Turkey Work Permit Cancellation and the 15-Day Notification Duty: Law No. 6735 Article 22

1. Article 22 creates an express 15-day notification duty

The International Labour Force Law does not treat the grant of a permit as the final compliance event. Article 22 regulates notification and social-security obligations after authorisation. Employers employing foreigners and foreigners holding independent or indefinite work permits must notify the Ministry of the commencement and end of work and circumstances that require cancellation of a work permit or work-permit exemption within 15 days.

The deadline is a statutory compliance period, not a recommendation. An employer that completes the SGK termination but leaves the work-permit relationship open can therefore have inconsistent public records. The reverse is also possible: an immigration notification does not replace SGK termination or employment-law documentation.

International HR teams should integrate Article 22 into the same workflow used for hiring, resignation, dismissal, corporate transfer and change of status.

2. The duty falls on both employers and specified foreign permit holders

For dependent foreign employees, the employer is a central addressee of the notification obligation. The company should not assume that the worker will close the permit file personally after leaving the job. The employing legal entity has its own responsibility under the Law.

Foreigners with independent work permits and foreigners with indefinite work permits also have statutory notification duties. That reflects the fact that these persons may not have an ordinary dependent employer responsible for every change in their working status.

Where an authorised representative manages the electronic file, the underlying legal responsibility still belongs to the persons identified by the statute. Companies should ensure that their service agreement with an immigration provider does not obscure internal responsibility for providing timely factual information.

3. The duty covers commencement, termination and cancellation-triggering circumstances

Article 22 expressly refers to the start and end of work and to circumstances that require cancellation of the permit or exemption. The exact action in the Ministry system depends on the type of permit and event, but the compliance principle is the same: the administrative record must reflect the actual working relationship.

Typical events include the employee actually starting work, the employment ending, the independent activity ending, closure of the underlying business, or another factual change that removes the legal basis on which the permit was issued. A material corporate or professional change should be reviewed before implementation to determine whether it is merely reportable or requires a new application.

The safest approach is not to wait for the 15th day. Once the legally relevant event occurs, collect the supporting records and submit the notification promptly.

4. Employer-initiated termination does not automatically complete immigration closure

When a foreign employee is dismissed, Turkish employment-law steps—termination notice, payment of accrued rights, severance or notice compensation where applicable, unused annual leave, and SGK exit—must be handled according to the governing employment rules. The work-permit notification is an additional immigration obligation.

The termination date used in the Ministry record should be consistent with the actual employment and SGK records. Artificially extending a work-permit relationship after the person has stopped working can create inconsistencies; backdating an immigration notice can create a different problem.

If the employee will move immediately to a different employer, the new company must handle its own work-permit application. The former employer’s permit cannot be transferred simply by closing one payroll and opening another.

5. Employee resignation also triggers a compliance review

Article 22 is not limited to dismissals. If the foreign employee resigns, the employer should process the end of work through the Ministry procedure within the statutory period and complete the separate employment and SGK actions.

The foreigner should also understand the immigration consequence. Because a valid work permit generally counts as a residence permit under Law No. 6458 Article 27, the end of the work-permit status can also affect the legal basis for remaining in Turkey. The person may need to obtain a residence permit appropriate to a new purpose.

International employees should therefore avoid treating resignation as purely an HR matter. Immigration status, planned travel and a new employer application should be coordinated before the final work date where possible.

6. A different employer normally requires a new application, not a notification-only transfer

The Ministry’s current application rules state that an application to work for a different employer is assessed under the procedures and principles of an initial application. The Article 22 notification duty therefore cannot be used to convert an employer-specific permit from Company A to Company B.

Within the same legal employer, changes in workplace, job title or other permit information can also require action. The correct procedure depends on whether the change is within the scope of an update/notification mechanism or changes the legal basis enough to require a new application.

For corporate groups, separate legal entities remain separate employers. Common shareholders, branding or management do not by themselves make one company’s permit valid for another company.

7. Independent and indefinite permit holders must keep the Ministry informed

An independent work permit is issued for own-account work and a definite period. If the underlying independent activity ends, the foreigner cannot simply keep an obsolete work record while no longer performing the authorised business. Article 22 places notification duties directly on independent permit holders.

Indefinite work-permit holders have broader continuing work rights, but they also remain subject to notification duties. “Indefinite” does not mean “no further administration.” Their permit document must also be renewed every five years under the current rules.

Foreign founders should align Ministry notifications with trade-registry, tax-office and SGK changes when a business closes, changes form or ceases operations.

8. Article 22 also preserves social-security obligations

The same Article 22 framework requires foreigners and employers to fulfil their social-security obligations within the legal periods under Law No. 5510, subject to Turkey’s international social-security agreements. Immigration compliance and SGK compliance must therefore run in parallel.

A Ministry notification does not close SGK employment. Likewise, an SGK exit declaration does not automatically notify the work-permit authority of every Article 22 event. Internal procedures should assign responsibility for both systems and confirm completion.

Where a bilateral social-security agreement applies, contribution obligations can differ, especially for temporary assignments. That treaty analysis does not remove the separate work-permit notification duty unless the law specifically provides otherwise.

9. Work-permit cancellation can change the foreigner’s residence position

Law No. 6458 Article 27 generally treats a valid work permit as a residence permit. The immigration regulation states that the end date of the work permit is also the end date of the residence status supplied by that work permit. A foreigner whose work permit ends should therefore determine immediately whether another lawful basis allows continued stay.

Possible residence routes depend on actual circumstances, such as family status, study, property ownership, business connections or another ground listed in the Foreigners and International Protection Law. The correct category must be applied for according to the statutory procedure; it is not created automatically by former employment.

For a detailed residence analysis, see Does a Turkey Work Permit Count as a Residence Permit?.

10. The official 2026 notification fine is TRY 6,805 per foreigner

The Ministry of Labour and Social Security’s official 2026 administrative-fines table sets the fine for each foreigner where the statutory notification obligation is not fulfilled at TRY 6,805 for the responsible employer, independent worker or indefinite-permit holder. The amount was adjusted under the annual revaluation mechanism.

This fine is separate from the much larger sanctions for employing a foreigner without a work permit. A validly authorised employee can therefore still give rise to a notification fine if the employer misses the required Article 22 filing.

Under Article 23, repeated violations are subject to an increased administrative fine. Companies that have already received a notification sanction should strengthen the internal deadline process rather than treating the amount as an ordinary business expense.

11. Permit cancellation decisions can be challenged within 30 days

The Ministry’s current FAQ states that decisions refusing, cancelling or terminating a work permit are notified to the employer or foreigner. An interested party may object within 30 days from notification. If the administrative objection is rejected, proceedings can be brought before the administrative courts.

A cancellation objection should address the stated statutory ground. If the decision is based on a factual assumption—such as the employment having ended or a permit condition no longer existing—the objection should include official records proving the contrary if that is the case.

Submitting an objection does not justify continuing unauthorised work where the permit is no longer effective. The immediate legal effect of the decision must be analysed separately.

12. Keep a dated record of the event and the notification

For each foreign worker, the personnel file should show the event date, the document triggering the change, the electronic notification date and confirmation or receipt from the Ministry system. That evidence is valuable if a later inspection questions whether the 15-day requirement was met.

For resignations, retain the written resignation and SGK exit record. For dismissal, retain the termination notice and payroll records. For business closure or corporate change, retain trade-registry documents. For independent workers, preserve the records showing when the authorised activity ended.

Electronic screenshots alone should not be the only record if the system provides an official confirmation document or reference number. Store the official electronic output in the compliance file.

13. A simple HR workflow prevents missed Article 22 deadlines

At onboarding, record the permit type, employer, job, workplace, permit expiry and Ministry application number. At any planned change, ask whether the event affects permit validity before HR completes the employment action. On termination or resignation, trigger the Article 22 notification task alongside SGK exit and final payroll.

At least two responsible persons should have access to the compliance calendar so that holidays, staff turnover or absence of one administrator do not cause a missed deadline. The company should also monitor work-permit expiry separately because extension applications have their own final-60-day filing window.

For the 2026 monetary sanctions, see Working Without a Permit in Turkey: 2026 Fines. For employer transfers, see Changing Employer on a Turkey Work Permit.

Conclusion

Turkey work-permit cancellation and notification is governed by Law No. 6735 Article 22. Employers and covered foreign permit holders must notify the Ministry within 15 days of the start or end of work and circumstances requiring cancellation of a permit or exemption. The 2026 notification-breach fine is TRY 6,805 per foreigner for the responsible person. The immigration notification must be coordinated with employment termination, SGK, residence status and any new-employer application rather than handled as an isolated formality.