Turkish citizenship by investment: what changed in property valuation in September 2026

In short: From 28 September 2026, property bought from a GYO (a Turkish REIT) is no longer exempt from an independent valuation. The USD 400,000 threshold is unchanged, but the sale price, the valuation and the payments must each reach it on their own. A TTB now stays valid for 12 months instead of 6, and GEDAŞ no longer holds a monopoly on citizenship valuations.

1. What changed

Turkey's General Directorate of Land Registry and Cadastre (TKGM) has changed the valuation rules for citizenship-by-investment files. The minimum investment is still USD 400,000, but proving the property's value has become stricter — and, in return, two important simplifications have been added.

The changes cover both new buyers and files already under way. What counts is not the date the contract was signed but the date the TYTB certificate is issued.

2. The end of the GYO exemption

Until this change, a property bought from a real estate investment trust (GYO) needed no independent valuation report. That exemption has gone. From now on, one of these two documents is required before the transaction at the land registry (tapu):

1. a new, independent valuation report; or

2. the GYO's own valuation, published on the KAP disclosure platform.

If the KAP valuation is submitted instead of a new report, the file is referred to the General Directorate in Ankara during the TYTB review and proceeds according to its answer. That does not mean the file is rejected, but it does mean a delay.

The rule also covers Emlak Konut GYO; its ties to the state do not create an exemption.

3. The USD 400,000 threshold: a three-part test

The amount has not changed, but three figures must now explicitly reach USD 400,000 each on their own, not in combination:

• the sale price in the title deed

• the value recorded in the valuation report

• the total of the bank payments to the seller

Structures that used to pass on an informal reading may therefore no longer be accepted. And according to Property Turkey, a shortfall in value under a promise-to-sell contract (satış vaadi) can no longer be made up later by adding a second property.

4. Two changes in the buyer's favour

a) TTB validity goes from 6 to 12 months. Under Circular 2024/4, certificates more than six months old had to be renewed. The period has now doubled, which lowers the risk of a document expiring mid-process because of bank delays, translations or appointment waits. The extension does not apply to the file's other deadlines and documents.

b) The GEDAŞ monopoly has ended. Until now, citizenship valuation reports could only be prepared by one designated firm. Now any valuation firm that meets all three of these conditions can issue one:

• a licence from the Capital Markets Board (SPK)

• membership of the Association of Valuation Experts (TDÜB)

• registration in the property valuation information system (TADEBİS)

The firm is chosen and the request filed through the Web Tapu portal. No official list of approved firms has been published, so choosing a reputable, experienced valuer matters more than before.

5. Files already under way: who is affected?

6. The automatic 25% uplift is a rumour

Some channels claim that Turkey will now add 25% to a property's appraised value. According to Property Turkey, which checked with a regional land registry office, no such mechanism exists in the circulars; each file's value is assessed individually.

7. Practical advice

• Get the valuation report before you sign any contract, not after.

• Check the TYTB status of every file that is under way.

• When buying from a GYO, compare the KAP figure with the sale price before you pay.

• Make sure all three figures — deed price, valuation and payments — reach USD 400,000, with a margin for exchange-rate moves.

• Choose a valuer with an SPK licence, TDÜB membership and TADEBİS registration.

• Watch for the updated implementing guide (Uygulama Kılavuzu); further changes are possible.

8. Glossary

9. Sources

The current text of Circular 2024/4, as amended by the TKGM Makam Oluru of 28 September 2026 (No. 21914825), is published on the TKGM website, and the main points of this article have been checked against it. Some practical details rely on a private firm's report: confirm them with the land registry or a lawyer before you decide.

• TKGM — Circular 2024/4 (current text, amended 28 September 2026)

• Property Turkey — Turkish Citizenship Changes: September 2026 Update

This article is for information only and is not legal advice. · Pergas Yönetim Danışmanlık İnşaat Ticaret Ltd. Şti.