Turkish Citizenship by Job Creation

The job creation route to Turkish citizenship is structurally different from every other pathway in the program. There is no minimum financial investment amount. No property to buy, no deposit to place, no bonds to purchase. The qualifying threshold is a workforce: at least 50 Turkish citizens employed full-time, continuously, with their contributions registered in Turkey’s Social Security Institution.

For investors who are building a Turkish business operation regardless of citizenship — a manufacturer expanding into Turkey, a regional headquarters being established, a technology company hiring local talent — this route is not an additional cost. It is citizenship that comes as a by-product of an operation that would have been built anyway.

For investors whose primary goal is the passport and who are not otherwise planning a Turkish business with 50+ staff, the financial investment routes will be faster, simpler, and lower in total cost.

This guide explains the legal requirements precisely, how the Ministry of Labour verification process works, what the company registration involves, and what genuine operational risks look like.

Legal Notice: This page provides general legal information for educational purposes only. It does not constitute legal advice. For guidance specific to your situation, please consult a qualified attorney.

The Legal Basis

Turkish citizenship by job creation is established under Article 12(1)(b) of Turkish Citizenship Law No. 5901, which provides for exceptional acquisition of citizenship by Presidential decree for foreign nationals who create employment for at least 50 Turkish citizens, as confirmed by the Ministry of Labour and Social Security.

The detailed procedural framework is published by the Ministry of Labour and Social Security — Directorate General for International Labour Force, which is the authority responsible for verifying employment and issuing the conformity certificate.

The company must be registered under Turkish Commercial Code No. 6102. Employees must be registered in Turkey’s social security system under Social Insurance and General Health Insurance Law No. 5510, administered by the Social Security Institution (SGK). Employment contracts must comply with Labour Law No. 4857.

Foreign investment in the company is protected under Foreign Direct Investment Law No. 4875, which guarantees equal treatment for foreign and domestic investors in Turkey.

The Employment Requirement: Precisely Stated

This is where most general guides on this topic are imprecise. The official requirements from the Ministry of Labour and Social Security are:

At the time of application:

At least 50 Turkish citizens must have been continuously employed full-time at the company for a minimum of 6 consecutive months preceding the application date. SGK registration must be uninterrupted throughout this period.

After application:

Employment must be maintained at or above the 50-person threshold for at least 2 years from the application date.

Important distinction: The 3-year figure cited by many sources refers to the total period from employment commencement to the end of the post-application maintenance obligation — but the legal framework measures it differently. The 6-month pre-application period plus the 2-year post-application maintenance period is the operative standard under the Ministry’s current guidelines.

What counts as an employee: Only Turkish citizens qualify toward the 50-person threshold. Foreign nationals employed at the company, even with valid work permits, do not count. All 50 qualifying employees must be registered with SGK on full-time employment contracts. Part-time workers, contractors, and freelancers do not count.

No minimum capital requirement: Unlike the financial investment routes, the job creation route has no statutory minimum investment amount. There is no requirement to demonstrate a specific level of capital contribution. The threshold is solely employment-based.

The Verification Process: How the Ministry of Labour Reviews Applications

The conformity certificate is issued by the Directorate General for International Labour Force of the Ministry of Labour and Social Security. The process:

Applications are submitted in writing to the Directorate General with the required documentation.

Timeline:

Applications with complete documentation are finalized within 7 working days. If documents are incomplete, the applicant is given 30 days to remedy deficiencies. Applications not completed within this period are rejected.

What the Ministry verifies:

The continuity of SGK registrations for the 50 qualifying employees over the 6-month period preceding the application. Social security payment records, employment contracts, and payroll documentation are cross-referenced against SGK’s database.

Output:

A certificate of conformity confirming that the employment requirement is met. This document triggers the citizenship application process.

Company Structure: What Must Be in Place

Entity Type

The company can be any Turkish commercial entity registered under Turkish Commercial Code No. 6102:

• Anonim Sirket (A.S.) — Joint Stock Company. Required minimum capital TRY 250,000. Better suited for larger operations, easier to bring in additional investors or shareholders.
• Limited Sirketi (Ltd. Sti.) — Limited Liability Company. Required minimum capital TRY 10,000. Simpler governance structure, suitable for owner-operated businesses.
• Branch office — A branch of a foreign company registered in Turkey. Can qualify if Turkish citizens are employed at the branch and SGK-registered.

For company formation support, Aslan Attorney handles full registration from entity selection through operational launch, including Trade Registry filing, tax registration, and social security employer registration.

SGK Employer Registration

Before any employees can be hired, the company must be registered as an employer with SGK. This registration must be in place before the first employee’s start date. Each employee’s SGK registration must be active from their first working day — retroactive registration is not permitted.

Payroll and Social Security Contributions

All 50 qualifying employees must be on formal payroll with monthly salary payments at or above the minimum wage. Social security contributions (employer and employee portions) must be paid monthly without interruption. Any gaps in contributions during the 6-month qualifying period will appear in the SGK database and will be flagged during Ministry verification.

As of January 2026, Turkey’s monthly minimum wage is TRY 33,030 gross. Employer social security contributions add approximately 20.75% on top of gross salary. For 50 employees at minimum wage, monthly payroll costs run approximately TRY 1,650,000 plus TRY 342,375 in employer social security — total approximately TRY 2,000,000 per month (roughly USD 55,000 to 65,000 at current exchange rates).

Step-by-Step Process

Step 1: Establish the Turkish Company

Register the entity with the relevant Trade Registry Office (Ticaret Sicil Mudurlugu). Obtain a tax identification number from the local tax office. Register as an employer with SGK. Open a corporate bank account. This process takes 1 to 2 weeks when properly prepared.

Step 2: Hire and Register 50 Turkish Citizen Employees

Execute employment contracts compliant with Labour Law No. 4857 for each of the 50 qualifying employees. Register each employee with SGK from their first working day. Maintain payroll and social security contributions without interruption.

Step 3: Maintain Employment for 6 Consecutive Months

The 6-month continuous employment period must complete before the conformity application can be submitted. SGK records during this period form the evidential basis of the Ministry’s review.

Step 4: Apply to the Ministry of Labour for the Conformity Certificate

Submit a written application to the Directorate General for International Labour Force with complete documentation. The Ministry reviews and issues the conformity certificate within 7 working days if the file is complete.

Step 5: Obtain a Short-Term Residence Permit

Applied for through the Directorate General of Migration Management under Law No. 6458 on Foreigners and International Protection. Physical presence required for biometric data collection.

Step 6: Submit the Citizenship Application

With the Ministry conformity certificate and residence permit, the citizenship application is submitted to the General Directorate of Population and Citizenship Affairs (NVI). Citizenship is granted by Presidential decree under Article 12 of Law No. 5901. Standard processing from full submission: 3 to 6 months.

Step 7: Maintain Employment for 2 Years Post-Application

The 50-employee threshold must be maintained throughout the 2-year post-application period. The Ministry monitors compliance. Falling below 50 SGK-registered Turkish citizen employees during this period risks citizenship revocation.

Required Documents for the Ministry Application

The following documents are submitted to the Directorate General for International Labour Force:

• Written application letter
• Company Trade Registry certificate and articles of association
• SGK employer registration certificate
• SGK monthly service documents (aylik hizmet belgesi) covering the 6-month qualifying period for all 50 employees
• Employment contracts for all 50 qualifying employees
• Payroll records for the 6-month period
• Proof of social security premium payments (prim odeme belgesi)
• Investor’s passport with notarized Turkish translation
• Company tax registration certificate
• Circular of signature (imza sirkuleri)

For the citizenship application itself, the standard documents apply: birth certificates, marriage certificate if applicable, police clearance, biometric photographs, and the conformity certificate from the Ministry.

Realistic Cost Picture

Unlike the financial investment routes where the cost is a defined threshold, the job creation route costs depend on business size, sector, and location. A realistic framework:

Cost Item	Estimate
Company registration (one-time)	USD 500 to 2,000
Monthly payroll — 50 employees at minimum wage	~USD 55,000 to 65,000/month
Employer social security — 6 months pre-application	~USD 70,000 to 80,000
Employer social security — 2 years post-application	~USD 270,000 to 310,000
Office space, equipment, operational costs	Varies by sector
Legal and advisory fees	Varies

The total payroll and social security obligation over the full qualifying and maintenance period runs to approximately USD 1.7 to 2.2 million for 50 employees at minimum wage — before any operational costs. This is the honest picture. The job creation route is not a low-cost citizenship pathway. It is the right pathway for investors whose business rationale independently justifies building a 50+ person Turkish operation.

Sectors That Work Well

Turkish authorities view applications more favourably when the business contributes meaningfully to the economy. Sectors that consistently generate credible 50+ employee operations include manufacturing and production facilities, technology development and regional headquarters, tourism and hospitality, logistics and distribution, and healthcare facilities. For businesses where the investor already has regional expertise, Turkey’s position bridging European and Asian markets creates genuine commercial rationale for these operations.

Key Risks and What to Manage

Employee turnover during the qualifying period.

If any of the 50 qualifying employees leave and are not immediately replaced, the SGK count drops below 50. Active HR management and contingency hiring are essential during the qualifying period.

SGK payment delays.

Late or missed social security payments appear immediately in SGK records. Even a single month’s delayed payment creates a documentation gap. Payroll and SGK contributions must run on time every month.

Misclassification of workers.

Freelancers, contractors, and part-time workers do not count. All qualifying workers must be on standard full-time SGK-registered employment contracts.

Post-citizenship employment monitoring.

The 2-year post-application maintenance requirement continues after citizenship is granted. Business planning must account for this ongoing obligation.

Foreign employee ratio.

Turkish labour regulations generally limit foreign employees to 1 for every 5 Turkish employees under Labour Law No. 4857. For a 50-person qualifying operation, up to 10 foreign staff can be employed alongside the qualifying Turkish workforce.

Frequently Asked Questions

Can an existing Turkish company be used, or must a new one be formed?

An existing Turkish company in which the investor holds a stake can qualify, provided the 50-employee threshold is met and the 6-month employment continuity requirement is satisfied. We review ownership structures and determine the most appropriate approach for each case.

Can employees across multiple subsidiaries be combined?

Generally, employees must be registered under the same SGK employer account as the entity the investor controls. Employees at legally separate subsidiaries may not be aggregated unless the structure is confirmed as acceptable by the Ministry.

Does the investor count as one of the 50 employees?

No. The investor-director does not count toward the 50 Turkish citizen employees. The 50 must be Turkish citizens on standard SGK-registered employment contracts.

Does the investor need to be physically present in Turkey?

No. A Turkish company can be managed remotely or through local directors under power of attorney. However, Turkish authorities assess whether the business is a genuine operation — purely nominal structures created solely for citizenship purposes do not qualify.

What happens if the workforce drops below 50 after citizenship is granted?

Reducing the workforce below 50 Turkish citizens during the 2-year post-application maintenance period risks revocation proceedings. Any planned restructuring during this period must be reviewed by legal counsel before action is taken.

Working With Aslan Attorney

Aslan Attorney is an Istanbul-based international law firm registered with the Istanbul Bar Association. The job creation route requires coordinating company law, labour law, social security compliance, and the citizenship application framework simultaneously across a multi-year process.

Our service for job creation route clients covers entity formation and Trade Registry registration, SGK employer registration and compliance monitoring, employment contract preparation, Ministry of Labour conformity application, residence permit and citizenship application, and post-citizenship employment maintenance compliance.

For clients evaluating whether the job creation route or a financial investment route better suits their situation, we provide a structured comparison as part of the initial consultation.

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