What are the 2026 work permit requirements for foreign company shareholders in Turkey? Learn the minimum capital, 20% ownership rule, five-Turkish-employee requirement, USD 100,000 exception and new 2026 exemptions.

Foreign nationals who establish or become shareholders of a company in Turkey can potentially obtain a work permit to actively manage or work in that company. However, being a shareholder does not automatically provide work authorization.

In 2026, the Ministry of Labour and Social Security applies specific evaluation criteria to foreign shareholders who open a business or acquire shares in an existing business.

For workplaces subject to the balance-sheet accounting system, the ordinary shareholder work permit criteria currently require:

at least TRY 500,000 paid-in company capital,

at least TRY 500,000 capital attributable to the foreign shareholder,

at least 20% ownership by the foreign shareholder,

and, subject to the first-permit transition rule, at least five Turkish citizens employed at the workplace.

There is also an important exception: where the foreign shareholder’s capital share is USD 100,000 or more, the Ministry states that these ordinary shareholder capital, percentage and employment criteria do not apply.

Does Every Foreign Shareholder Need a Work Permit?

No.

Simply owning shares does not necessarily mean that the foreign investor is working in Turkey.

A passive foreign investor who lives abroad and does not participate in the company’s daily operations may be treated differently from a shareholder who personally manages employees, negotiates contracts, supervises business operations or works from the company’s Turkish office.

The work permit issue becomes especially important when the foreign shareholder is also an active manager, director or business owner.

Is Company Ownership Enough to Obtain a Work Permit?

No.

The company must satisfy the applicable Ministry criteria, and the foreigner’s ownership structure must also satisfy the shareholder requirements unless an exemption applies.

The Ministry evaluates the actual corporate structure rather than merely checking whether the applicant’s name appears in the shareholder records.

Accordingly, foreign investors should structure their capital and ownership percentages carefully before filing the work permit application.

What Is the Minimum Company Capital in 2026?

For a foreign shareholder applying under the ordinary shareholder criteria, the company must generally have paid-in capital of at least TRY 500,000.

This is not merely authorized or promised capital.

The Ministry’s criteria refer to paid-in capital, making it important that company records and supporting financial documentation accurately reflect the capital actually contributed.

How Much Capital Must the Foreign Shareholder Personally Hold?

The foreign shareholder’s own capital amount must generally also be at least TRY 500,000.

This means the company having TRY 500,000 capital by itself is not necessarily sufficient if the foreign applicant owns only a very small portion of that amount.

For example, if a company has TRY 2 million in paid-in capital but the foreign applicant’s individual share represents only TRY 200,000, the ordinary shareholder criterion would not be satisfied.

What Is the Minimum Ownership Percentage?

The foreign shareholder must ordinarily hold at least 20% of the company.

Therefore, the ordinary shareholder work permit test generally requires both:

TRY 500,000 minimum individual capital, and

20% minimum shareholding.

These are cumulative conditions under the standard rule.

Example: 25% Foreign Shareholder

A company has TRY 2 million in paid-in capital.

A foreign investor owns 25%, representing TRY 500,000.

The foreign shareholder therefore meets both the ordinary minimum capital contribution and the 20% ownership threshold.

The remaining work permit requirements, including the applicable employment criterion, must then be considered.

Example: 10% Foreign Shareholder

A company has TRY 5 million paid-in capital.

A foreign investor owns 10%, representing TRY 500,000.

Although the foreigner’s capital amount reaches TRY 500,000, the shareholder owns less than the ordinary 20% minimum shareholding requirement.

Accordingly, the standard shareholder criteria would not be satisfied merely because the monetary investment reaches TRY 500,000.

The person’s role and possible alternative work permit structure would need separate review.

Are Five Turkish Employees Required?

Generally, yes.

The Ministry’s 2026 shareholder criteria state that at least five Turkish citizens must be employed at the workplace for a foreign company shareholder or business owner.

However, an important transition rule applies to the foreigner’s first work permit.

When Does the Five-Employee Requirement Begin?

For a shareholder’s first work permit, the permit is issued subject to a condition concerning the employment criterion.

The Ministry provides that from the beginning of the seventh month of the first work permit, the workplace must employ at least five Turkish citizens in each month.

This means the company is generally given the first six months to build the required domestic workforce.

For many start-ups and newly incorporated companies, this is one of the most important work permit rules.

Does the Company Need Five Employees on the Application Date?

Under the first-permit shareholder rule, not necessarily.

The five-Turkish-employee requirement is generally deferred until the beginning of the seventh month of the foreign shareholder’s first permit.

However, the company should plan financially for this obligation from the beginning.

A shareholder should not obtain a first permit and then ignore the seventh-month employment condition.

What Happens During a Work Permit Extension?

The employment history becomes significantly more important.

Because the five-employee requirement applies from the seventh month of the first permit, compliance during the existing permit period can affect a later extension.

Companies should therefore maintain consistent payroll and employment records showing compliance with the required number of Turkish employees where the ordinary shareholder rule applies.

What Is the USD 100,000 Exception?

This is one of the most important exceptions for foreign investors in 2026.

The Ministry states that where the foreign shareholder’s capital share is USD 100,000 or more, the ordinary shareholder requirements concerning:

TRY 500,000 minimum company/shareholder capital,

20% minimum ownership,

and

five Turkish employees

do not apply under the shareholder criteria.

For substantial foreign investors, this can significantly simplify the work permit analysis.

Does USD 100,000 Guarantee Approval?

No.

The USD 100,000 exception removes the specific ordinary shareholder criteria listed by the Ministry, but it does not turn the work permit into an automatic right.

The Ministry continues to evaluate work permit applications under international labour force policy and the applicable legal framework.

Accordingly, corporate documentation, the foreigner’s actual position, the legitimacy of the business and other relevant requirements remain important.

Does the USD 100,000 Threshold Refer to Total Company Capital?

No.

The Ministry’s criterion refers to the foreign shareholder’s capital share.

Accordingly, the focus is on the amount attributable to the particular foreign applicant rather than merely the company’s total capitalization.

For example, a company may have USD 500,000 equivalent in total capital, but if the foreign applicant’s individual share is only USD 50,000, the USD 100,000 shareholder exception would not be satisfied on that basis.

What Are the General Employment Criteria for Foreign Workers?

Separate from the shareholder-specific rules, the Ministry’s general criteria ordinarily require at least five Turkish citizens for each foreign employee at a workplace subject to balance-sheet accounting.

A separate general exception applies to workplaces whose previous-year net sales are at least TRY 50 million: employment criteria are not applied for work permit applications covering up to five foreign workers.

However, shareholder applications should first be assessed under the specific shareholder criteria rather than automatically applying ordinary employee rules.

What Are the General Financial Criteria for Existing Companies?

For ordinary foreign employee applications, an existing business with at least one completed financial year generally satisfies the financial-capacity criterion through one of the following:

TRY 500,000 paid-in capital,

TRY 8 million net sales,

or

USD 150,000 in exports.

These general business criteria should not be confused with the special shareholder requirements.

For foreign shareholders, the Ministry separately imposes the minimum shareholder capital and ownership criteria described above unless an exemption applies.

What About Newly Established Companies?

Under the general criteria, a newly incorporated workplace that has not yet prepared its first year-end balance sheet and income statement must generally have at least TRY 500,000 paid-in capital for foreign employee applications.

For an applicant who is also a shareholder, however, the special shareholder rules remain particularly important.

Accordingly, company formation and work permit planning should ideally be handled together.

Did the Work Permit Criteria Change in 2026?

Yes.

The Ministry introduced additional exceptions effective August 3, 2026.

One significant rule applies to certain domestic work permit applications made for foreigners who, during the three years before the application date, have legally remained in Turkey for at least one year under a work permit, residence permit or international protection status.

For up to three qualifying foreigners at the same workplace, the Ministry states that the ordinary employment and financial-capacity criteria are not applied, provided the other conditions of the rule are satisfied.

What Is the One-Year-in-Three-Years Rule?

Under the rule effective August 3, 2026, a foreign national who has legally remained in Turkey for at least one year during the previous three years under one of the specified lawful statuses may potentially benefit from relaxed employment and financial criteria in a domestic work permit application.

The rule is generally limited to three qualifying foreign workers at the same workplace.

The number of foreign workers benefiting from this exception must also generally not exceed the number of Turkish citizens working at that workplace.

Whether this exception changes the outcome for a foreign shareholder should be assessed according to the applicant’s precise work permit category and corporate position.

What Happens With the Fourth Foreign Worker?

Where more than three qualifying foreigners are employed under the August 2026 framework, the fourth and subsequent foreigners are generally evaluated under ordinary criteria.

The Ministry states that the workplace must then satisfy the requirement of five Turkish citizens for each additional foreigner and meet the relevant financial-capacity requirements.

Are Some Foreigners Completely Exempt From Employment, Financial and Salary Criteria?

Certain categories receive broader exemptions.

The Ministry states that employment, financial-capacity and wage criteria are generally not applied to qualifying foreigners including:

foreigners whose parent or child is a Turkish citizen,

holders of humanitarian residence status,

recognized stateless persons,

holders of long-term residence status,

foreigners who have lived in a marriage with a Turkish citizen for at least three years,

and certain foreigners who have remained legally in Turkey for at least eight years under qualifying statuses. The eight-year provision became effective on August 3, 2026.

The Ministry expressly notes, however, that being within an exempt category does not create an absolute right to receive a work permit.

Does the Foreign Shareholder Need to Be a Manager?

The corporate role matters.

A passive foreign shareholder who does not participate in active management presents a different work permit issue from a shareholder who is also the company’s managing director, operational director or executive.

A shareholder work permit should reflect genuine business activity.

Foreign investors should therefore make sure that:

the corporate records,

the work permit application,

the company’s registered management structure,

and the foreigner’s actual daily role

are consistent with one another.

Can a Foreign Shareholder Work Before the Permit Is Approved?

The foreign investor should not assume that company ownership authorizes work.

The company may already be legally incorporated, but the foreign shareholder must still have the appropriate work authorization before carrying out activities that constitute work in Turkey.

Daily management, supervising employees, providing professional services or continuously operating the company from Turkey can create work authorization issues.

Does the Work Permit Also Provide Residence Authorization?

Generally, a valid work permit also serves as lawful residence authorization during its validity, subject to specific statutory exceptions.

This is why the shareholder work permit can be particularly important for foreign entrepreneurs who want both to actively manage their company and live in Turkey.

The residence right arises from the work permit rather than merely from ownership of the company.

Can the Application Be Filed From Turkey?

Potentially, depending on the foreigner’s current lawful status.

Domestic and overseas application procedures are distinct.

A foreign shareholder already lawfully present in Turkey should determine whether they meet the requirements for a domestic application before filing.

Otherwise, the application may need to begin through the appropriate Turkish foreign mission.

Does the Shareholder Need to Receive a Salary?

The treatment of a foreign shareholder should be distinguished from an ordinary salaried foreign employee.

General work permit rules contain wage criteria for categories such as senior executives, managers, engineers, architects and specialists.

The shareholder application should therefore be structured according to the applicant’s actual legal status and role rather than automatically applying an ordinary employee salary model.

What Are the General 2026 Salary Multiples?

For applications to which the general wage criteria apply, the Ministry currently requires 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 and skilled roles,

and at least the gross minimum wage for certain other occupations.

The correct wage category should be determined according to the position declared in the work permit application.

Are There Special Rules for Large Foreign Investments?

Yes.

Certain foreign-owned companies that qualify as special foreign direct investments are subject to separate rules for foreign personnel.

For 2026, one route to qualifying as a special foreign direct investment requires foreign shareholders’ total capital share of at least TRY 21,946,007 together with company or branch annual turnover of at least TRY 1,648,938,600. Other qualifying routes also exist.

Large multinational investors should therefore determine whether the ordinary shareholder criteria or the special foreign direct investment regime is more relevant.

Practical Example: Foreign Shareholder Meets the Standard Criteria

A foreign investor establishes a company in Istanbul with TRY 1 million paid-in capital.

The foreign investor owns 60%, representing TRY 600,000.

The ordinary shareholder capital requirements are satisfied because:

the company’s paid-in capital exceeds TRY 500,000,

the foreigner’s capital exceeds TRY 500,000,

and the ownership percentage exceeds 20%.

If the first shareholder work permit is granted, the company must ordinarily begin employing at least five Turkish citizens from the seventh month unless an applicable exemption applies.

Practical Example: Foreign Shareholder Invests USD 150,000

A foreign entrepreneur establishes a company in Ankara and holds a capital share worth USD 150,000.

Because the foreign shareholder’s capital share exceeds USD 100,000, the Ministry states that the ordinary shareholder capital, ownership percentage and five-employee criteria do not apply.

This does not guarantee approval, but it substantially changes the evaluation framework.

Practical Example: Foreign Shareholder Owns 15%

A foreign investor owns 15% of a Bursa company and the value of that share is TRY 800,000.

The investor satisfies the TRY 500,000 individual capital threshold but does not satisfy the ordinary 20% ownership requirement.

Unless another exception or appropriate permit structure applies, the ordinary shareholder criteria are not fully met.

Practical Example: Start-Up With No Employees

A foreign founder establishes a technology company in Izmir with qualifying capital and ownership.

At the time of the first shareholder work permit application, the company has no Turkish employees.

The first-permit framework generally allows the foreign shareholder to build the workforce during the initial six-month period, but from the beginning of the seventh month at least five Turkish citizens must ordinarily be employed each month.

Practical Example: Long-Term Foreign Resident

A foreign entrepreneur has already spent eight qualifying lawful years in Turkey and establishes a company in Mersin.

The Ministry’s 2026 criteria list certain foreigners with at least eight years of qualifying lawful stay among those exempt from the employment, financial-capacity and wage criteria.

The applicant must still document eligibility, and exemption from the criteria does not guarantee permit approval.

What Documents Should Be Checked Before Applying?

Although requirements depend on the individual case, foreign shareholders should generally ensure that their application is consistent with:

the trade registry records,

current shareholder structure,

paid-in capital records,

company financial documents,

employment records,

tax information,

passport and immigration status,

management authority,

and the actual work to be performed.

Inconsistencies between corporate records and the work permit application can create unnecessary rejection risk.

2026 Foreign Shareholder Work Permit Checklist

Before applying, a foreign investor should confirm:

Is the foreigner an active or passive shareholder? → Is paid-in company capital at least TRY 500,000? → Does the foreigner’s own share represent at least TRY 500,000? → Does the foreigner own at least 20%? → Is the foreigner’s capital share at least USD 100,000, making the ordinary shareholder criteria inapplicable? → Is this the first work permit? → When will the five-Turkish-employee obligation begin? → Does an August 2026 exemption apply? → Does the foreigner qualify for a broader personal exemption? → Is the company a special foreign direct investment? → Are corporate and work permit records consistent?

Frequently Asked Questions

1. What is the minimum investment for a foreign shareholder’s work permit in 2026?

Under the ordinary shareholder criteria, the company must generally have at least TRY 500,000 paid-in capital, and the foreign shareholder’s individual capital amount must also be at least TRY 500,000.

2. What percentage of the company must the foreigner own?

The ordinary criterion requires at least 20% ownership.

3. Are five Turkish employees required?

Generally yes. For the foreign shareholder’s first work permit, however, this requirement ordinarily begins from the start of the seventh month.

4. Must five Turkish employees already be working when the first application is filed?

Not ordinarily under the shareholder first-permit transition rule. The five-employee requirement generally begins from month seven.

5. What happens if the foreign shareholder invests USD 100,000 or more?

The Ministry states that where the foreign shareholder’s capital share is at least USD 100,000, the ordinary shareholder capital, ownership and five-Turkish-employee criteria do not apply.

6. Does a USD 100,000 investment automatically guarantee a work permit?

No. It removes specified shareholder evaluation criteria, but the Ministry still evaluates the application.

7. Did any important rules change in August 2026?

Yes. From August 3, 2026, certain qualifying domestic applicants with at least one year of lawful stay during the preceding three years may benefit from exemption from general employment and financial-capacity criteria, subject to numerical and workplace limitations.

8. Are long-term foreign residents exempt from some criteria?

Yes. Current criteria include several exempt categories, including certain foreigners with at least eight years of qualifying lawful stay.

9. Does meeting all criteria guarantee approval?

No. The Ministry expressly states that falling within an exemption does not create an absolute right to a work permit, and applications remain subject to official evaluation.

10. Can a foreign shareholder establish the company first and apply for the permit afterward?

Yes. In practice, the company and shareholder structure must exist before the shareholder work permit criteria can be meaningfully evaluated. Active work in Turkey should then begin only after the appropriate authorization is obtained.

Legal Assistance for Foreign Shareholder Work Permits in Turkey

The 2026 shareholder work permit rules require careful planning because company formation, shareholder ownership and permission to work are separate legal issues.

Under the ordinary rules, a foreign company shareholder generally needs at least TRY 500,000 in personal capital, a company with at least TRY 500,000 paid-in capital and at least 20% ownership. The five-Turkish-employee requirement generally becomes applicable from the beginning of the seventh month of the shareholder’s first permit. A major exception applies where the foreign shareholder’s capital share reaches USD 100,000, in which case the Ministry states that those ordinary shareholder criteria do not apply.

The 2026 amendments also make it important to examine the foreigner’s previous lawful stay in Turkey and whether any personal or workplace-specific exemption applies.

Firat Fesih Kaya Law Office provides legal assistance to foreign founders, shareholders, executives and international investors in Ankara, Istanbul, Izmir, Mersin, Bursa and throughout Turkey concerning shareholder work permits, company establishment, ownership restructuring, work permit extensions, foreign director applications and foreign investment planning.

Legal assistance may include reviewing capital and ownership requirements, evaluating the USD 100,000 exception, determining when the five-employee condition applies, assessing the August 2026 exemptions and coordinating company registration with the work permit application.

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 most important 2026 rule is this: do not structure the company’s capital and shareholding first and examine the work permit requirements afterward. For foreign founders who intend to work in the company, the ownership and capital structure should be designed with the work permit criteria in mind from the beginning.