What happens to foreign employees’ work permits when a Turkish company is sold in 2026? Learn how share sales, asset sales, employer changes, mergers, workplace transfers and corporate restructuring affect Turkish work permits.

When a Turkish company employing foreign nationals is sold, the effect on existing work permits depends heavily on how the transaction is structured.

A share sale in which the same Turkish legal entity continues as the employer can produce a very different work-permit result from an asset or business transfer in which employees move to another legal entity.

This distinction is critical because ordinary employer-dependent work permits in Turkey are issued in connection with a specific employer, job and workplace. The Ministry of Labour and Social Security confirms that a foreigner holding a permit for one employer cannot simply use the same permit to work for another employer; working for a different employer generally requires a new work permit.

Foreign employees and acquiring companies should therefore review immigration consequences before closing a corporate transaction rather than after employees have already moved to the purchaser.

Does a Company Sale Automatically Cancel Foreign Employees’ Work Permits?

Not necessarily.

The expression “company sale” can describe several legally different transactions.

The most common distinction is between:

Share sale: The shareholders change, but the Turkish company employing the foreign worker remains the same legal entity.

Business or asset transfer: The business or assets are transferred and the foreign worker may begin working for another legal entity.

For work-permit purposes, this distinction can be decisive.

What Happens in a Share Sale?

In a conventional share acquisition, the purchaser acquires shares in the company.

The company itself normally continues to exist as the same legal entity.

For example:

Before acquisition

Foreign Employee → Company A

After acquisition

Foreign Employee → Company A

The shareholders of Company A have changed, but the employee’s legal employer may still be Company A.

This is materially different from an employee moving from Company A to Company B.

Accordingly, a change in shareholders should not automatically be treated as identical to a change of employer.

Nevertheless, the existing work-permit file should be reviewed to determine whether the transaction causes any change that must be reported or updated.

Why Does the Employer’s Legal Identity Matter?

Because an employer-dependent work permit is tied to employment by a particular employer.

The Ministry states that temporary employer-dependent work permits are issued for work in a particular workplace belonging to a real or legal person, or in specified workplaces within the same line of business, for a particular job.

Therefore, lawyers conducting immigration due diligence should identify the employer’s legal identity rather than merely its commercial brand.

Two companies may:

• Have the same shareholders,
• Use the same brand,
• Operate from the same building,
• Belong to the same corporate group,

and still constitute separate legal employers.

What Happens If the Purchaser Becomes the New Employer?

This is where work-permit risk becomes substantially greater.

The Ministry expressly states that a foreigner holding a work permit for a specific employer cannot use that permit to work at another employer’s workplace. A new work permit is required to work for a different employer.

Therefore, if a corporate sale results in the foreign employee legally moving from:

Company A → Company B

the existing Company A work permit should not simply be assumed to authorize employment by Company B.

The work-permit transition must be planned separately.

Does the Employment Contract Transfer Solve the Work-Permit Problem?

Not necessarily.

Employment-law continuity and immigration authorization are related but separate legal issues.

Even if Turkish employment law results in continuity of certain employment rights following a workplace or business transfer, this does not automatically mean that an employer-specific work permit can be used by a different legal employer.

The immigration question remains:

Which legal entity is named as the employer for work-permit purposes?

If that employer changes, a new work-permit process may be necessary.

Can Foreign Employees Start Working for the Buyer Immediately?

This should not be assumed.

Foreigners covered by the work-permit requirement must hold valid authorization before working in Turkey. The Ministry states that foreigners working without a valid work permit or applicable exemption can face administrative and other legal consequences.

Accordingly, a transaction should not be structured as:

Closing → employee automatically starts working for buyer → immigration review later.

The work-permit analysis should ideally be completed before the employment transfer becomes effective.

What If Only the Shareholders Change?

Where the legal employer remains exactly the same company, the situation is generally different from changing employers.

However, the parties should still examine whether the transaction changes:

• Company information,
• Workplace information,
• Trade name,
• Registered address,
• Foreign employee’s position,
• Salary,
• Corporate registration data,
• Other information appearing in the permit file.

A change that does not require an entirely new permit may still require an administrative update or notification.

What If the Company’s Trade Name Changes After the Sale?

A trade-name change should not automatically be confused with creation of a new employer.

The important issue is whether the same legal entity continues.

For example:

ABC Teknoloji A.Ş. → XYZ Teknoloji A.Ş.

may represent only a corporate-name change if the same legal entity continues.

By contrast:

ABC Teknoloji A.Ş. → employment transferred to XYZ Holdings A.Ş.

involves two different companies.

These situations should not receive the same work-permit treatment.

What If the Company’s Tax Number Changes?

A change in tax identity can be an important warning sign that the legal employer has changed.

The immigration file should therefore be compared against:

• Trade registry records,
• Tax information,
• Social security workplace registration,
• Employment agreement,
• Payroll records,
• Existing work permit.

Where a different legal entity becomes the employer, the parties should determine whether a new work permit is required before employment continues.

What Happens in an Asset Sale?

Asset transactions require particular caution.

A buyer may acquire:

• Factory,
• Machinery,
• Customer contracts,
• Intellectual property,
• Inventory,
• Business operations,
• Employees.

But the seller’s legal entity may remain separate.

If the foreign employees move from the seller to the purchasing company, the transaction can result in an immigration-law employer change even where the employees continue:

• Doing the same work,
• At the same factory,
• Using the same equipment,
• Under the same brand.

The physical continuity of the business does not necessarily mean continuity of the employer for work-permit purposes.

What Happens When a Factory Is Sold?

The same analysis applies.

Suppose a foreign engineer works for Company A at a factory in Ankara.

Company B purchases the factory and becomes the engineer’s new employer.

Even if the engineer continues working:

• At the same desk,
• In the same factory,
• In the same position,

the legal employer has changed from Company A to Company B.

Because employer-dependent permits are tied to a specific employer, the existing permit should not automatically be treated as transferable.

What About a Merger?

Mergers require a transaction-specific assessment.

The relevant questions include:

• Which company survives?
• Which company disappears?
• Who becomes the legal employer?
• Does the foreign employee remain attached to the same legal entity?
• Does the workplace registration change?
• Do employment records move to another company?
• What happens to the corporate information underlying the work-permit file?

A merger should therefore trigger an immigration review even if employment appears commercially continuous.

What About a Demerger or Corporate Split?

A corporate split can create similar issues.

A foreign employee may move with one business division into another company.

If that restructuring results in a different legal entity becoming the employer, the work permit cannot simply be assumed to move automatically with the employee.

The work-permit consequences should be addressed as part of the restructuring plan.

What About Intra-Group Transfers?

Being transferred between companies belonging to the same corporate group does not necessarily avoid the new-permit requirement.

For example:

Foreign employee works for Company A.

Both Company A and Company B are owned by Holding Company H.

The employee is transferred to Company B.

Company A and Company B remain separate legal employers.

The Ministry’s current guidance states that a foreigner permitted to work for a specific employer cannot work for another employer under the same permit.

Common ownership does not by itself convert two companies into one employer for immigration purposes.

Can a Foreign Employee Work at Another Branch of the Same Employer?

This is different.

The Ministry states that a foreigner who has received a work permit under one employer may, where the necessary conditions are satisfied, work in a different position at the same employer or at other branches of that employer in the same line of business.

Therefore:

Different branch of same legal employer

and

different company in same corporate group

should not be confused.

What Happens If the Employee’s Job Title Changes After the Acquisition?

This should also be reviewed.

A transaction may result in foreign employees becoming:

• Managers,
• Directors,
• Engineers,
• Department heads,
• Specialists,
• Board members.

Work-permit assessment criteria can vary depending on the employee’s position and profession.

A substantial role change should therefore be reviewed together with the corporate transaction rather than treated merely as an internal HR matter.

What If the Foreign Employee Becomes a Company Manager?

Special attention may be required.

The Ministry confirms that certain foreign company partners, board members and managers may work in Turkey subject to work-permit rules, while specified non-resident board members and non-managing partners may fall within exemption provisions.

Therefore, an acquisition that converts an employee into a shareholder, director or manager can change the applicable immigration analysis.

Must the Ministry Be Notified About Relevant Changes?

The Ministry currently states that employers employing foreigners, and foreigners holding permits not tied to an employer where applicable, must notify the Ministry within 15 days regarding commencement and termination of work and circumstances that may require cancellation of the work permit or exemption.

This notification obligation is important in acquisition and restructuring scenarios.

The exact filing required depends on what changes in the transaction.

What Happens If the Foreign Employee Leaves the Seller?

The employer must address termination of the existing work-permit relationship.

The Ministry’s current electronic procedure provides for permit termination requests through the post-permit transaction functions of the work-permit system.

The buyer should separately ensure that the employee has the correct authorization to work for the acquiring entity.

Can the Buyer Simply Take Over the Old Work Permit Card?

A physical permit card should never be treated as a freely transferable employment authorization.

The important issue is not possession of the card.

It is whether the foreign employee is legally authorized to work:

for that employer + in that work arrangement + under the conditions covered by the permit.

A card issued in connection with Company A does not automatically authorize employment by Company B merely because Company B purchased Company A’s business.

Does the Remaining Validity Period of the Permit Matter?

A permit may still display months of remaining validity while the employment circumstances underlying it have materially changed.

Therefore:

Permit expiration date ≠ automatic authorization to work for any employer until that date.

Employer identity remains critical.

Can the Buyer File a New Domestic Work-Permit Application?

Where a new employer requires a new permit, eligibility for a domestic application should be checked.

The Ministry currently states that employers may generally submit a domestic work-permit application for foreigners holding a qualifying Turkish residence permit valid for at least six months and still valid on the application date; certain other legally present foreigners designated by the Directorate General may also be able to apply through the system without such a residence permit.

The correct application route therefore depends on the foreigner’s immigration position.

Does the Existing Work Permit Count as Residence Authorization?

Generally, a work permit issued under Law No. 6735 also functions as a residence permit under Article 27 of Law No. 6458, subject to statutory exceptions.

This makes transaction planning particularly important.

If an employer-linked work permit ends, the foreign employee should not consider only employment authorization. The consequences for lawful residence in Turkey may also require immediate analysis.

Can the Foreign Employee Continue Working While a New Application Is Pending?

This should never be assumed simply because an application has been submitted.

The Ministry expressly provides a limited continuation rule for qualifying extension applications: following expiry of the permit, work may continue during evaluation for up to 90 days provided that the work and workplace do not change.

That rule should not automatically be transferred to a new-employer situation.

A foreign employee moving to a different employer should confirm that the required authorization exists before beginning work for the buyer.

What Happens to Work-Permit Extensions After a Company Sale?

Where the same legal employer remains after a share acquisition, the future extension may still be associated with that employer.

The Ministry currently provides that an extension application may be made beginning 60 days before expiration and in any event before the existing permit expires. Positive first extensions may be issued for up to two years, and subsequent extensions for up to three years, where the foreigner remains with the same employer.

If the transaction results in a new employer, the case should instead be assessed under the rules applicable to that new employment relationship.

Will the Buyer Have to Meet Work-Permit Evaluation Criteria?

Potentially, yes.

Where the buyer must submit a new work-permit application, the acquiring company may need to satisfy the Ministry’s applicable employment, financial and salary criteria.

Current general criteria include requirements concerning Turkish-citizen employment, financial capacity and minimum remuneration levels depending on the foreign employee’s position.

Therefore, immigration due diligence should evaluate the buyer—not merely the seller.

Are There Important 2026 Changes to the Evaluation Criteria?

Yes.

The Ministry’s current criteria include changes effective from 3 August 2026.

For example, the Ministry states that, subject to the published conditions, employment and financial-capacity criteria are not applied to domestic work-permit applications for up to three qualifying foreigners who have legally stayed in Turkey for at least one year during the previous three years through a work permit, residence permit or international-protection status. Additional conditions apply.

The Ministry has also introduced sector-specific 2026 criteria and exemptions for certain industries.

This can matter significantly when an acquisition creates a need for new work-permit applications.

What About Companies With High Net Sales?

Under the Ministry’s current general evaluation criteria, where the workplace’s net sales for the previous year are at least TRY 50 million, the employment criterion is not applied in evaluating work-permit applications for up to five foreigners to be employed at that workplace.

For large corporate acquisitions, this can materially affect post-closing work-permit planning.

The remaining applicable criteria must still be examined.

Can the Sale Affect Highly Skilled Foreign Executives?

Yes.

An acquisition often changes senior management.

Foreign CEOs, general managers, technical directors, engineers and other executives may be moved between group companies or appointed to newly acquired companies.

The immigration team should verify:

• Employer identity,
• Position,
• Salary,
• Workplace,
• Corporate authority,
• Applicable work-permit criteria,
• Whether a new permit is required.

The transaction documents should also allow sufficient time for these processes.

What Should Be Checked During Work-Permit Due Diligence?

Before closing, the purchaser should identify every foreign employee and review at least:

1. Work-permit type.
2. Permit number and validity period.
3. Legal employer.
4. Workplace and registered address.
5. Employee’s job title.
6. Salary.
7. Social security registration.
8. Residence implications.
9. Whether the employee will remain with the same legal entity.
10. Whether a new work-permit application will be necessary.
11. Whether any Ministry notification is required.
12. Whether the buyer satisfies current evaluation criteria.

This review can prevent employees from inadvertently working without proper authorization immediately after closing.

Can the Buyer Discover Work-Permit Problems After Closing?

Yes.

Common problems can include:

• Permit issued to another group company,
• Employee actually working at an unapproved employer,
• Permit approaching expiration,
• Salary not satisfying applicable criteria,
• Incorrect workplace records,
• Missing termination notifications,
• Corporate information not updated,
• Unauthorized employment beginning immediately after transfer.

For this reason, foreign-employee compliance should be included in legal due diligence.

Should Work Permits Be Included in an SPA Due-Diligence Checklist?

For businesses employing foreign nationals, yes.

The share purchase agreement or transaction process may need to address:

• Validity of permits,
• Accuracy of immigration records,
• Compliance with employment conditions,
• Pending applications,
• Potential administrative fines,
• Responsibility for pre-closing violations,
• Cooperation with post-closing applications,
• Immigration conditions precedent where essential personnel are involved.

For key foreign executives, the ability to continue legally working after closing may be commercially important.

What Should Foreign Employees Do Before the Company Is Sold?

Foreign employees should obtain clarity on:

• Who will be their legal employer after closing,
• Whether their existing employer continues,
• Whether their workplace changes,
• Whether their job changes,
• Whether a new work permit is required,
• When the new application will be made,
• Whether existing authorization must be terminated,
• Whether residence status will be affected.

They should not rely only on verbal assurances that “the company is the same.”

The legal identity of the employer should be verified.

2026 Current Legal Position

The key rule applicable in 2026 is that ordinary employer-dependent work permits are linked to a specific employer and employment arrangement. The Ministry expressly states that a foreigner with a permit for one employer cannot work for another employer using the same permit and must obtain a new work permit to work for a different employer.

Accordingly, the effect of a Turkish company sale depends primarily on the transaction structure.

Share sale: If only ownership changes and the same legal company remains the foreigner’s employer, this is materially different from an employer transfer.

Asset/business transfer: If another legal entity becomes the employer, a new work-permit analysis is required and a new permit will generally be necessary before employment by that new employer.

Group transfer: Common ownership does not automatically permit a foreign employee to move between separate group companies using the same permit.

Branch/internal role change: The Ministry recognizes certain possibilities for work at another branch of the same employer in the same line of business or another position with the same employer, subject to the necessary conditions.

Notification: Relevant commencement, termination and circumstances potentially requiring permit cancellation are subject to a 15-day notification obligation.

2026 criteria: New work-permit applications following a transaction must be evaluated under the Ministry’s current criteria, including changes effective from 3 August 2026.

The practical strategy is therefore:

Identify the transaction type → identify the post-closing legal employer → audit every foreign employee’s permit → determine whether the employer changes → assess notification or new-application requirements → check the buyer against 2026 criteria → complete immigration procedures before unauthorized post-closing employment occurs.

Frequently Asked Questions

1. Does selling a Turkish company automatically cancel its foreign employees’ work permits?

Not necessarily. The effect depends on whether the same legal employer continues or the employees move to another legal entity.

2. What happens if only the company’s shares are sold?

Where the same company continues as the employer, a shareholder change is different from transferring the employee to another employer. Any related corporate-information or notification requirements should still be reviewed.

3. Can a foreign employee use the same permit after being transferred to the buyer?

Generally not where the buyer is a different legal employer. The Ministry states that working for a different employer requires a new work permit.

4. Does working at the same factory mean the old permit remains valid?

Not necessarily. Employer identity matters even if the workplace and job remain physically unchanged.

5. Can a foreign employee move to another company within the same corporate group?

The existing permit does not automatically authorize employment by a separate group company. A different legal employer generally requires a new permit.

6. What if only the company’s name changes?

A mere trade-name change may be different from a change of legal employer. The corporate identity and any required permit-record update should be verified.

7. Can the foreigner continue working while a new-employer application is pending?

This should not be assumed. The Ministry’s specific continuation rule for pending extensions applies where the work and workplace do not change and should not automatically be treated as authorization for employment by a new employer.

8. Does the buyer need to satisfy the 2026 work-permit criteria?

Potentially, yes, where a new application is required. Current employment, financial and salary criteria—and applicable exemptions—must be checked.

9. Is there a notification deadline when employment ends?

The Ministry states that relevant commencement, termination and permit-cancellation circumstances must be notified within 15 days.

10. Should foreign employees’ work permits be reviewed before an acquisition closes?

Yes. Pre-closing review can identify employees who require new permits, notifications or other action and can reduce the risk of unauthorized employment immediately after the transaction.

Legal Assistance for Foreign Employees During Company Acquisitions in Turkey

Foreign-employee work permits should be included in the legal due diligence of Turkish company acquisitions, mergers, business transfers and corporate restructurings. A transaction that appears seamless from a commercial perspective can still create a change of employer for immigration-law purposes.

Fırat Fesih Kaya Law Office advises foreign employees, investors and companies on Turkish work-permit and corporate immigration matters.

Lawyer Fırat Fesih Kaya assists with work-permit due diligence, employer changes, mergers and acquisitions, post-acquisition work-permit applications, foreign executive appointments, corporate restructurings and work-permit disputes in Turkey.

Phone: +90 312 434 22 22
Mobile: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No:221, Yıldırım Tower No:148, 06520 Balgat, Çankaya, Ankara, Turkey

This publication is provided for general informational purposes and does not constitute legal advice. The work-permit consequences of a company sale depend on the transaction structure, identity of the post-closing employer, permit type, employee’s role and current Ministry requirements.

Does a Change in Job Title Require a New Work Permit for Foreign Employees in Turkey?