Turkish Citizenship by Government Bonds: $500,000 and 3-Year Holding Rule

1. Government-bond citizenship is a regulated exceptional-investment route

Article 12 of Turkish Citizenship Law No. 5901 and Article 20 of the implementing regulation form the legal basis. The President determines the qualifying investment categories and amounts, while the relevant institution confirms whether the specific investment meets the condition.

For government debt instruments, the current official threshold is at least USD 500,000 or qualifying equivalent, with a three-year holding commitment and conformity determination by the Ministry of Treasury and Finance.

Citizenship remains subject to a separate administrative decision and security/public-order review after the investment requirement is confirmed.

2. The qualifying instrument must fall within the official government-debt category

The route is designed for government debt instruments recognised under the applicable Treasury procedure. Investors should not assume that every security issued by a state-owned company, municipality, private bank or Turkish corporation is a qualifying “government bond.”

Before purchase, obtain written confirmation from the intermediary/custodian as to the instrument type and whether it can be used in the citizenship conformity process.

A corporate Eurobond or private debt security can have Turkish exposure without being the government debt instrument contemplated by the citizenship regulation.

3. The minimum investment is USD 500,000

The current threshold is USD 500,000 or qualifying equivalent. The investment file should show the acquisition value used for the official determination, transaction date, quantity, instrument identification and investor identity.

A portfolio whose gross market value temporarily exceeds USD 500,000 is not enough if the actual qualifying purchase does not meet the official threshold.

Conversely, later market fluctuations should be distinguished from the original qualifying investment and holding commitment. The Treasury procedure controls how value is assessed.

4. Custody records are central evidence

Government debt instruments are held through securities/custody accounts rather than through a paper title deed. The investor should preserve account-opening records, trade confirmations, custody statements and any citizenship restriction/commitment record applied through the financial institution.

The custody account must clearly identify the investor. Nominee, joint or corporate ownership structures should be reviewed before purchase because the conformity application must connect the qualifying investment to the citizenship applicant.

Changing custodians during the commitment period should not be done without confirming that the citizenship restriction and traceability remain intact.

5. The three-year no-sale commitment is substantive

The investor must undertake not to sell the qualifying government debt instruments for at least three years. This commitment distinguishes a citizenship investment from ordinary active bond trading.

Maturity dates should be considered before purchase. An instrument maturing before the required commitment is completed can create reinvestment/continuity issues that should be resolved in accordance with the Treasury’s current procedure rather than improvised later.

Portfolio managers should be informed that the position is subject to a citizenship holding commitment so it is not automatically sold or switched as part of routine discretionary management.

6. Bond prices can move during the holding period

Government debt instruments have market-value risk. Interest-rate changes, currency movements and remaining maturity can increase or decrease market price even where the issuer continues to perform.

The citizenship threshold and conformity determination should therefore be distinguished from investment performance. The investor can satisfy a legal citizenship condition while experiencing investment gain or loss.

Legal advice on citizenship does not replace financial advice about duration, currency and credit/market risk.

7. Coupon or interest income is separate from the restricted principal

Qualifying bonds can generate coupon/interest payments depending on their terms. The citizenship condition focuses on maintaining the qualifying investment; income distributions should be handled in accordance with the custody and restriction arrangement.

An investor should confirm whether coupon proceeds can be withdrawn without affecting the restricted qualifying principal. Do not assume the treatment without checking the financial institution and official procedure.

Tax on bond income is a separate tax-law matter and can depend on instrument, investor residence and treaty rules.

8. The Ministry of Treasury and Finance confirms conformity

NVI identifies the Ministry of Treasury and Finance as the determining institution for the government-debt route. The conformity certificate confirms that the investment condition under the citizenship regulation has been met.

The investor should not treat a broker statement saying “eligible for citizenship” as equivalent to the Ministry’s determination. Private institutions facilitate the transaction; the statutory authority makes the conformity determination.

After conformity, the investor proceeds through investor residence and the nationality application.

9. Securities purchases remain subject to financial compliance

The financial institution can request evidence concerning source of funds, tax residence, sanctions and beneficial ownership. Citizenship investment does not exempt the investor from Turkish banking/capital-market compliance.

Keep the transfer trail from the original source account through settlement of the bond purchase. Large unexplained third-party transfers can complicate both financial onboarding and citizenship documentation.

Foreign source documents should be translated/legalised where required for the administrative file.

10. Early sale can jeopardise the investment basis

Selling the qualifying position before completing the three-year commitment can cause the investment to cease satisfying the regulatory condition. Any planned sale, redemption, switch, pledge or restructuring should be reviewed first.

Automatic redemption at maturity can also require attention where it occurs during the commitment. The investor should plan maturities around the citizenship restriction.

After the three-year period is completed, preserve official evidence that the holding requirement was satisfied before changing the portfolio.

11. Investor residence is a separate stage

NVI’s current process includes short-term investor residence under Article 31(1)(j) of Law No. 6458 after conformity. This residence basis differs from tourism, property or family residence.

The conformity certificate, passport and civil-status documents should use consistent identity information. Any passport renewal or name change during the process should be documented.

Residence approval and citizenship approval remain separate administrative steps.

12. Spouse and qualifying children need their own evidence

The investor’s spouse and qualifying minor/dependent children can fall within the exceptional-investor framework. Marriage, birth and dependency records must be legally usable in Türkiye.

Where prior marriages, custody or name changes exist, resolve the civil-status chain before the citizenship file reaches final review.

Adult children should not be treated as automatically included without analysing dependency and the current statutory requirements.

13. Government bonds and bank deposits are legally distinct despite the same headline threshold

Both routes currently use a USD 500,000 minimum and a three-year commitment, but the assets and determining authorities are different. Bank deposits are confirmed by BDDK; government debt instruments are confirmed by the Ministry of Treasury and Finance.

Deposit risk centres on bank/account structure and liquidity; bond risk includes securities custody, market value and maturity. The correct route depends on the investor’s commercial objectives, not only the citizenship threshold.

See our bank-deposit citizenship guide for the separate banking route.

14. Keep a securities-specific citizenship file

Preserve passport/identity documents, source-of-funds records, securities-account contracts, trade confirmations, instrument identifiers, custody statements, restriction/undertaking documents, conformity certificate, investor residence and family civil-status documents.

Do not rely on a generic investment statement that does not identify the security and transaction. The Ministry must be able to verify the qualifying investment.

Bakırcı & Keskin Hukuk Bürosu has one physical office in Mersin. Foreign-investor citizenship files throughout Türkiye can be coordinated from Mersin subject to competent authorities and procedural rules.

Conclusion

Turkish citizenship by government bonds requires a qualifying USD 500,000 investment, a three-year no-sale commitment and Ministry of Treasury and Finance conformity. The legal file should control securities identity, custody, valuation, maturity, holding restriction, source of funds, residence and family records. This route can avoid property-title risk but adds capital-market and duration risk that must be managed separately.