions; however, the fact of employment must be proven with concrete evidence.

Can an incident involving an unauthorized working foreign national be considered an occupational accident?

Yes. If the actual employment relationship and the conditions under Law No. 5510 are proven, the absence of a permit or SGK registration does not automatically eliminate the occupational accident character of the incident.

Are the SGK notification and the e-Permit notification a single transaction?

No. SGK entry and exit transactions and the 15-day notifications to be made to the Ministry are separate obligations. Fulfilling one does not substitute for the other.

If the employer changes, will the existing SGK registration be sufficient?

No. As a rule, a work permit is tied to a specific employer. In addition to the termination procedures of the former employer and the SSI (SGK) procedures of the new employer, a work permit application must be submitted on behalf of the new employer.

Official Sources

Conclusion

The registration of a foreign employee with the SSI (SGK) is an obligation that must be managed separately from, yet concurrently with, the work permit file. The starting points for in-country and out-of-country applications differ; SSI's special 30-day period, the Ministry's 15-day notification, and the 10-day period for SSI employment termination should not be confused with one another. Ensuring that the permit, actual employment, payroll, and insurance records reflect the same reality is crucial for both preserving the work permit and mitigating the risk of premium liabilities and administrative fines.

Regarding the preparation of application documents, documents required for foreign work permit our guide; and for the general framework of the work permit process, work permit for foreigners you can review our services page. The specific case may also need to be evaluated separately in terms of the permit type, the foreigner's status, employer change, and social security agreements.

Author Information

Attorney Batın YILMAZ

Istanbul Bar Association Bar Registry No: 77008

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