Can foreign CEOs and senior executives obtain work permits in Turkey without five Turkish employees? Learn the 2026 employment rule, TRY 50 million exception, foreign shareholder exception, lawful-stay exemption and sector-specific rules.

Yes, in certain circumstances a foreign CEO, general manager or senior executive can obtain a work permit in Turkey without the employer satisfying the ordinary five-Turkish-employee requirement. However, being called a “CEO,” “general manager” or “senior executive” does not itself create an exemption.

Under the general 2026 work permit criteria, an employer subject to balance-sheet accounting must ordinarily employ at least five Turkish citizens for each foreign national for whom a work permit is requested. The current rules nevertheless contain several important exceptions based on the employer’s turnover, the foreigner’s previous lawful stay, the sector, the nature of the position and, where the executive is also a shareholder, the amount of the foreigner’s capital investment.

Foreign companies appointing CEOs or senior executives in Ankara, Istanbul, Izmir, Mersin, Bursa or elsewhere in Turkey should therefore determine which exemption applies before assuming that five Turkish employees must always be hired.

What Is the General Five-Turkish-Employee Rule in 2026?

The general rule is straightforward.

For workplaces subject to balance-sheet accounting, at least five Turkish citizens must ordinarily be employed for each foreign employee for whom a work permit application is made.

For example, if a newly established Turkish subsidiary employs only two Turkish citizens and wants to appoint a foreign CEO, the ordinary employment criterion would not be satisfied unless an exemption applies.

But several exemptions can change this result.

Are Foreign CEOs Automatically Exempt?

No.

This is one of the most important distinctions for international companies.

The Ministry’s current criteria classify senior executives separately for salary purposes, but they do not establish a general rule saying that every foreign CEO is automatically exempt from the five-Turkish-employee requirement.

The applicant’s title alone is therefore insufficient.

The company must establish an applicable exemption based on the employer, investment, sector, foreigner’s status or another provision of the current criteria.

What Salary Must a Foreign CEO Receive?

The 2026 evaluation criteria require the remuneration of a senior executive to be at least five times the gross minimum wage applicable on the work permit application date.

Other managers are generally subject to a lower threshold of three times the gross minimum wage.

Accordingly, correctly identifying the foreigner’s position is important.

A company cannot necessarily describe a foreign employee as a CEO to obtain one treatment while declaring remuneration inconsistent with the senior executive category.

Exception 1: Companies With TRY 50 Million or More in Net Sales

One of the most useful exceptions for established international companies concerns employer turnover.

Under the current criteria, where the workplace’s net sales in the previous year are TRY 50 million or more, the ordinary employment criterion is not applied to work permit applications for up to five foreign employees.

This means a qualifying company may potentially employ a foreign CEO without maintaining five Turkish employees specifically for that CEO.

Example

A Turkish company has previous-year net sales of TRY 75 million and employs three Turkish citizens.

The company wants to appoint a foreign chief executive.

Although the ordinary rule would require five Turkish employees for one foreign worker, the company exceeds the TRY 50 million net-sales threshold. The employment criterion may therefore be disregarded for up to five foreign workers under this exception.

The remaining work permit requirements must still be satisfied.

Does TRY 50 Million in Turnover Automatically Guarantee the CEO’s Permit?

No.

The exception concerns the employment criterion.

It does not automatically eliminate every other work permit requirement.

The company and foreign executive must still satisfy the remaining applicable conditions, including the salary requirement and appropriate application documentation.

The Ministry’s 2026 guidance continues to confirm that work permit applications are evaluated under the current criteria and international labour force framework.

Exception 2: Foreign Executives With Qualifying Previous Lawful Stay

An important new exception became effective on August 3, 2026.

For certain domestic work permit applications made for foreigners who have legally remained in Turkey for at least one year during the preceding three years under a work permit, qualifying residence status or international protection, the Ministry generally does not apply the employment and financial-capacity criteria for up to three qualifying foreigners at the workplace.

The number of foreign workers benefiting from this rule generally cannot exceed the number of Turkish citizens working at the same workplace.

This rule can be extremely important for foreign executives already living legally in Turkey.

Example

A foreign executive has lawfully lived in Turkey for two years and is appointed CEO of a newly established company.

The company currently employs two Turkish citizens.

If the foreign CEO satisfies the requirements of the August 3, 2026 domestic-application exception, the ordinary five-Turkish-employee and financial-capacity criteria may not apply.

The applicant’s complete immigration history and application category should therefore be reviewed before the company hires additional employees solely to satisfy the ordinary rule.

Does the 2026 Lawful-Stay Exception Apply to Unlimited Foreign Executives?

No.

The exception is generally limited to three qualifying foreigners at the same workplace.

Furthermore, the number of foreign workers benefiting from the exception generally cannot exceed the number of Turkish employees at that workplace.

Where a fourth or subsequent qualifying foreign employee is sought, the ordinary employment and financial-capacity rules generally become relevant again.

Exception 3: Foreign CEO Is Also a Company Shareholder

A different set of rules applies where the CEO or senior executive is also a shareholder of the company.

Under the ordinary foreign-shareholder criteria, the foreigner’s capital contribution must generally be at least TRY 500,000, the company’s paid-in capital must be at least TRY 500,000, and the foreigner must hold at least 20% of the company.

The business must also generally employ five Turkish citizens. For the foreign shareholder’s initial work permit, however, the five-employee condition begins from the start of the seventh month.

Therefore, a foreign founder acting as CEO may already have a temporary advantage during the first six months.

Can a Foreign Shareholder CEO Avoid the Five-Employee Requirement Entirely?

Potentially, yes.

The current criteria contain a major investment exception.

Where the foreign shareholder’s capital share is USD 100,000 or more, the ordinary foreign-shareholder criteria concerning minimum capital, 20% ownership and employment of five Turkish citizens do not apply.

This can be particularly important for foreign founders, chief executives and managing shareholders making substantial investments in Turkey.

Example

A foreign investor establishes a company in Ankara and serves as its CEO.

The foreigner’s capital share is USD 150,000.

Because the capital share exceeds USD 100,000, the ordinary shareholder requirement to employ five Turkish citizens does not apply under the specific shareholder exception.

The work permit application must still satisfy the remaining applicable legal requirements.

What If the Foreign CEO Is Not a Shareholder?

Then the shareholder exception cannot be used merely because the person holds the title of CEO.

Instead, the company should examine other exemptions, particularly:

the TRY 50 million net-sales exception,

the August 2026 lawful-stay exception,

sector-specific exemptions,

or a personal exemption applicable to the foreign national.

The correct legal basis should be identified before the application is submitted.

Exception 4: Information Technology Companies

The 2026 criteria contain particularly favorable rules for the information technology industry.

For businesses operating in that sector, the employment and financial-capacity criteria are not applied to work permit applications concerning positions requiring expertise in areas such as software development, database expertise, mobile software, systems, network and security expertise and enterprise architecture.

Even companies outside the information technology industry can benefit from a limited exception for qualifying information technology positions, generally for up to two foreigners.

A foreign executive’s actual duties must fit the relevant specialist category; simply placing “technology” in a CEO’s title is not enough.

Exception 5: Certain Foreign Airline Executives

There is also a specific aviation exception.

The Ministry states that foreign nationals working as senior executives or specialists at Turkish branches of foreign-flag air carriers are exempt from the employment and financial-capacity criteria.

This is a genuine senior-executive exemption tied to a particular industry.

It should not be generalized to CEOs in unrelated businesses.

Exception 6: High-Technology Investments

High-technology investments can also receive special treatment.

For qualifying investments expected to make a significant contribution to the economy, create substantial employment or require highly qualified workers unavailable domestically, work permit applications may be exempted from the general evaluation criteria with the approval of the Directorate General of International Labour Force.

This may be relevant to foreign executives leading major technology, advanced manufacturing, research or strategic investment projects.

However, this is not an automatic exemption available to every start-up.

What About Research and Technology Development Companies?

Foreign research, innovation and design personnel working in qualifying companies with recognized research or design centers, and qualifying foreigners working in technology development zones, may benefit from exemption from the employment and financial-capacity criteria, subject to the required approval from the Ministry of Industry and Technology.

International companies operating in technology-intensive sectors should therefore check sector-specific rules before applying the general five-employee test.

Are Some Foreign CEOs Personally Exempt From the Five-Employee Rule?

Yes.

The current criteria provide broader exemptions from the employment, financial-capacity and salary criteria for certain categories of foreigners.

These include, among others, qualifying holders of long-term residence status, foreigners who have lived in a marriage with a Turkish citizen for at least three years, certain humanitarian-status holders and foreigners who have spent at least eight qualifying lawful years in Turkey.

The eight-year provision became effective on August 3, 2026.

However, the Ministry expressly states that being within an exempt category does not guarantee issuance of a work permit.

Can a Newly Established Company Hire a Foreign CEO Without Five Turkish Employees?

Potentially.

A new company should examine whether the CEO qualifies through:

the August 2026 lawful-stay exception,

a foreign-shareholder exception,

a sector-specific exemption,

a personal exemption,

or another special rule.

If none applies, the ordinary five-Turkish-employee criterion may prevent approval.

The company’s paid-in capital must also be considered. Under the general rules, a newly established workplace ordinarily needs at least TRY 500,000 paid-in capital for a foreign employee application.

What If the Company Has Only One Turkish Employee?

That does not automatically make a foreign CEO application impossible.

For example, if the foreign CEO qualifies under the August 3, 2026 lawful-stay exception, the number of foreign workers benefiting from that exception cannot generally exceed the number of Turkish employees.

A company with one Turkish employee may therefore potentially benefit for one qualifying foreign applicant, subject to the remaining requirements.

Alternatively, a USD 100,000 shareholder investment or another applicable exemption may independently remove the five-employee criterion.

Can a Foreign CEO Apply From Inside Turkey?

Potentially.

The Ministry’s current documentation guidance states that domestic applications can generally be filed where the foreign national holds a qualifying residence permit valid for at least six months. Otherwise, the work permit process generally begins through the appropriate Turkish foreign mission.

The application route is particularly important where the company intends to rely on the August 2026 lawful-stay exception because that provision specifically concerns qualifying domestic applications.

Can the Company Simply Give the Foreign Employee the Title “CEO”?

No.

The actual role should correspond with the application.

Authorities can examine the company’s structure, the foreigner’s qualifications, declared duties, remuneration and corporate documentation.

A nominal CEO appointment designed only to avoid work permit requirements can therefore create rejection risk.

Practical Example: Multinational Subsidiary

A multinational company establishes a subsidiary in Istanbul and appoints a foreign national as chief executive.

The subsidiary has only three Turkish employees, but its previous-year net sales exceed TRY 50 million.

Because qualifying workplaces with previous-year net sales of at least TRY 50 million are exempt from the general employment criterion for up to five foreigners, the CEO application may proceed without satisfying the ordinary five-Turkish-employee requirement.

The CEO’s remuneration must still comply with the senior-executive salary criterion.

Practical Example: Foreign Founder and CEO

A foreign entrepreneur owns 70% of a company in Izmir and acts as chief executive.

The foreigner’s capital share exceeds USD 100,000.

The specific shareholder rules state that the ordinary shareholder capital, percentage and five-Turkish-employee criteria do not apply where the foreign shareholder’s capital share reaches USD 100,000.

The company should document the investment carefully when filing.

Practical Example: CEO With Previous Lawful Residence

A foreign executive has legally lived in Turkey for more than one qualifying year during the previous three years and is appointed chief executive of a Bursa company employing two Turkish citizens.

If the application satisfies the conditions of the August 3, 2026 domestic-application exception, the employment and financial-capacity criteria may not apply.

The applicant must still satisfy other applicable work permit requirements.

Practical Example: Ordinary Foreign CEO With No Exception

A company in Mersin employs two Turkish citizens and appoints a foreign CEO.

The company has net sales below TRY 50 million. The CEO has no qualifying previous lawful stay, does not hold shares worth USD 100,000, and no sector-specific or personal exemption applies.

In this situation, simply describing the applicant as a senior executive does not remove the ordinary five-Turkish-employee requirement.

2026 Checklist for Foreign CEO Work Permit Applications

Before filing, the company should determine:

Is the executive genuinely a CEO or senior executive? → Is the foreigner also a shareholder? → Is the shareholder’s capital share at least USD 100,000? → Did the company have at least TRY 50 million in previous-year net sales? → Has the foreigner completed the qualifying lawful-stay period for the August 2026 exception? → Is the application domestic or overseas? → Does a technology, aviation or high-technology exemption apply? → Does the foreigner qualify for a personal exemption? → If no exemption applies, are at least five Turkish citizens employed? → Does the proposed remuneration meet the five-times-gross-minimum-wage requirement for senior executives?

Frequently Asked Questions

1. Are all foreign CEOs exempt from the five-Turkish-employee requirement?

No. Senior executive status alone does not create a general exemption. The ordinary rule requires five Turkish citizens for each foreign worker unless another exemption applies.

2. Can a company with TRY 50 million in net sales hire a foreign CEO without five Turkish employees?

Potentially, yes. Where previous-year net sales are at least TRY 50 million, the employment criterion is not applied for up to five foreign workers.

3. Is a foreign shareholder CEO exempt if they invest USD 100,000?

Where the foreign shareholder’s capital share is USD 100,000 or more, the ordinary shareholder employment and specified capital and ownership criteria do not apply.

4. Does a foreign CEO who has lived in Turkey qualify for an exemption?

Potentially. From August 3, 2026, certain domestic applicants with at least one year of qualifying lawful stay during the previous three years may benefit from exemption from employment and financial-capacity criteria.

5. What salary is required for a foreign CEO?

A senior executive must generally receive at least five times the gross minimum wage applicable on the application date.

6. Are foreign technology executives exempt?

Certain qualifying information technology, research, innovation and high-technology positions benefit from special rules. The actual position and business activity must satisfy the relevant criteria.

7. Are foreign airline executives exempt?

Foreign senior executives and specialists working at Turkish branches of foreign-flag air carriers are exempt from employment and financial-capacity criteria under the current sector-specific rules.

8. Does exemption from five Turkish employees guarantee the work permit?

No. An employment-criterion exemption removes that particular requirement; it does not automatically guarantee approval.

9. Can a new company obtain a foreign CEO’s work permit?

Yes, potentially. The company must satisfy the applicable financial and other requirements unless an exemption applies. A newly established workplace ordinarily requires at least TRY 500,000 paid-in capital under the general financial criterion.

10. Can the foreign executive begin working before the permit is issued?

Company appointment and work authorization are separate matters. A foreign executive should not assume that appointment as CEO or registration as a manager alone authorizes active work in Turkey.

Legal Assistance for Foreign CEOs and Senior Executives in Turkey

The 2026 rules provide several routes through which a foreign CEO or senior executive may obtain a work permit without satisfying the ordinary five-Turkish-employee requirement. The most important possibilities include the TRY 50 million net-sales exception, the USD 100,000 foreign-shareholder exception, the August 3, 2026 lawful-stay exception, sector-specific exemptions and personal-status exemptions.

However, CEO status by itself is not an exemption. Companies should determine the correct legal basis before submitting the application. Senior executives are also generally subject to a remuneration threshold of at least five times the gross minimum wage applicable on the application date.

Firat Fesih Kaya Law Office provides legal assistance to foreign CEOs, senior executives, company founders, shareholders and multinational companies in Ankara, Istanbul, Izmir, Mersin, Bursa and throughout Turkey concerning executive work permits, foreign shareholder permits, employment-criterion exemptions, work permit applications, rejected applications and work permit extensions.

Legal assistance may include reviewing whether the five-Turkish-employee requirement applies, determining eligibility under the TRY 50 million or USD 100,000 exceptions, assessing the August 2026 lawful-stay rules, reviewing executive salary requirements and structuring the application according to the foreigner’s actual corporate position.

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 key 2026 principle is clear: a foreign CEO does not automatically escape the five-Turkish-employee requirement because of their executive title, but several important investment, turnover, residence and sector-based exceptions can legally remove that requirement when their conditions are satisfied.