Working Without a Permit in Turkey: 2026 Fines for Employers and Foreign Workers Under Law No. 6735

1. Law No. 6735 requires authorisation before work begins

The International Labour Force Law applies to foreigners who work or apply to work in Turkey, foreigners undergoing vocational training or internships in the situations covered by the Law, cross-border service providers and the natural or legal persons who employ or apply to employ foreign workers. The core compliance rule is that a foreigner within the Law must obtain a work permit or lawful work-permit exemption before beginning work unless a separate statute or international agreement removes that requirement.

Whether a person is “working” depends on the real activity, not merely the label used in a contract. Calling a foreigner a volunteer, consultant, shareholder, guest or trainee does not eliminate work-permit rules if the facts amount to work covered by the legislation. The employer should classify the role before the person starts performing duties.

A valid work-permit exemption is different from having no authorisation. A foreigner who fits Regulation Article 48 and obtains the exemption document works within an authorised exemption. A person who simply assumes that a short stay is exempt does not gain protection from the Article 23 fine.

2. The 2026 employer fine is TRY 102,503 for each unauthorised foreign worker

The Ministry’s official 2026 administrative-fines table sets the employer fine at TRY 102,503 for each foreigner employed without a work permit. The “for each foreigner” wording is commercially significant. If an employer has three unauthorised foreign workers, the violation is not treated as one workplace-level event for the purpose of the stated fine; the amount is applied per foreign worker.

The employer-side fine is separate from the fine imposed on the foreign worker. Paying the employer fine does not legalise future work and does not substitute for obtaining the required permit. Work should stop or be brought within lawful authorisation in accordance with the applicable procedure.

A company should also investigate how the unauthorised work occurred. Common causes include a missed renewal date, an employee beginning before a new-employer permit is granted, a shareholder-manager assuming share ownership is enough, or a short-term foreign technician exceeding an Article 48 exemption period.

3. A dependent foreign worker faces a TRY 40,977 fine in 2026

A foreigner who works dependently without the required work permit is subject to a separate administrative fine of TRY 40,977 under the Ministry’s 2026 table. This amount applies to the worker and does not replace the employer’s TRY 102,503 liability.

Dependent work normally involves work for a real or legal person, public body or organisation under an employment or service relationship in a specified job and workplace. A foreign employee’s belief that the employer “handled the permit” does not itself create a permit. Before starting, the foreigner should confirm that the required authorisation has actually been issued or that a lawful exemption applies.

Foreign employees changing companies need particular care. The existing employer-specific permit does not transfer to the new employer. An application to work for another employer is assessed under initial-application rules, and the old permit cannot be used as permission to start work at the new company.

4. Unauthorised independent work carries a TRY 82,010 fine

The Ministry sets the 2026 fine for a foreigner who works independently without the required work permit at TRY 82,010. Independent work refers to own-account activity rather than dependent work for an employer. The fact that the person has no Turkish employer therefore does not place the activity outside work-permit law.

Foreign entrepreneurs should distinguish passive investment from active work. Incorporating a Turkish company or acquiring shares does not itself create work authorisation. If the foreigner actively manages the business, delivers services or otherwise works, the correct permit or exemption category must be determined.

The independent-work fine is relevant to consultants, founders and self-employed professionals who assume that invoicing through a foreign or Turkish entity avoids the need for work authorisation. The real substance of the activity matters.

5. The 2026 notification-breach fine is TRY 6,805 per foreigner

Law No. 6735 Article 22 imposes notification duties on employers of foreign workers and on foreigners with independent or indefinite work permits. They must notify the Ministry of the start and end of work and circumstances that require cancellation of a work permit or exemption within 15 days.

The Ministry’s 2026 table sets the administrative fine for failure to fulfil the statutory notification obligation at TRY 6,805 for each foreigner for the responsible employer or covered foreigner. This is a different violation from employing someone without a permit. A company can therefore have a valid permit yet still create a compliance issue by failing to make a required notification on time.

HR should place the 15-day deadline in the same offboarding and change-of-status process used for SGK and payroll. Immigration notifications should not depend on a single employee remembering the deadline after a resignation or corporate change.

6. Repeated violations are increased by one-fold under Article 23

The Ministry’s current fines page states that, pursuant to Article 23 of Law No. 6735, the administrative fines listed for these violations are increased by one-fold when the acts are repeated. A repeated unauthorised-work problem is therefore materially more expensive than an isolated first violation.

The repeat rule makes documentation important. After a first violation, the employer should record the remedial measures taken: permit verification before onboarding, automated expiry alerts, central responsibility for extension applications and checks on contractors or group-company transfers. Continuing the same weak process can produce a second violation with an increased sanction.

Employers should not calculate repeated fines informally from older published figures. Fine amounts are revalued annually, so the amount in force for the year of the new violation must be used together with the repeat rule.

7. A valid work-permit exemption prevents the case from being treated as unauthorised work within its scope

Article 48 of the Implementing Regulation contains specific exemption categories for activities such as short scientific or artistic work, certain imported-machinery installation and training, qualifying cross-border services, approved internships, sporting activities, tour-operator representatives and specified company roles. The exemption period and conditions differ by category.

An exemption is lawful only within its scope. A technician authorised for a three-month installation assignment cannot use that exemption as permission to remain in ordinary employment after the installation ends. If the activity exceeds the exemption period, the Ministry expressly requires a work permit.

For the full category and duration analysis, see our Turkey Work Permit Exemption 2026 guide.

8. A residence permit does not by itself grant a right to work

A Turkish residence permit authorises residence for the purpose and period granted under Law No. 6458. It does not generally authorise dependent or independent work. The Ministry and Migration Management both state this distinction clearly. A foreigner can therefore be lawfully resident in Turkey and still commit an unauthorised-work violation.

The relationship works differently in the opposite direction: under Law No. 6458 Article 27, a valid work permit or work-permit exemption issued under Law No. 6735 generally counts as a residence permit, subject to statutory exceptions for certain protection statuses. That does not mean an ordinary residence card counts as a work permit.

Employers should never use “the employee has an ikamet card” as the sole onboarding check. The actual work authorisation must be verified.

9. Corporate title does not eliminate the work-permit requirement

Foreign company partners and directors require role-specific analysis. The Ministry’s rules distinguish limited-company shareholder-managers, joint-stock company shareholder board members, non-resident board members and non-managing shareholders. Some roles require work permits; some can fall within Article 48 exemptions for limited periods.

The trade-registry record is therefore part of the work-permit analysis. A foreign founder who signs contracts, directs staff and manages the company should not rely on the argument that “I am an owner, not an employee” without checking the applicable category.

Corporate groups have the same issue. A permit held for Company A does not authorise work for Company B merely because both are controlled by the same parent company.

10. Inspections look at real work, documents and workplace records

In an inspection or administrative review, the authorities can compare the foreigner’s work-permit status with workplace, SGK, payroll, company and identity records. An employer should therefore maintain a clear personnel file containing the permit or exemption, passport information, employment contract, role and relevant application records.

Where the foreigner claims an exemption, preserve the evidence supporting that exact Article 48 category: import and service documents for technicians, program records for interns, contracts for sport personnel, board records for corporate exemptions and other category-specific evidence.

Backdating a contract or creating documents after detection does not retroactively create authorisation. The relevant question is whether the foreigner was legally authorised at the time the work was performed.

11. Work-permit compliance and social-security compliance are separate duties

Article 22 of Law No. 6735 requires foreigners holding permits or exemptions and employers to fulfil their social-security obligations within the legal period under Law No. 5510, while preserving the provisions of Turkey’s international social-security agreements. A work permit therefore does not replace SGK registration.

Conversely, SGK registration does not create a work permit. An employer can enter a foreigner into payroll systems and still be in breach of the work-permit legislation if the necessary authorisation was never obtained.

Cross-border assignments should be reviewed under any applicable bilateral social-security agreement. Treaty coverage can change premium obligations, but it does not itself answer the work-permit question unless the treaty or another rule specifically provides an exemption.

12. Unauthorised work can also create immigration consequences

Administrative fines are not the only legal consequence. Migration legislation treats unauthorised work as relevant to immigration status and removal procedures. The exact consequence depends on the foreigner’s status, facts and applicable provisions, so the work-permit and immigration files should be reviewed together as soon as unauthorised work is detected.

A company should not respond by simply paying the fine and continuing employment. Continued work requires a valid legal basis. The correct response can involve stopping work, filing the appropriate work-permit application, correcting notifications and reviewing residence status.

Foreign workers should also preserve proof of any pending lawful extension. A timely same-employer extension can allow continued work for up to 90 days after expiry while the application is assessed, provided the job and workplace remain unchanged. That statutory bridge is different from unauthorised work after a permit simply lapses.

13. A four-stage employer control prevents most fine exposure

First, classify the role: dependent work, independent work, corporate management or a genuine exemption. Second, verify the actual document before the start date. Third, calendar expiry and extension windows; ordinary extensions must be filed during the final 60 days before expiry. Fourth, integrate the 15-day Article 22 notification duty into HR onboarding and offboarding.

For multinational companies, add a group-company check. Before changing the legal employer, branch, workplace or role, determine whether the existing permit remains valid or a new application is required. The old employer’s permit should never be treated as a portable group permit.

For current employer criteria and salary thresholds, see our Turkey Work Permit 2026 guide. For employer changes, see Changing Employer on a Turkey Work Permit.

Conclusion

Working without a permit in Turkey in 2026 creates separate financial exposure for the employer and foreign worker. The official 2026 amounts are TRY 102,503 per unauthorised foreigner for the employer, TRY 40,977 for a dependent foreign worker, TRY 82,010 for unauthorised independent work and TRY 6,805 for covered notification breaches. Repeated violations are increased by one-fold under Article 23. The legally effective prevention method is not after-the-fact payment; it is verifying the correct permit or exemption before work begins and keeping renewal and notification deadlines under control.