As of 28 September 2026, GEDAŞ is no longer the only company allowed to prepare valuation reports for Turkish citizenship by investment. Following a Ministry of Environment, Urbanization and Climate Change decision (No. 21900458, 18 September 2026), any valuation company holding an SPK licence, active TDUB membership, and TADEBİS registration can now prepare the report. The USD 400,000 minimum investment threshold is unchanged.
For eighteen months, every foreign national pursuing Turkish citizenship through the real estate route had to obtain the valuation report for the property from a single company. On 28 September 2026, that changed. The Directorate General of Land Registry and Cadastre, Tapu ve Kadastro Genel Müdürlüğü, TKGM, issued an office directive, Makam Oluru, updating Circular No. 2024/2, ending the exclusive authority of GEDAŞ over citizenship-purpose valuation reports and reopening the field to every valuation company licensed by the Capital Markets Board that also meets two further conditions. The reform restores choice and speed to a stage of the process that had become a bottleneck, but it also transfers a responsibility back to the applicant that had been absent since March 2024: the responsibility of selecting a valuer whose report will withstand scrutiny not only at the land registry but for years afterwards, since a valuation that does not reflect the real value or the real money that changed hands is the single most common cause of citizenship annulments in this programme. This guide explains what changed, why the restriction existed, the three cumulative conditions a valuation company must now meet, what has not changed, what the reform means for files already in progress, and how to choose a valuer so that the report protects the citizenship it supports rather than endangering it.
Quick Answer: As of 28 September 2026, applicants for Turkish citizenship by real estate investment are no longer required to use GEDAŞ, Gayrimenkul Değerleme A.Ş., for their valuation report. Any valuation company holding a licence from the Capital Markets Board, SPK, active membership in the Turkish Valuation Experts Association, TDUB, and registration in the Real Estate Valuation Information System, TADEBİS, may now prepare the report. The change follows a decision of the Ministry of Environment, Urbanisation and Climate Change dated 18 September 2026, numbered 21900458, given effect by TKGM's directive updating Circular No. 2024/2. The 400,000 United States Dollar minimum investment, the three year resale annotation on the title deed, and the twelve month validity of the report are all unchanged. GEDAŞ may still prepare reports; it has simply lost its exclusivity. Because the applicant must now select the valuer, and because under Article 31 of Law No. 5901 citizenship obtained on the basis of a report that does not reflect the true value may be annulled years after it is granted, the choice of valuation company has become a decision with lasting consequences rather than an administrative formality.
The legal basis for the change is a decision of the Ministry of Environment, Urbanisation and Climate Change dated 18 September 2026, numbered 21900458, which authorised valuation reports used for determinations under the Regulation on the Implementation of the Turkish Citizenship Law to be prepared by any valuation institution licensed by the Capital Markets Board, not only GEDAŞ. TKGM gave effect to that decision on 28 September 2026 with an office directive updating Circular No. 2024/2, the same circular that had granted GEDAŞ its exclusive mandate in March 2024.
Practically, this means that the applicant, or the attorney handling the file, can once again choose which licensed valuation company prepares the report supporting a citizenship by investment application, rather than being routed to a single state-linked provider with a single national queue. The land registry directorates were instructed to accept reports from any company meeting the conditions described in section 3 from that date.
To understand why the new freedom of choice carries a corresponding responsibility, it helps to recall why the restriction existed at all. Before March 2024, applicants could use any valuation company licensed by the Capital Markets Board, and the system had a well-documented weakness. Some valuation reports were inflated to make a property worth considerably less appear to meet the 400,000 United States Dollar threshold, and in other cases a genuine sale was overstated on paper while a much smaller sum actually changed hands, with the difference returned to the buyer outside the banking system. Türkiye's 2025 citizenship fraud investigation, which uncovered roughly 1,198 irregular applications and an estimated 181.2 million United States Dollars in fabricated or diverted capital, traced a substantial share of that fraud to exactly this weak point: a valuation report that did not reflect the property's real value or the real money that moved.
The consequences of those irregular valuations did not fall only on the intermediaries who arranged them. Under Article 31 of Law No. 5901, citizenship acquired on the basis of false statements or the concealment of material facts may be annulled by decision of the authority, and the annulment extends to the spouse and children who acquired citizenship through the principal applicant. In the wake of the investigation, a significant number of foreign nationals who had obtained Turkish citizenship in good faith, relying on a valuation report arranged by an agent or a developer, had their citizenship annulled when the report was found to have overstated the value, in some cases several years after the passport had been issued. The applicant's own lack of knowledge of the inflation was not, in the authority's view, a defence, because the application had been filed on the basis of a figure that was false. These annulments are the clearest illustration of why the valuation report is not a formality: it is the factual foundation of the citizenship, and a defective foundation can be removed at any time.
TKGM's response, effective 4 March 2024 under Circular No. 2024/2, was blunt but effective: exclusive authority for citizenship-purpose appraisals was handed to GEDAŞ, a valuation company under the umbrella of TOKİ, the Housing Development Administration. With one state-linked gatekeeper and no competition, the market for inflated citizenship appraisals largely disappeared. So, however, did the applicant's ability to choose a valuer, and GEDAŞ's turnaround times became a genuine bottleneck for a programme whose attraction depends in part on speed, with reports in busy periods taking many weeks and delaying the conformity letter, the certificate of eligibility, and every subsequent stage.
The September 2026 update does not return to the pre-2024 position in which any licensed appraiser could act. A valuation company preparing a citizenship-purpose report must now meet three conditions at once.
| Condition | What It Means |
|---|---|
| SPK licence | Formal authorisation from the Capital Markets Board, Sermaye Piyasası Kurulu, to carry out real estate valuation activity, listed on the Board's register of authorised valuation institutions |
| Active TDUB membership | The company and the responsible valuation expert who signs the report must be active, not lapsed or suspended, members of the Turkish Valuation Experts Association, Türkiye Değerleme Uzmanları Birliği |
| TADEBİS registration | The company must be registered in the Real Estate Valuation Information System, Taşınmaz Değerleme Bilgi Sistemi, the digital registry through which valuation reports are now generated, tracked, and transmitted to the land registry |
These conditions are cumulative. A company that holds an SPK licence but whose TDUB membership has lapsed, or that is not registered in TADEBİS under the corporate name appearing on the report, does not qualify, and a report from such a company is rejected by the land registry regardless of the quality of the valuation itself.
The reason the Ministry and TKGM were able to reopen the field without reopening the fraud gap is the digital infrastructure built after 2024. Valuation reports produced by any qualifying company are now generated within TADEBİS, connected to Web Tapu, and cross-checked against the land registry file, which prevents a report's figures from being altered between preparation and submission and makes every report traceable to the expert who signed it. GEDAŞ's monopoly was one way to close the gap; a shared, auditable digital trail across every licensed, TDUB-member, TADEBİS-registered company is another, and it no longer requires funnelling every applicant through a single office. The same trail, however, also makes an inflated report considerably easier to trace back to its author, and to the applicant who relied on it, than it was before 2024.
It is worth being precise about the limits of this reform, because overstating it creates real risk for an applicant relying on it.
A property, or a combination of properties, must still be valued at no less than 400,000 United States Dollars for the real estate route to Turkish citizenship by investment. If the valuation comes in below that figure, the file is rejected regardless of the contract price, and if the contract price exceeds the valuation, the lower figure governs.
The title deed annotation preventing resale for three years from acquisition still applies, and the property must be retained for that period. See our guide on removing the three year annotation for how and when it lifts.
A valuation report remains valid for twelve months from issue for citizenship purposes, and must be renewed sooner if the property's registered status changes in the meantime, for example a change of use, a partial expropriation for road widening, yola terk, or a similar registered change.
The land registry checks that the report is complete, properly issued by a qualifying company, and consistent with the registry file; it does not re-verify the valuation figure itself. Responsibility for the accuracy of the report, and liability if it is later found to be wrong, rests with the valuation company and the expert who signed it, and the consequences of an inaccurate report fall on the applicant whose citizenship was built on it.
A generic SPK licence alone is not enough. The TDUB membership and TADEBİS registration conditions are cumulative, and an applicant who is handed a report from a company that fails either test risks having the file rejected on a technicality that has nothing to do with the property's actual value.
For an investor with a file open today, or about to open one, the practical effect is choice. GEDAŞ's exclusivity had become one of the more common causes of delay in an otherwise well-prepared file, since a single institution serving every citizenship-linked valuation nationwide inevitably builds a queue. Being able to instruct any qualifying company again means that the attorney handling the file can select a valuer on the basis of turnaround time, availability, and experience with the property type and location, rather than accepting whatever slot GEDAŞ offers.
The freedom to choose a valuer does not mean shopping for the most generous figure. A report that overstates a property's value to clear the 400,000 United States Dollar line is exactly the pattern that triggered the 2024 restriction and the 2025 investigation, and the TADEBİS trail makes such a report traceable to its author and to the file in which it was used. An inflated report does not merely delay a file if it is caught at the land registry stage; under Article 31 of Law No. 5901 it exposes the applicant to annulment of citizenship already granted, with the spouse and children losing their citizenship alongside the principal applicant, and with the three years invested in the holding period and the fees paid along the way unrecoverable.
Nothing in the September 2026 update suggests that valuation reports already prepared by GEDAŞ under the previous rule are affected. A report issued while the GEDAŞ requirement was in force remains a report validly obtained under the rule that applied at the time, and there is no indication that TKGM intends to require it to be redone. Where a file is mid-process and a GEDAŞ report has been requested but not yet issued, the applicant now has the option to instruct a different qualifying company instead, which may be the faster route depending on GEDAŞ's current queue. Anyone with an open file should confirm the current status with their attorney before assuming either path is automatically quicker, since cancelling a pending GEDAŞ instruction and starting afresh elsewhere is not always the shorter route.
The most important practical consequence of the reform is one that the official announcements do not emphasise. Between March 2024 and September 2026, the applicant had no decision to make about the valuer: the report came from GEDAŞ, and whatever its delays, the applicant could not be blamed for its content. From 28 September 2026 the applicant, or the attorney, selects the valuation company, and with that selection comes responsibility for the consequences of the choice. An applicant who allows the selling developer or an intermediary agent to arrange the valuation, as was common before 2024, is placing the factual foundation of his or her citizenship in the hands of a party whose interest is in closing the sale, not in the durability of the citizenship that follows.
The valuation should be instructed by the applicant's own attorney, independently of the seller, the developer, and any agent who introduced the property. The attorney should verify the three conditions described in section 3 against the current registers before instruction, should review the resulting report against the actual sale price, the bank transfer records, and the Central Bank conformity certificate so that the three figures are consistent, and should sequence the report within the wider timeline so that it does not expire before the land registry appointment or the citizenship application. A report obtained in this way is not only more likely to be accepted at the land registry but, more importantly, is one that the applicant can defend if it is ever examined again.
The annulment cases that followed the 2025 investigation share a common feature: the applicant did not control the valuation and did not know, until the annulment decision arrived, that the figure on which the citizenship rested was false. That risk can be eliminated entirely, not merely reduced, by ensuring that the valuation is independent of the seller, that the valuer is selected for the defensibility of its figures rather than their generosity, and that the sale price actually paid through the banking system, the figure in the valuation report, and the figure declared at the land registry correspond to each other and to the market. Where those three conditions are met there is nothing in the file that a later review could find to be false, and nothing on which an annulment under Article 31 could be based. This is precisely the gap that working with Bayraktar Attorneys closes. Our approach has not changed with this reform: we select and instruct the valuation company ourselves, never through the seller or an agent, we work only with companies whose figures we are confident will hold up under scrutiny, we reconcile the report against the bank transfers and the land registry declaration before the file proceeds, and we treat the valuation report as the document that will be examined if the citizenship is ever questioned, because that is what it is. An applicant whose valuation has been handled in this way can eliminate the annulment risk entirely rather than hoping that a report arranged by someone else will never be looked at again.
Given that eligibility now rests on three separate conditions rather than a single named institution, the following checks should be made before any valuation company is instructed. The company must hold a valid SPK licence for real estate valuation activity, verifiable on the Capital Markets Board's published list of authorised valuation institutions. The company and the responsible expert must hold active, not lapsed or suspended, membership in TDUB, verifiable through the association. The company must hold an active registration in TADEBİS under the same corporate name that will appear on the report. Beyond the formal conditions, the company should have demonstrated experience with citizenship-purpose valuations specifically, since these reports are reviewed against the land registry file in a way that ordinary mortgage or insurance valuations are not, and should have experience with the property type and district concerned. A company that meets all three formal conditions but has no track record with citizenship reports is a different risk from one that is simply unqualified, but for an investment of 400,000 United States Dollars tied to citizenship status, a firm with demonstrated experience in citizenship valuations is preferable to a generalist appraiser in either case. Finally, the instruction should come from the applicant's side, never from the seller's, for the reasons given in section 6.
Yes. Nothing about the requirement for a valuation report has changed, only who is allowed to prepare it. Every real estate route application still needs a report confirming that the property meets the 400,000 United States Dollar threshold.
GEDAŞ can still prepare reports; it has lost its exclusivity. It remains one of the qualifying SPK-licensed, TDUB-member, TADEBİS-registered companies, but is no longer the only one.
TKGM issued an office directive updating Circular No. 2024/2, implementing a Ministry decision of 18 September 2026, numbered 21900458, that allows any valuation company meeting the three conditions to prepare citizenship-purpose reports.
The report is rejected at the land registry. The three conditions, SPK licence, active TDUB membership, and TADEBİS registration, are cumulative.
No. The minimum investment for the real estate route is unchanged, and a report valuing the property below that figure still results in rejection regardless of the contract price.
Twelve months from the date of issue, and it must be renewed sooner if the property's registered status changes, for example a change of use or a partial expropriation.
If the GEDAŞ report has already been issued, it remains valid and there is no indication it needs to be redone. If it is still pending, you may now instruct a different qualifying company, but confirm with your attorney which path is actually faster for your file.
No. TKGM's review is formal: it checks that the report is complete and issued by a qualifying company. Responsibility for the figure rests with the valuer, and the consequences of an incorrect figure fall on the applicant.
Yes. Under Article 31 of Law No. 5901, citizenship obtained on the basis of a report that overstated the value may be annulled, together with that of the spouse and children, and this has happened to applicants who relied in good faith on reports arranged by agents or developers.
The buyer, through his or her own attorney. A valuation arranged by the seller, the developer, or the introducing agent places the foundation of the citizenship in the hands of a party whose interest is in closing the sale.
You can, but you should not. An inflated figure is traceable through TADEBİS, is the pattern that led to the 2024 restriction and the 2025 investigation, and exposes you to annulment years after citizenship is granted.
Check the Capital Markets Board's list of authorised valuation institutions, confirm active TDUB membership of the company and the signing expert, and confirm TADEBİS registration under the same corporate name that will appear on the report.
The valuation figure governs for citizenship purposes. If it is below 400,000 United States Dollars, the property does not qualify on its own, although it may be combined with another property to reach the threshold.
It removes one bottleneck. The valuation stage, which had depended on GEDAŞ's national queue, can now be completed by a company selected for availability, but the remaining stages of the process are unchanged.
The directive concerns citizenship-purpose reports under the Citizenship Law Regulation. Valuation reports for ordinary property purchases by foreigners and for residence permits were never subject to the GEDAŞ requirement and continue under the general rules.
By ensuring that the valuation is independent of the seller, prepared by a qualifying company selected for the defensibility of its figures, and consistent with the price actually paid through the banking system and the value declared at the land registry. Working with Bayraktar Attorneys, which instructs and reviews the valuation as part of a supervised file, ensures that those three figures correspond to each other and to the market, leaving nothing in the file on which an annulment could be based.
The end of GEDAŞ's exclusivity on 28 September 2026 is a welcome reform for a programme in which delay had become the principal complaint, and the three cumulative conditions of SPK licence, TDUB membership, and TADEBİS registration, together with the digital trail through which every report now passes, mean that the reopening of the field need not reopen the fraud that closed it in 2024. The reform's less visible consequence is that the choice of valuer, and with it the durability of the citizenship, is once again in the applicant's hands. The annulments that followed the 2025 investigation fell on applicants who had not made that choice themselves and did not know what had been done in their name. An applicant who instructs the valuation independently, through an attorney who verifies the valuer's standing and reviews the report against the real transaction, removes that risk entirely and obtains a citizenship that rests on a foundation no later review can disturb.
We instruct valuation companies on behalf of our citizenship by investment clients as part of a fully supervised file: checking SPK, TDUB, and TADEBİS status before instruction, reviewing the resulting valuation report against the underlying sale and the bank records, and sequencing it correctly within the wider citizenship by investment timeline. If you have a file open with GEDAŞ, or are starting a new application and want to know which valuation company can move quickest and most safely for your property, our legal team can advise on the current landscape and handle the instruction directly.
