Turkey’s Land Registry and Cadastre Directorate (TKGM) updated Circular 2024/2 on 28 September 2026, changing how property valuation reports are prepared for applications under the Turkish Citizenship by Investment route. The property investment threshold remains US$400,000; the changes concern the authorised report providers, the selection process and the report’s validity.
What changed in the property valuation process?
| Topic | Previous arrangement | Updated arrangement |
|---|---|---|
| Who can issue the report | GEDAŞ was the designated provider | A valuation firm authorised by the Capital Markets Board (SPK), subject to the circular’s eligibility requirements |
| Provider requirements | Primarily GEDAŞ | Active TDUB membership and registration in TADEBİS, in addition to SPK authorisation |
| Report validity | 6 months | 12 months for title deed transactions |
| When a new report may be needed | As required | On expiry, or if a subsequent registry entry affects the property’s value |
Five points applicants should understand
- The US$400,000 threshold remains. The property-investment route continues to require an investment meeting the applicable minimum. The valuation report is an important part of the assessment; do not rely on the sale-contract figure alone. Confirm the treatment of your property and file with qualified Turkish counsel.
- Valuation providers are not limited to GEDAŞ. The updated circular permits eligible SPK-authorised valuation firms that meet the applicable TDUB and TADEBİS requirements. The SPK’s published list of authorised valuation firms is a useful starting point; confirm current eligibility and the applicable appointment process before proceeding.
- The report validity period is now 12 months. This gives applicants a longer window for title deed registration, but it is not a blanket extension of every document or approval in a citizenship application.
- Some property changes can require a fresh valuation. If a registry entry made after the report affects value—for example, a land-use change, road abandonment or easement—the updated circular calls for a new report, even if the original report has not expired.
- Transition cases need individual review. The circular update does not make every pending file identical. If you have signed a contract, received a conformity document or are waiting for title deed registration, ask Turkish counsel to check the dates and documents against the current rules. Do not budget on unverified claims about exemptions or automatic percentage uplifts.
Practical implications for Hong Kong investors
- Already signed, not yet registered: check the valuation report date, the title deed timeline and any value-affecting registry entries; have counsel confirm which requirements apply to your file.
- Not yet signed: build the valuation appointment and title deed registration into the project timetable, allowing enough time to complete the relevant transaction within the report’s validity period.
- Budgeting: account for valuation, translation, notarisation and registration costs in addition to the investment threshold.
- Choosing a project: request clear property, valuation and registration documents and carry out due diligence before committing funds.
Who may consider Turkish citizenship by investment?
Turkey offers several investment routes, and the requirements differ by route. The property option is only one of them. Read more on JHM’s Turkey immigration page, and seek advice on how the current rules fit your circumstances before making an investment decision.
Important for Hong Kong residents: people who hold Chinese nationality should obtain professional advice about nationality recognition, travel documents and related arrangements before acquiring another citizenship. Do not assume that dual nationality or travel-document treatment will be recognised in a particular way.
Frequently asked questions
Has Turkey’s property investment threshold increased?
No. The applicable property-investment minimum remains US$400,000. The September 2026 update concerns property valuation procedures, not the minimum threshold.
Can applicants use a valuation firm other than GEDAŞ?
The updated circular allows eligible SPK-authorised firms that meet the relevant TDUB membership and TADEBİS registration requirements. Check the current official requirements and appointment procedure for your case.
How long is a valuation report valid?
For title deed transactions, the updated circular provides a 12-month validity period. A new report may still be required if the report expires or a registry entry affects the property’s value.
This article is for general information only and is not legal, tax or investment advice, nor a guarantee of approval. Requirements and outcomes depend on the applicant, property, documents and current Turkish rules. Official Turkish legislation and guidance prevail; seek qualified advice before acting. Investment involves risk.
John Hu Migration Consulting has 17 years of experience and states that it has assisted more than 6,000 families. JHM provides second-citizenship route assessments and due-diligence support.
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