
Turkey’s citizenship-by-investment programme — commonly known as the “golden passport” or “golden visa” route — has come under unprecedented scrutiny in 2025 and 2026. A series of large-scale investigations by Turkish authorities has revealed systemic fraud in the real-estate investment track, and thousands of foreign nationals who obtained citizenship through it are now facing revocation. This article explains the legal framework behind the programme, why citizenships are being cancelled, and — most importantly — what affected investors and their families can do to protect their rights.
Article 12 of Law No. 5901 on Turkish Citizenship, together with the Regulation on the Implementation of the Turkish Citizenship Law, provides an exceptional fast-track route to Turkish citizenship for foreign nationals who make a qualifying investment, provided there are no national security or public order concerns.
Under Article 20 of the Regulation, the real-estate route requires the foreign national to either:
Article 31 of Law No. 5901 allows the Ministry of Interior to cancel a citizenship decision — as an administrative act — where it is established that citizenship was obtained through false declarations or by concealing material facts. In the context of the golden passport programme, the recurring grounds identified by investigators include:
Once irregularities of this kind come to light — typically flagged by the land registry or another public authority — the matter is reported to the Ministry of Interior, which opens a cancellation procedure ex officio.
This is not an isolated or speculative concern. Turkey’s own senior officials have confirmed, on the record, that abuse of the programme is widespread and has been actively investigated across at least three major operations since 2024, with underlying conduct reaching back to 2019–2023:
Taken together, these three ministerial-level statements confirm that citizenship revocation on investment-fraud grounds is being pursued systematically, at scale, and with active tracking at the highest levels of the Turkish state — not as a marginal enforcement action.
Under Article 32 of Law No. 5901, a cancellation decision takes effect from the date it is issued, and it extends to any spouse or children who acquired citizenship derivatively through the primary applicant’s status.
Article 33 governs what happens to the person’s assets in Turkey. The provisions of the 1950 Law on the Travel and Residence of Foreigners apply, and if the cancellation decision specifies that liquidation is necessary, the affected person must liquidate their belongings in Turkey within one year. If they fail to do so, the Treasury will sell the assets and deposit the proceeds into an account held in the person’s name at a state bank. Critically, Article 33(2) provides that if the person challenges the cancellation decision before the courts, the liquidation process is suspended until that case is concluded.
A cancellation decision is an administrative act, not a criminal conviction, and it can be challenged. If you or a family member has received — or fears receiving — a citizenship cancellation notice, here is what you need to know:
1. It is a reviewable administrative decision. Cancellation under Article 31 is issued by the Ministry of Interior as an administrative act. Like any administrative decision, it is subject to judicial review before Turkey’s administrative courts, and it can be annulled if it is unlawful, disproportionate, procedurally defective, or not supported by the evidence.
2. The 60-day deadline is strict. Under Turkish administrative procedure, an annulment action (iptal davası) against a cancellation decision must be filed with the competent administrative court within 60 days of formal notification of the decision. This deadline is jurisdictional — missing it will generally bar the challenge outright, regardless of the merits. Acting quickly, and instructing counsel as soon as a notice is received (or even suspected), is essential.
3. Filing suit suspends the liquidation clock. Article 33(2) provides that where the cancellation decision is challenged in court, the obligation to liquidate assets in Turkey is suspended until the litigation concludes. Filing promptly therefore protects both your legal status and your property in Turkey.
4. Family members can be independently affected — and independently defended. Because cancellation extends automatically to spouses and children who derived citizenship from the primary applicant, each affected family member’s situation should be reviewed individually. Errors, disproportionate measures, or defects in the underlying file can sometimes be challenged even where the primary applicant’s case is more complicated.
5. The facts matter — including facts about the intermediary or developer. Many of the fraud patterns identified by investigators (fake appraisals, sham sales, non-transferred titles) originated with real-estate agents, developers, or facilitators — not necessarily with the investor. Where an investor acted in good faith and was misled by a third party, this can be a critical element of the defence and should be documented and argued before the administrative court.
6. Parallel criminal exposure is possible but distinct. Where authorities allege the investor knowingly participated in fraud, forgery, or organised crime, separate criminal proceedings may arise. These require separate legal strategy and should not be confused with, or left to be resolved solely through, the administrative cancellation process.
Our team advises foreign nationals and their families on Turkish citizenship-by-investment matters, including administrative annulment actions against citizenship cancellation decisions, asset-liquidation suspension, and related criminal exposure. Given the strict 60-day deadline for challenging a cancellation decision, we recommend contacting counsel as soon as a notice is received — or as soon as you become aware that your file may be under review.
If you or someone you know has received, or is concerned about receiving, a citizenship cancellation decision related to a real-estate investment in Turkey, our expert team is ready to assist. Get in touch to discuss your situation and the options available to protect your status and your assets.