AMENDMENTS TO THE APPRAISAL PROCESS FOR CITIZENSHIP THROUGH REAL ESTATE ACQUISITION
The Circular No. 2024/2 of the General Directorate of Land Registry and Cadaster (“TKGM”) on the “Procedures and Principles Regarding Appraisal Reports to be Used in Real Estate Acquisitions by Foreigners and Certain Other Transactions” and Circular No. 2024/4 on the “Regulation on the Implementation of the Turkish Citizenship Law” have been amended pursuant to the Ministerial Approvals dated 28 September 2026.
The amendments are particularly significant in terms of the validity period of appraisal reports, the selection of appraisal companies, and the Amount Determination Certificate (“TTB”) used in Turkish citizenship applications through real estate acquisition.
Validity Period of Appraisal Reports Extended to 12 Months
Under the new regulation, the validity period of real estate appraisal reports to be used in land registry transactions has been increased from 6 months to 12 months. If this period expires, a new appraisal report must be requested through the system before the land registry transaction is carried out.
However, if the land registry records indicate that a change affecting the value of the property has occurred between the date of the appraisal report and the date of the application for the land registry transaction, a new appraisal report must be obtained even if the 12 month period has not yet expired.
Applicants Are Now Permitted to Select the Appraisal Company
Appraisal reports underlying the TTB to be used for determinations under the Regulation on the Implementation of the Turkish Citizenship Law may now be prepared by any appraisal company licensed by the Capital Markets Board (“SPK”) in addition to GEDAS.
In this context, applicants may now select any appraisal company either by preference or through an automatic algorithm, using the application option corresponding to the purpose of the appraisal report request.
Appraisal Report Requirement Introduced for Sales by Real Estate Investment Trusts to Foreigners for Turkish Citizenship Purposes
Real estate investment trusts (“GYOs”) are required to submit an appraisal report for real estate sales or preliminary sale agreements entered into with foreign nationals for the purpose of acquiring Turkish citizenship. Such appraisal report must be prepared prior to the date of the land registry transaction in accordance with the applicable legislation, published on the Public Disclosure Platform (“KAP”), and indicate the value of the relevant independent unit.
Alternatively, GYOs may request a new appraisal report underlying the TTB through Web Tapu/TADEBİS. Where a appraisal report published on KAP is submitted, the matter will be referred to the Foreign Affairs Department of the General Directorate of Land Registry and Cadastre (TKGM) during the TYTB review, and the transaction will proceed based on the response received.
Conclusion
The amendments effective as of 29 September 2026, particularly the extension of the validity period of appraisal reports and TTBs to 12 months, provide investors with a longer timeframe to complete real estate investment transactions for Turkish citizenship purposes. Besides, allowing applicants to select among any appraisal companies authorized by the SPK, in addition to GEDAS, introduces greater flexibility into the appraisal process.
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