Work Permit for Foreign Shareholder-Managers in Turkey 2026: TRY 500,000 Capital, 20% Share and 5-Employee Rule

1. The work-permit question depends on the shareholder’s actual corporate role

Foreign investment and foreign share ownership are permitted in Turkey subject to the applicable company and sector legislation. But owning shares and working for the company are separate legal questions. International Labour Force Law No. 6735 regulates the foreigner’s right to work, while the Turkish Commercial Code regulates the company’s legal structure, management and representation.

The Ministry’s current guidance identifies active corporate roles that fall within the work-permit framework. A foreign shareholder who is a manager of a Turkish limited liability company, a foreign shareholder serving as a board member of a joint-stock company, and a managing partner in a partnership limited by shares can require work authorisation. The decisive issue is not whether the person receives a monthly salary; it is whether the person actually performs a corporate management or working function that falls within the legislation.

A foreign investor should therefore review the trade-registry record, articles of association, manager or board appointment and signature authority before beginning operational management in Turkey. The legal title used in those records must be consistent with the work-permit application.

2. The current shareholder criterion begins with TRY 500,000 paid-in capital

The Ministry’s 2026 evaluation criteria state that the workplace’s paid-in capital must be at least TRY 500,000 in a foreign company-partner work-permit application. This is a workplace-level threshold and should be documented through current company records and the financial documents accepted in the e-İzin process.

The same criteria require the foreign shareholder’s own capital amount in the company to be at least TRY 500,000 unless the special USD 100,000 capital-share exception applies. A nominal shareholding that produces a smaller capital amount will therefore not satisfy the general shareholder criterion merely because the company itself has enough total capital.

Capital records should reflect amounts that have actually been registered and paid in as required by company law. A future capital-increase plan is not the same as a completed increase registered in the commercial registry. When the permit strategy depends on increasing capital, the corporate transaction should be completed before the work-permit filing unless the Ministry’s applicable procedure states otherwise.

3. The foreign shareholder must generally hold at least 20%

The Ministry’s current shareholder criteria also require the foreigner’s shareholding to be at least 20%. This threshold is separate from the TRY 500,000 amount. A foreigner can therefore fail the general rule in two different ways: by holding a percentage below 20%, or by holding at least 20% but having an attributable capital amount below TRY 500,000.

The percentage should be verified from current trade-registry and share records. Informal beneficial ownership, an unsigned share-transfer agreement or a planned future transfer does not replace the legally registered corporate position on which the application is assessed.

For international groups using nominee structures or layered ownership, the Turkish applicant should establish exactly who the direct shareholder is and what corporate office the foreigner holds. The work-permit category should correspond to the legal person shown in official records.

4. The general shareholder rule requires five Turkish citizens per foreign shareholder permit

The Ministry’s current criteria require at least five Turkish citizens to be employed at the workplace for each foreign company shareholder for whom a work permit is requested. The requirement is linked to the workplace and the number of foreign shareholder permits.

If two foreign shareholder-managers each require permits, the company should not assume that five Turkish employees automatically satisfy both applications. The Ministry’s wording is based on five Turkish citizens for each foreigner covered by the criterion. The exact headcount should be tested against current SGK records for the relevant months.

The employee count should consist of genuine insured employment. A company should not create temporary paper payroll entries solely to satisfy the threshold. SGK records, workplace operations and employment documentation should reflect real employment.

5. On a first shareholder permit, the five-employee rule begins from month seven

The Ministry’s current shareholder criteria contain an important first-permit timing rule. For the first work permit granted to a foreign company shareholder, the requirement to employ at least five Turkish citizens begins from the start of the seventh month of the permit period.

This gives a newly operating business a limited initial period to establish operations and build its Turkish workforce. It does not remove the employment criterion from the permit. Once month seven begins, the workplace must satisfy the five-Turkish-employee requirement unless another published exemption applies.

Founders should therefore create a compliance calendar when the first permit is issued. Recruitment, SGK onboarding and payroll should be completed early enough that the workplace is compliant when the seventh month begins rather than reacting after the threshold date has passed.

6. A foreign shareholder capital share of at least USD 100,000 changes the criteria

The Ministry’s current page expressly states that where the foreign shareholder’s capital share is at least USD 100,000, the company-partner criteria relating to the capital/share threshold and the five-Turkish-employee requirement are not applied. This is a specific Ministry criterion and should be documented precisely.

The exception is based on the foreign shareholder’s capital share, not merely the total value of the Turkish company or a general group investment. The application file should therefore demonstrate the foreigner’s qualifying capital participation through the corporate and financial records accepted by the Ministry.

An investor should not confuse this work-permit criterion with citizenship-by-investment thresholds, foreign direct investment classifications or other regulatory amounts. Each legal regime has its own statutory purpose and documentary requirements.

7. Joint-stock company board members require a resident/role analysis

The Ministry distinguishes between active foreign shareholder board members and some non-resident board members for work-authorisation purposes. A foreign shareholder who is a board member and actively works within the Turkish company can fall within the work-permit requirement. By contrast, the Implementing Regulation’s Article 48 contains a time-limited exemption category covering non-resident joint-stock company board members within its stated conditions.

The corporate record should therefore show whether the foreigner is a shareholder, board member, signatory and active manager. Physical presence in Turkey and the duration and nature of the activities matter when considering the Article 48 exemption.

A long-term executive role should not be structured as repeated short exemption periods if the actual arrangement is continuing management work. Where the facts show continuing work in Turkey, the appropriate permit route should be used.

8. A limited-company foreign shareholder-manager normally requires work authorisation

A Turkish limited liability company is managed by one or more managers under the Turkish Commercial Code. Where a foreign shareholder is appointed as manager and performs management functions in Turkey, the Ministry’s work-permit system treats that role as one requiring work authorisation unless a specific exemption applies.

The manager appointment, shareholding and signature authority should be consistent across the articles of association, commercial-registry announcements and work-permit application. A person who is shown as manager in the registry but applies as if he or she were a passive investor can create an avoidable inconsistency.

If the foreign shareholder will not manage the business, the company should structure and record that position accurately. A passive non-managing shareholding has a different work-authorisation analysis from active management.

9. Passive share ownership is not the same as active work

The work-permit legislation regulates work, not passive investment by itself. The Ministry’s exemption framework recognises certain non-managing shareholders and non-resident board members within Article 48. This confirms the importance of distinguishing passive ownership from operational work.

A passive shareholder who visits Turkey for a shareholder meeting is not automatically in the same position as a manager who directs employees, signs operational contracts and runs the business day to day. The actual activities performed during the visit should be compared with the statutory exemption and permit categories.

Calling an operational executive a “passive shareholder” in internal documents does not alter the facts. During an inspection or later permit review, the authorities can examine trade-registry information, signature authority, contracts and workplace activity.

10. The e-İzin file should prove the company and shareholder criteria directly

A shareholder-manager application is submitted through the Ministry’s electronic work-permit system under the applicable domestic or overseas route. The application must connect the foreigner to the Turkish company through current trade-registry documents and identify the management role and proposed work.

The company should prepare current capital records, shareholding documents, SGK employee information and any financial evidence requested by the system. The foreigner’s passport and professional or educational documents should be prepared in the legally accepted form, including translations where required.

If the application relies on the USD 100,000 exception, the evidence should make the qualifying foreign shareholder capital amount clear rather than expecting the Ministry to infer it from a complex company structure.

11. Salary criteria can still matter for the managerial work relationship

The Ministry publishes salary multiples linked to the foreigner’s job. Under the current general rules, senior managers generally require a declared wage at least five times the gross minimum wage, while other managers generally require at least three times the gross minimum wage. The correct category depends on the actual position.

For shareholder-managers, the corporate and immigration file should describe compensation accurately. A manager’s remuneration, dividend rights and capital position are legally different concepts. Dividend income from share ownership does not automatically substitute for the salary information requested in a work-permit application where salary criteria apply.

The position stated in e-İzin should correspond to the commercial-registry role and real authority. Reducing the title artificially to meet a lower salary multiple can create inconsistency.

12. Extension applications test continued compliance throughout the permit period

The Ministry’s shareholder criteria expressly state that, for an extension application, the five-Turkish-employee requirement must have been satisfied in each month throughout the permit period where the criterion applies. It is therefore not sufficient to hire five Turkish citizens only shortly before the renewal filing.

The company should monitor monthly SGK headcount from the seventh month of the first permit onward, and throughout later permit periods. Departures should be replaced promptly enough to avoid a month that falls below the required number.

The extension itself must be filed within the ordinary legal window: during the final 60 days before the existing permit expires and before the expiry date. A late filing is not treated as a normal extension.

13. Managing without the required permit creates separate employer and foreigner exposure

Where a foreign shareholder actually works or manages without the required work permit or valid exemption, Law No. 6735 Article 23 can apply. In 2026, the Ministry’s official fine table sets separate administrative fines for the employer and the foreign worker, with a distinct amount for unauthorised independent work where that classification applies.

The existence of a company, capital investment or residence permit does not cure unauthorised work. The correct work-authorisation status must be in place before the foreigner performs the role that requires it.

For the 2026 sanctions, see Working Without a Permit in Turkey: 2026 Fines. For short corporate exemptions, see Turkey Work Permit Exemption 2026.

Conclusion

A work permit for a foreign shareholder-manager in Turkey in 2026 is governed by the foreigner’s actual corporate role and the Ministry’s current shareholder criteria. Under the general rule, the workplace and the foreign shareholder must each meet the TRY 500,000 capital threshold, the foreigner must hold at least 20%, and five Turkish citizens must be employed for each foreign shareholder permit. For a first permit, the five-employee condition begins at month seven; extensions require continuous monthly compliance. A foreign shareholder capital share of at least USD 100,000 removes the listed shareholder capital/share and five-employee criteria. The corporate registry, SGK records and work-permit file should be planned together before the foreign investor begins active management.