

What happens if a foreign employee changes employer in Turkey without obtaining a new work permit? Learn the 2026 rules on employer-specific permits, administrative fines, removal risk, employer liability, new applications and legal remedies.
A foreign employee who holds a valid work permit in Turkey cannot normally use that permit to work for an entirely different employer.
This is one of the most important rules foreign workers and companies should understand in 2026.
The Ministry of Labour and Social Security expressly states that work permits are issued for a specific job, workplace and address, and that a foreign national who holds a work permit for one employer cannot work at another employer’s workplace using the same permit. A foreigner who wants to work for a different employer must obtain a new work permit.
Accordingly, a foreign employee who leaves Employer A and begins working for Employer B before obtaining the necessary new permit may be treated as working without valid authorization, even though the employee still physically possesses an unexpired work permit card issued for Employer A.
The consequences can include administrative fines for both the employee and the new employer and, for the foreign worker, referral to the Ministry of Interior for possible removal proceedings.
For an ordinary fixed-term dependent work permit, yes.
The Ministry describes a fixed-term work permit as authorization allowing a foreign national to work for a specific employer, at a specific workplace and in a specific job, subject to the conditions stated in the permit.
This means the permit is not a general labor-market authorization that the worker can carry from one employer to another.
For example, if a foreign software specialist holds a work permit for Company A in Ankara, that permit does not ordinarily authorize the employee to resign and immediately begin working for Company B in Istanbul.
Company B generally needs to obtain a new work permit for that employee.
The document may still display a future expiration date, but that does not mean it authorizes work for the new employer.
The crucial issue is the employer identified in the permit.
A foreign national cannot rely on the remaining validity period of Employer A’s permit as authorization to perform employment for Employer B.
This distinction is especially important where the foreign worker changes jobs several months before the original permit expires.
No.
The Ministry expressly states that applications to work for a different employer are evaluated according to first-application procedures and principles, rather than as ordinary extensions under the previous employer.
This is significant because an extension with the same employer may benefit from continuity rules, while a different-employer application is reassessed as a new employment relationship.
The new employer must therefore independently satisfy the applicable work permit criteria.
Foreign workers should not assume that filing a new application automatically authorizes them to begin working for the new employer.
The Ministry provides a specific continuation rule for timely extension applications with the same employer: the foreigner may continue working during evaluation for up to 90 days after expiry, provided that the work performed and workplace do not change.
That rule does not create a general right to begin work for a completely different employer before the new permit is issued.
Therefore, where the worker moves from Employer A to Employer B, the new employment start date should be coordinated carefully with the new work permit procedure.
If the foreign national works for Employer B without having the appropriate permit for Employer B, the work may be classified as unauthorized foreign employment.
The Ministry states that foreigners found working without a valid work permit and employers who employ them are subject to administrative fines. The foreign national may also be reported to the Ministry of Interior for possible removal action.
This means the problem affects both sides of the employment relationship.
For 2026, the Ministry lists an administrative fine of TRY 40,977 for a foreign national who works dependently without a valid work permit.
This amount applies to the unauthorized worker.
The fine is separate from the penalty imposed on the employer.
For 2026, the Ministry lists a fine of TRY 102,503 for each foreign national employed without a valid work permit.
Therefore, if a company employs several unauthorized foreign workers, the financial exposure may increase significantly because the employer-side fine applies per foreign employee.
Yes.
The Ministry states that where the violations identified under Article 23 of International Labour Force Law No. 6735 are repeated, the applicable administrative fine is increased by one additional amount, effectively increasing the penalty substantially for repeat conduct.
Employers with previous unauthorized foreign employment findings should therefore treat future work permit compliance particularly seriously.
There is a real immigration risk.
The Ministry states that foreigners found working without a work permit are reported to the Ministry of Interior for removal proceedings.
This does not mean that every unauthorized employment case automatically results in immediate removal.
The immigration authorities must assess the person’s individual circumstances and applicable immigration law.
However, unauthorized employment can trigger a separate immigration process beyond the labor-law fine.
No.
A residence permit alone does not authorize ordinary employment.
The Ministry expressly states that possession of a residence permit does not, by itself, give most foreign nationals the right to work.
Therefore, a worker cannot solve an employer-change problem by arguing:
“I still have a valid residence permit.”
The employee needs the appropriate work authorization for the new employment relationship.
A valid work permit generally functions as residence authorization during its validity, subject to specific statutory exceptions.
However, where the employment on which that permit was based ends, the worker should immediately review the continuing status of the work authorization and residence position.
A foreigner should not assume that an employer-specific permit remains unaffected indefinitely after the underlying employment relationship has ended.
Where the employment relationship ends, the change should be reflected through the applicable work permit procedures and notifications.
Employers should not leave the previous employment relationship appearing active while the foreigner has already started working somewhere else.
The end of employment and commencement of new employment should be coordinated from both employment-law and immigration-law perspectives.
Yes, work permit law contains notification obligations for relevant changes.
The Ministry’s 2026 fine schedule provides a separate administrative fine of TRY 6,805 for each foreign national or employer who fails to comply with notification obligations under Law No. 6735 where the relevant duty applies.
The specific notification required depends on the nature of the employment change and permit.
In practice, work permit planning can begin before the employee’s transition date.
This is often the safest approach.
The new company can review eligibility, gather corporate documents, prepare the employment agreement and determine whether the worker can use the domestic application procedure.
The actual start of work should then be aligned with the new authorization rather than allowing an unauthorized employment period to arise.
This depends on the permit type and factual circumstances.
Ordinary fixed-term dependent permits are structured around employment by a particular employer.
A foreign national who wants to perform work for more than one employer should not assume that a permit issued by one company automatically covers another company.
Each separate employment relationship must be reviewed to determine whether independent authorization is required.
Group membership does not automatically mean that two separate legal entities are the same employer for work permit purposes.
If Employer A and Employer B are separate companies, a permit issued in the name of Employer A generally should not be assumed to authorize employment by Employer B merely because both companies have the same shareholders or foreign parent company.
The legal employer identified in the permit remains important.
This situation may be different.
The Ministry states that a foreigner who holds a permit under one employer may, where the necessary conditions are satisfied, work in another position at that employer’s workplace or in another branch belonging to the same employer and operating in the same line of business.
Therefore, a change of branch within the same legal employer is not automatically equivalent to changing employer.
The actual company registration, line of business, workplace and job should still be reviewed.
A position change with the same employer may be possible where the applicable conditions are met.
However, a material change in the employee’s role may affect the wage requirement or other work permit criteria.
For example, moving from a technical position to a managerial position may require reassessment of the applicable salary threshold.
The Ministry’s current criteria distinguish between categories such as senior executives, other managers, engineers and architects, specialists and ordinary workers.
Remote work does not necessarily eliminate the work permit problem.
The legal question is not merely where the laptop is physically located.
If the foreign national is performing employment in Turkey for a different employer while relying on a permit issued for another company, the employment relationship should be reviewed under the work permit rules.
A change from office work to remote work should not be used to bypass employer-specific authorization requirements.
Cross-border remote employment requires a more detailed analysis.
A foreign national physically present in Turkey may work for a foreign company under certain structures, but the immigration, employment, tax, social security and work authorization consequences depend on the facts.
The answer can differ substantially from a straightforward transfer between two Turkish employers.
Potentially, yes.
The key point is that the new-employer application is treated according to first-application principles.
The new employer does not necessarily need to wait for the old permit’s printed expiration date before beginning the new application process.
However, the transition should be structured correctly to avoid overlapping or unauthorized employment.
The new employer must satisfy the current evaluation criteria applicable to the particular position and worker.
Depending on the circumstances, these may include financial-capacity criteria, Turkish-employee headcount requirements and wage criteria.
For example, current Ministry rules require the salary at the application date generally to be at least:
five times the gross minimum wage for senior executives and pilots,
four times the gross minimum wage for engineers and architects,
three times the gross minimum wage for other managers,
two times the gross minimum wage for specialist or skilled positions,
and at least the gross minimum wage for certain other occupations.
Not always.
The current 2026 criteria contain several exceptions.
A particularly important rule effective from August 3, 2026 provides that for certain domestic applications filed for foreigners who have lawfully remained in Turkey for at least one year during the previous three years, the ordinary employment and financial-capacity criteria are generally not applied to up to three qualifying foreign employees at the same workplace, subject to the applicable conditions.
Therefore, when an existing foreign worker changes employer, the new company should check whether this 2026 exception applies rather than automatically assuming that the ordinary criteria govern.
A foreign engineer has a valid work permit for an engineering company in Istanbul.
The employee receives a better offer from another engineering company and resigns on Monday.
On Tuesday, the employee begins working for the new company while the old permit remains valid for another eight months.
This is risky.
The old permit was issued for the first employer.
The new company generally must obtain a new work permit, and the application is evaluated according to first-application procedures.
The employee’s unexpired permit does not automatically authorize work for the second company.
A foreign manager works at Employer A’s Ankara office.
The same company transfers the employee to its Istanbul branch in the same line of business.
The Ministry recognizes that work at another branch of the same employer may be possible where the required conditions are satisfied.
This should therefore be distinguished from employment by a separately incorporated affiliate.
Company A and Company B have the same ultimate parent company.
A foreign employee holds a permit for Company A but begins working for Company B.
Even though the companies belong to the same corporate group, they are separate legal employers.
The existing permit should not automatically be treated as valid for Company B.
A new work permit should be obtained where required.
This creates direct risk for both parties.
The employee may be treated as working without authorization, while the new employer may face the employer-side administrative fine.
For 2026, the Ministry lists the applicable fines as TRY 40,977 for the dependent foreign worker and TRY 102,503 per unauthorized foreign employee for the employer.
The safest approach is to complete the work permit procedure before unauthorized employment begins.
Submission alone should not automatically be treated as permission to work.
The Ministry’s continuation rule specifically allows continued work during a timely extension process where the same work and workplace continue, for up to 90 days.
A new-employer application is different.
Foreign workers should therefore confirm that they have legal authority to commence the new employment before actually starting.
A short period does not automatically make the employment lawful.
Even a brief period can theoretically be treated as unauthorized employment if the foreigner lacked the appropriate permit for the new employer.
However, the factual circumstances, evidence and administrative findings will matter in any enforcement procedure.
The company should not create the appearance of ordinary employment before the foreigner is legally authorized to work for that employer.
Salary payments, payroll registration, workplace attendance, company email activity and actual performance of services may all become relevant evidence regarding when employment began.
The employment start date should therefore be coordinated with the work permit strategy.
Work permit and social security compliance should be coordinated.
A new employer should ensure that the foreign worker’s social security registration corresponds with the lawful commencement of employment and the work permit documentation.
Starting employment first and trying to regularize immigration records later may create inconsistencies across multiple government systems.
Obtaining a new work permit later does not necessarily erase an earlier period of unauthorized employment.
The new permit legalizes employment prospectively according to its effective terms.
If authorities identify earlier unauthorized work, administrative penalties may still be imposed for that earlier period.
Potentially, yes.
A penalty should be reviewed to determine whether the factual and legal elements of the alleged violation actually existed.
Relevant issues can include:
whether the employee actually performed work,
whether the companies were legally the same employer,
whether a valid exemption applied,
whether the work permit covered the activity,
whether notification requirements were satisfied,
and whether the administrative record correctly identifies the employment period.
The applicable objection or judicial deadlines should be checked immediately after formal notification.
The Ministry states that decisions concerning rejection, cancellation or termination of a work permit may be challenged through an administrative objection within 30 days from notification. If the objection is rejected, judicial review before the administrative courts may be pursued.
The employee should not begin working for the new employer merely because an objection has been filed unless there is a separate legal basis allowing the work.
Potentially, if the original work permit remains legally valid and the underlying employment relationship can lawfully continue.
However, the actual status of the permit and any termination notifications should be checked before returning.
A foreign employee should not rely solely on the card’s printed expiry date.
This depends on the foreigner’s overall immigration status.
A valid work permit generally functions as residence authorization.
When the employment relationship supporting that permit changes, the foreigner’s work and residence position should be reviewed together.
Where the worker also holds an independent valid residence status, the residence analysis may differ.
Not necessarily.
Foreign nationals who satisfy the conditions for a domestic work permit application may potentially complete the new-employer procedure from within Turkey.
The correct application route depends on the worker’s lawful status at the time of filing.
The fact that the foreigner is changing employer does not by itself always require departure.
Foreign workers sometimes believe they are legally prohibited from changing employer during the first work permit year.
The more accurate rule is that the permit is linked to the employer for which it was issued.
The foreigner may move to another employer, but the new company must obtain a new work permit under the applicable first-application procedures.
The same principle applies.
A permit extension granted for Employer A does not become transferable merely because it has a longer validity period.
If the employee moves to Employer B, a new permit application should be considered.
Before leaving the current employer, the foreign worker should determine:
whether the prospective employer satisfies the current work permit criteria → whether a domestic application is available → whether any 2026 exemption applies → when the new application can be filed → when the employee may lawfully start work → how termination of the old employment will affect residence status.
This planning can prevent a period of unauthorized employment.
The new employer should not simply copy the employee’s existing work permit and place it in the personnel file.
Instead, the employer should verify:
the employer named on the existing permit,
the foreigner’s lawful immigration status,
the appropriate position and salary,
the company’s financial and employee criteria,
the correct application route,
and the legal start date.
Review the current work permit → Confirm the employer named on it → Do not use Employer A’s permit for Employer B → Assess the new employer’s eligibility → Check 2026 exemptions → Prepare a first-application-style new permit request → Coordinate termination and commencement dates → Do not start unauthorized work → Complete social security and payroll registration correctly → Keep proof of all submissions and decisions.
Generally no. The Ministry states that a foreign worker cannot use a permit issued for one employer to work at another employer’s workplace. A new work permit is required.
No. Applications to work for a different employer are evaluated according to first-application procedures and principles.
The employee should not assume so. The Ministry’s specific continued-work rule during processing applies to qualifying same-employer extension applications where the workplace and work do not change.
The Ministry lists the 2026 administrative fine for a dependent foreigner working without authorization as TRY 40,977.
The employer-side fine is TRY 102,503 for each foreign national employed without a valid work permit.
Yes. The Ministry states that foreigners found working without a work permit are reported to the Ministry of Interior for removal-related procedures.
No. A residence permit alone generally does not grant the right to work.
Potentially. The Ministry allows work in another position or another branch of the same employer in the same line of business where the necessary conditions are satisfied.
Not necessarily. If the new workplace belongs to a separate legal employer, the original employer-specific permit should not automatically be treated as transferable.
Yes. The Ministry states that rejection, cancellation and termination decisions may be challenged administratively within 30 days of notification, after which judicial review may be available if the objection is rejected.
Changing employer is one of the areas in which foreign workers most frequently create an immigration problem unintentionally.
The essential 2026 rule is that an ordinary fixed-term work permit is employer-specific. A foreign employee who has authorization to work for Employer A cannot ordinarily begin working for Employer B using the same permit. The new employer must obtain the appropriate new work authorization.
Failure to follow this procedure can expose both sides to administrative penalties. In 2026, the Ministry lists a TRY 40,977 fine for a dependent foreign worker working without authorization and TRY 102,503 for the employer for each unauthorized foreign employee. Unauthorized workers may also be reported to the Ministry of Interior for removal-related action.
Firat Fesih Kaya Law Office provides legal assistance to foreign employees, international companies and Turkish employers concerning employer changes, new work permit applications, work permit extensions, unauthorized employment allegations, administrative fines, work permit rejection, corporate transfers and foreign executive employment in Turkey.
Legal assistance may include reviewing the existing permit, determining whether a new permit is required, assessing the new employer’s eligibility, applying the current 2026 evaluation criteria, coordinating resignation and new employment dates, responding to administrative investigations and challenging unlawful penalties or adverse work permit decisions where appropriate.
Phone: +90 312 434 22 22
Mobile / WhatsApp: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Office: Mevlana Boulevard No:221, Yildirim Tower, Balgat, Cankaya, Ankara, Turkey
The central rule is straightforward: do not begin working for a new employer merely because the old work permit has not expired. A permit issued for one employer generally does not authorize employment by another company. Obtain the appropriate new work permit before beginning the new employment relationship.