Legal Risks, Administrative Lawsuits, and Solutions (2026 Updated Guide)
Foreign investors applying for Turkey citizenship through investment frequently include their spouse and children in the same application file. However, one issue has recently become one of the most critical and controversial problems in Turkish citizenship by investment applications:
What Happens If a Child Turns 18 During the Turkish Citizenship Application Process?
In recent years, Turkish administrative authorities have increasingly rejected dependent child applications where the child turned 18 during the evaluation process — even though the child was under 18 at the application date.
This issue has become particularly important for families applying for:
If not handled correctly, this situation may lead to partial rejection of the family application and force applicants into complex administrative litigation procedures in Turkey.
This 2026 updated legal guide explains:
Under Turkish Citizenship Law No. 5901, foreign nationals may obtain Turkish citizenship through several investment routes, including:
One of the major advantages of the Turkish Citizenship by Investment Program is the ability to include family members in the same application file.
Applicants may generally include:
within the same citizenship application.
Applications are reviewed by the General Directorate of Population and Citizenship Affairs after security investigations and administrative examination procedures.
Legally, the determining factor for dependent child eligibility is whether the child was under 18 at the application date.
Turkish citizenship by investment applications often remain under review for several months due to:
As a result, a recurring legal issue has emerged in practice:
This interpretation has triggered serious legal debate among Turkish immigration lawyers and administrative law practitioners.
In earlier Turkish citizenship by investment cases, authorities generally adopted a more flexible interpretation.
When a child turned 18 during the evaluation process:
This approach was consistent with the principle that eligibility should be evaluated according to the application date rather than the decision date.
In recent years, despite no amendment to Turkish Citizenship Law No. 5901, administrative interpretation has changed significantly.
Authorities increasingly:
Importantly, this change appears to stem from administrative interpretation rather than legislative reform.
This has become one of the most common hidden risks in Turkish citizenship by investment applications involving dependent children.
Under general principles of Turkish administrative law, applications should generally be assessed according to the legal and factual circumstances existing at the date of application.
Therefore, if:
subsequent administrative delays should not automatically result in loss of rights.
Otherwise, investors may effectively be penalized for delays entirely outside their control.
Foreign investors often make substantial investments in Turkey relying on the legal framework existing at the time of application.
Once applicants fully satisfy legal requirements, a legitimate expectation arises.
Administrative reinterpretations that later invalidate previously compliant applications may conflict with:
Another major issue concerns family unity.
In many recent Turkish citizenship by investment cases:
This creates serious proportionality concerns and may undermine the purpose of family-based citizenship procedures in Turkey.
Applicants facing rejection may file an annulment action before the competent Turkish Administrative Court.
These lawsuits challenge the rejection decision issued by the General Directorate of Population and Citizenship Affairs.
Common legal arguments include:
Depending on the circumstances, applicants may also request:
A foreign investor family applied for Turkish citizenship through real estate investment in Turkey.
At the application date:
However, due to prolonged administrative review procedures, the child turned 18 before the final decision.
The family later received partial approval:
In such cases, annulment litigation before Turkish Administrative Courts may become the primary legal remedy.
Yes, it is legally possible but requires careful navigation of administrative procedures. Your child may need to file an independent application as an adult, or pursue an annulment lawsuit Turkey to challenge the exclusion. The success of either approach depends on the specific circumstances, timing, documentation quality, and legal arguments presented. Consulting with an experienced Turkish citizenship lawyer is essential for determining the best strategy for your situation.
Turkish Administrative Court proceedings typically require 12 to 24 months for a first instance decision. Appeals to the Council of State (Danıştay) can add another 12 to 18 months. However, courts may grant a stay of execution (yürütmenin durdurulması) while the case is pending, potentially allowing the child's citizenship to be processed during litigation.
Generally, the child's existing residence permit remains valid until its expiration date. However, renewal applications may become complicated if the Turkish citizenship application is rejected or suspended. Maintaining valid residence status throughout the process is essential.
Transferring property after the initial Turkish citizenship through real estate investment valuation may affect the application's eligibility. Property transfers involving minors require guardianship court approval. Any transfers should be carefully documented to demonstrate continuity of the qualifying investment.
Essential documentation includes: (1) Original application submission date and receipt, (2) Birth certificate proving the child's age at application time, (3) Investment documentation showing compliance with thresholds, (4) The official rejection or exclusion decision letter, (5) All correspondence with the General Directorate, (6) Evidence of the child's ties to Turkey including school records and residence history.
Administrative lawsuit costs in Turkey include court fees (based on the claimed amount), legal representation fees (which vary based on complexity), and potential expert witness costs. Given the significance of citizenship rights and family unity, these cases represent a valuable investment in protecting your family's future in Turkey.
Cases involving dependent children turning 18 during Turkish citizenship applications are highly technical and require detailed knowledge of:
Effective legal representation may involve:
Every case should be assessed individually according to:
If your family's Turkish citizenship by investment application has been rejected because your child turned 18 during the evaluation process, obtaining immediate legal assessment is critical.
Professional legal support may help:
Each Turkish citizenship case requires a tailored legal strategy based on the administrative file and procedural history.
Although Turkish Citizenship Law No. 5901 has not changed, recent administrative practice regarding dependent children turning 18 during Turkish citizenship by investment applications represents a significant interpretative shift.
These rejection decisions may be challenged before Turkish Administrative Courts under principles including:
Foreign investors facing such situations should obtain case-specific legal evaluation to determine the most effective procedural and judicial strategy under Turkish law.
Attorney Merve Bayrak has extensive experience handling complex Turkish citizenship by investment cases, including annulment lawsuits for families facing age-related complications during the application process.
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