Five of the six routes to Turkish citizenship by investment ask for capital. The sixth asks for something else: jobs. A foreign national who creates employment for at least fifty people in Türkiye, certified by the Ministry of Labour and Social Security, may apply for citizenship on an exceptional basis. It is the least used route, and for a specific kind of investor it is the most natural one.
The rule
Article 20 of the Regulation implementing Law No. 5901 provides that a foreign national who creates employment for at least fifty persons, as determined by the Ministry of Labour and Social Security, qualifies for exceptional citizenship. The original threshold was one hundred employees; it was reduced to fifty in 2018 and has remained there.
Determination is made on the basis of Social Security Institution (SGK) records. The test is documentary and objective: the payroll either shows fifty insured employees or it does not.
Who this route is for
It is not a cheaper alternative to the capital routes. Employing fifty people in Türkiye costs considerably more per year than USD 500,000 held on deposit — wages, employer social security contributions, premises, equipment and management.
The route makes sense for someone who was going to build that business anyway. A manufacturer establishing production in Türkiye, a logistics operator opening a hub, a hospitality group running hotels, a textile business relocating capacity, a services company opening a delivery centre. For those investors, citizenship follows from an activity already planned rather than being the reason for it.
For an investor whose sole objective is a passport, the capital routes are cheaper, faster and simpler. That should be said plainly rather than discovered later.
What the fifty employees must be
The determination rests on SGK registration, and the practical requirements that follow are:
- Registered employment. Employees must be formally registered with the SGK, with contributions paid. Informal arrangements do not count and expose the employer to separate liability.
- Employed by the applicant's business. The employment must be attributable to the company the foreign national has established or invested in.
- Sustained, not momentary. Fifty people on the payroll for one month is a red flag, not a qualification. The ministry looks for genuine, continuing employment.
- Documented. Payroll records, contributions, contracts and the company's operational reality all form part of the assessment.
Whether particular categories — part-time staff, seasonal workers, employees of affiliated companies — count toward the total is a question determined by the ministry on the facts. It should be clarified before the structure is fixed, not assumed.
Building the business first
The employment route necessarily starts with a company. In outline:
- Company formation. A Turkish company with foreign shareholders is formed under Law No. 6102, with the same rights as a domestic company under the Foreign Direct Investment Law No. 4875. Minimum capital is TRY 50,000 for a limited company and TRY 250,000 for a joint stock company, though a business employing fifty people will be capitalised far above those figures.
- Registration. MERSIS, trade registry, tax office, SGK employer registration, municipal permits, and any sector-specific licences.
- Premises and operations. Real, not nominal. The assessment considers whether the business genuinely operates.
- Recruitment and registration of the workforce, with contributions running.
- Application to the Ministry of Labour and Social Security for the certificate of conformity once the threshold is met and sustained.
Note what this sequence implies about timing. Capital routes can be completed in weeks; this one takes as long as it takes to build a business to fifty employees.
The applicant's own work permit
A foreign national who is a shareholder in a Turkish company does not need a work permit merely to hold shares. A permit is required to work in the company — including to serve as a managing director of a limited company.
Work permit criteria interact with employment in a way that matters here. As a general rule, a workplace applying for a work permit must employ at least five Turkish citizens for each foreign employee, with the requirement applied to a foreign shareholder over the latter part of the first permit year. A business that already employs fifty people satisfies this comfortably — which is one respect in which the employment route is easier than it looks.
What it costs, realistically
There is no fixed figure, because it depends on the sector and the wage level, but the components are: gross wages for fifty employees, employer social security contributions on top, premises, equipment, working capital, accounting and payroll administration, and management.
Set against a deposit of USD 500,000 that is returned after three years, the employment route is by a wide margin the most expensive on a cash basis — unless the business generates a return, which is precisely the point. An operating business is an asset that produces income; a deposit is a sum that is returned. Which is preferable depends on whether the business works.
Advantages that do not appear in the regulation
- No lock-up. There is no three-year holding period on capital, because the qualifying act is employment rather than an asset held.
- Substantive presence. An investor who employs fifty people has a genuine footprint in Türkiye, which simplifies everything from banking to residence.
- Alignment with other reliefs. Investment incentives, regional support schemes and sectoral programmes may apply to the business independently of the citizenship question.
- Durability. The business continues to exist after citizenship is granted, unlike a deposit that is withdrawn.
Where it goes wrong
- Artificial employment. Registering fifty people who do not genuinely work is a fraud on the SGK before it is a citizenship problem, with serious consequences under Turkish law. It is also detectable, because payroll patterns are visible in the records.
- Counting employees of affiliated entities without confirming that they attribute to the applicant's business.
- Losing the threshold before certification. Employment fluctuates; the file needs the number to hold when it is assessed.
- Unpaid contributions. Registration without payment does not satisfy the test and creates liability.
- Treating it as a shortcut. It is the longest route, not the shortest.
Frequently asked questions
Must the employees be Turkish citizens? The requirement is employment created in Türkiye, assessed on SGK records. Whether particular foreign employees count is a matter for the ministry's assessment; the practical expectation is domestic employment.
How long must the fifty be employed before I apply? There is no single published period. Genuine, continuing employment is what is assessed, so the file should show a sustained position rather than a snapshot.
Can I buy an existing company that already employs fifty people? Acquiring a business is a legitimate route to the same position, but the employment must be attributable to the applicant's investment. Take advice on structuring before acquiring.
Do I need to live in Türkiye? No residence requirement applies to this route, though running a business of this size usually implies presence.
Does it cover my family? Yes — spouse and children under eighteen.
What if employment falls below fifty after citizenship is granted? The grant is not conditional in the way the three-year capital undertakings are. The obligation attached to the qualifying determination; ordinary employment fluctuation afterwards is a business matter.
Can I combine this with a property purchase? Each route is certified separately against its own criteria. Combining across routes is not the intended structure.
If you were building here anyway
The employment route rewards investors whose plans already involve operating in Türkiye. For them it converts a business decision into a citizenship outcome at no additional capital cost. For everyone else, the capital routes are the honest recommendation.
Dural Hukuk advises foreign investors on company formation, work permits, employment compliance and the certification process with the Ministry of Labour and Social Security, and carries the resulting citizenship file through to conclusion. Call +90 535 260 74 54 or use the contact form on this site.
This article is general information on Turkish law as at August 2026 and is not legal advice. Employment and social security compliance is assessed on the facts; obtain advice on your own circumstances before proceeding.