Learn the 2026 capital, shareholding and Turkish employee requirements for foreign company shareholders seeking work permits in Turkey, including the TRY 500,000 rule, 20% ownership requirement and USD 100,000 exemption.

Foreign nationals who establish a company or become shareholders in an existing company in Turkey frequently assume that company ownership automatically gives them the right to work in that business. This is incorrect. Owning shares in a Turkish company and having legal authorization to work in Turkey are separate matters.

For 2026, the Ministry of Labour and Social Security applies specific financial and employment criteria to work permit applications filed for foreign company shareholders. The most important thresholds are a minimum TRY 500,000 capital share, at least 20% ownership, and a minimum TRY 500,000 total paid-in capital of the company for foreign shareholders falling under the standard shareholder criteria.

There is also a particularly important exception: where the foreign shareholder has a capital share of USD 100,000 or more, the standard shareholder capital/share-ratio and five-Turkish-employee criteria are not applied.

What Is the Minimum Capital Requirement for a Foreign Shareholder in 2026?

For businesses operating under the balance-sheet method, the current Ministry criteria provide that a foreigner who establishes a new business or becomes a shareholder in an existing business must generally satisfy three connected financial conditions.

The foreigner’s own capital contribution must be at least TRY 500,000.

The company’s total paid-in capital must be at least TRY 500,000.

The foreigner’s ownership percentage must be at least 20%.

These criteria have applied at their current threshold level since 1 January 2025 and remain part of the Ministry’s current 2026 evaluation framework.

Is TRY 500,000 Company Capital Alone Enough?

No.

This is one of the most important distinctions for foreign investors.

It is not enough for the Turkish company’s total paid-in capital merely to reach TRY 500,000. The foreign shareholder seeking the work permit must also personally hold a capital amount of at least TRY 500,000.

For example, assume a company has total paid-in capital of TRY 2,000,000.

A foreign investor owns 20% of the company.

The investor’s capital share would therefore be TRY 400,000.

Although the company itself exceeds the TRY 500,000 threshold and the foreigner owns 20%, the foreigner’s individual capital amount would remain below TRY 500,000. Under the standard shareholder criteria, the financial threshold would therefore not be satisfied.

Is There a Minimum Shareholding Percentage?

Yes.

The foreign shareholder must generally own at least 20% of the company under the standard shareholder work permit criteria.

This requirement operates together with the TRY 500,000 individual capital threshold.

A foreigner cannot normally satisfy the standard shareholder criterion merely by investing TRY 500,000 if that investment represents less than 20% of the company’s capital.

Example: TRY 500,000 Investment and 20% Ownership

Consider a company with TRY 2,500,000 paid-in capital.

A foreign shareholder contributes TRY 500,000.

The foreigner’s ownership percentage is 20%.

In principle, the capital structure satisfies the standard shareholder financial requirements because:

Company paid-in capital: TRY 2,500,000
Foreign shareholder’s capital: TRY 500,000
Foreign shareholder’s ownership: 20%

The remaining work permit requirements must still be examined.

Meeting the capital threshold does not guarantee approval of the work permit.

Example: TRY 500,000 Investment but Only 10% Ownership

Assume the company has TRY 5,000,000 paid-in capital and the foreigner holds TRY 500,000.

The monetary threshold is satisfied, but the ownership percentage is only 10%.

Under the ordinary shareholder criteria, this would fail the minimum 20% shareholding requirement.

The company may therefore need to restructure the shareholder’s capital position before the application is filed, unless an applicable exemption or different evaluation category exists.

Example: 25% Ownership but Only TRY 250,000 Capital

Assume a company has TRY 1,000,000 paid-in capital.

A foreign investor owns 25%, corresponding to TRY 250,000.

Although the investor exceeds the minimum 20% ownership requirement, the investor’s individual capital amount remains below TRY 500,000.

The standard financial criterion is therefore not satisfied.

This demonstrates why both the percentage and monetary value of the foreigner’s shares must be checked.

What Happens If the Foreign Shareholder Invests USD 100,000 or More?

This is one of the most important 2026 rules for substantial foreign investors.

Under the Ministry’s current criteria, where the foreign shareholder has a capital share of USD 100,000 or more, the standard requirements concerning the TRY 500,000 shareholder capital threshold, 20% ownership threshold and five-Turkish-employee criterion are not applied.

This can substantially change the work permit strategy for larger foreign investments.

For investors approaching this threshold, the company’s capital documentation and the value attributable to the foreigner’s share should therefore be reviewed carefully before filing.

Does a Foreign Shareholder Have to Employ Five Turkish Citizens?

Under the standard rule, yes.

For a foreigner who establishes a business or becomes a shareholder in an existing business, the workplace must employ at least five Turkish citizens.

However, the rule is structured differently for the initial permit.

For the foreign shareholder’s first work permit, the five-Turkish-citizen employment condition is effectively deferred during the first six months. From the beginning of the seventh month, the workplace must employ at least five Turkish citizens every month.

This provides newly established foreign-owned businesses with an initial period in which to develop their workforce.

What Happens During the First Six Months?

The first permit granted to a foreign company shareholder or business owner is issued with a notation concerning the employment requirement.

The Ministry’s current work permit annotations confirm that the five-Turkish-citizen requirement does not apply during the initial six-month period. Beginning with the seventh month, at least five Turkish citizens must be employed each month.

This distinction is especially important for start-ups and newly incorporated foreign-owned businesses.

What Happens After the Seventh Month?

From the beginning of the seventh month, the company must generally maintain at least five Turkish employees every month where the ordinary foreign-shareholder criteria apply.

Temporary compliance may therefore not be sufficient.

For example, employing five Turkish citizens only shortly before the work permit extension application may create problems if the company’s employment history shows that the requirement was not maintained during the relevant period.

What Happens When the Work Permit Is Extended?

For an extended work permit held by a foreign shareholder or business owner, the Ministry’s current permit annotations state that at least five Turkish citizens must be employed every month throughout the permit period. Failure to satisfy the requirement may result in rejection of the extension request.

Foreign-owned businesses should therefore treat the employment requirement as an ongoing compliance obligation rather than merely an application-date requirement.

Does the Five-Employee Requirement Apply to a USD 100,000 Foreign Shareholder?

Under the Ministry’s current criteria, the standard shareholder requirements are not applied where the foreign shareholder has a capital share of USD 100,000 or more.

This exception covers both the shareholder financial criteria and the employment criterion contained in the standard shareholder provision.

For high-value foreign shareholders, this can be a major advantage.

What Is the Difference Between Company Capital and the Foreign Shareholder’s Capital?

These concepts should not be confused.

Company paid-in capital refers to the total paid-in capital of the business.

Foreign shareholder capital refers to the amount of that capital attributable to the individual foreign shareholder seeking the work permit.

Under the standard 2026 rule, both figures matter.

For example:

Company paid-in capital: TRY 10,000,000
Foreign shareholder: 5%
Foreign shareholder capital: TRY 500,000

Although the foreigner’s monetary capital reaches TRY 500,000, the 5% ownership level remains below the standard 20% threshold.

Therefore, the ordinary shareholder criterion would not be satisfied solely because the foreigner invested TRY 500,000.

Do the TRY 8 Million Net Sales and USD 150,000 Export Thresholds Apply to Foreign Shareholders?

A distinction is necessary.

Under the Ministry’s general financial eligibility criteria for workplaces employing foreigners, an existing balance-sheet-basis workplace can satisfy the general financial criterion by having:

• At least TRY 500,000 paid-in capital;
• At least TRY 8,000,000 in net sales; or
• At least USD 150,000 in exports.

However, foreign company shareholders are subject to a separate specific section of the evaluation criteria.

Therefore, an investor should not assume that a company’s TRY 8 million turnover or USD 150,000 exports automatically replaces the specific capital and ownership requirements applicable to a foreign shareholder.

The application category must be identified correctly.

Does the TRY 50 Million Net Sales Exemption Apply?

The Ministry’s general 2026 criteria contain another important rule.

A workplace with net sales of TRY 50,000,000 or more in the previous year is exempt from the general employment criterion for work permit applications concerning up to five foreigners.

However, foreign company shareholders have their own specific evaluation criteria.

Accordingly, the TRY 50 million general exemption should not automatically be treated as replacing the separate shareholder criteria without first determining the correct legal category of the application.

What About Newly Established Companies?

New companies require particular planning because they may not yet have annual financial statements or turnover history.

For an ordinary foreign employee, a newly established balance-sheet-basis workplace that has not yet prepared a year-end balance sheet and annual income statement must generally have at least TRY 500,000 paid-in capital.

For a foreign shareholder, however, the specific shareholder rules additionally require the foreigner’s own capital position and share percentage to satisfy the shareholder criteria unless an exemption applies.

This makes capital planning before incorporation particularly important.

Should Foreign Investors Plan the Capital Structure Before Establishing the Company?

Yes.

Many avoidable work permit problems arise because foreign investors establish the company first and examine immigration and employment requirements afterward.

Before incorporation, the investor should determine:

• Total company capital
• Foreign investor’s capital amount
• Foreign investor’s ownership percentage
• Number of foreign shareholders
• Which foreign shareholders will actively work
• Expected number of Turkish employees
• Whether the USD 100,000 shareholder exception can be used
• Whether another exemption applies

The shareholding structure should therefore be designed together with the intended work permit strategy.

Does Every Foreign Shareholder Need a Work Permit?

Not necessarily.

A distinction should be made between passive investment and actively working in or managing the company.

Merely owning shares should not automatically be equated with performing work.

However, where the foreign shareholder actively performs management, operational, executive, commercial, or professional activities in Turkey, work authorization issues can arise.

The person’s actual role should therefore be examined rather than relying only on their title in the company’s corporate records.

Can a Foreign Shareholder Become a Company Manager?

Corporate authority and work authorization are separate issues.

Being appointed as a manager, director, or authorized representative does not necessarily eliminate the need for appropriate work authorization.

The investor’s corporate-law position and international labour-law status should therefore be assessed together.

Are There Exceptions to the General Financial and Employment Criteria in 2026?

Yes, and an important change became effective on 3 August 2026.

Under the current general criteria, for domestic work permit applications made for foreigners who, as of the application date, have legally remained in Turkey for at least one year during the previous three years under a work permit, residence permit, or international protection, the general employment and financial eligibility criteria are normally not applied for up to three foreigners meeting the conditions. Additional restrictions apply, including the relationship between the number of foreign and Turkish employees.

There are also categories of foreigners for whom employment, financial eligibility and salary criteria generally do not apply, including certain long-term residents and other specifically identified groups. The current list was also updated in 2026.

However, an exemption from evaluation criteria does not itself create an absolute right to receive a work permit.

Are Long-Term Residents Exempt?

Under the Ministry’s current criteria, foreigners holding a long-term residence permit are among the categories for whom employment, financial eligibility and salary criteria are generally not applied.

The applicant must document eligibility for the exemption.

Even then, the Ministry retains authority to evaluate the work permit application under the applicable international labour force policy.

What About Foreigners Who Have Lived in Turkey for Many Years?

The 2026 criteria include a significant exemption for foreigners who have spent at least eight years in Turkey under specified lawful statuses, including qualifying residence and work permits.

This provision became effective on 3 August 2026.

Long-term foreign residents considering company ownership should therefore determine whether they fall within an exemption before restructuring company capital solely for work permit purposes.

What Are the 2026 Special Foreign Direct Investment Thresholds?

Large foreign investments may fall under a separate framework for Specific Foreign Direct Investments.

For 2026, the Ministry states that certain categories require total foreign shareholders’ capital of at least TRY 21,946,007, together with one of specified conditions, such as annual turnover of at least TRY 1,648,938,600, exports of at least USD 1 million, or at least 250 employees registered with the Social Security Institution. Another route concerns a planned fixed investment of at least TRY 522,163,890.

These thresholds relate to the special foreign direct investment regime and should not be confused with the ordinary TRY 500,000 foreign-shareholder work permit rule.

Is a TRY 500,000 Investment Enough to Guarantee a Work Permit?

No.

The Ministry evaluates work permit applications according to the applicable evaluation criteria and international labour force policy. Properly completed applications are generally evaluated within 30 days once all required information and documents are complete.

Therefore, satisfying the capital threshold is a prerequisite in applicable cases—not a guarantee of approval.

Other factors may include:

• Corporate documentation
• Actual business activity
• Employment structure
• Applicant’s role
• Social security records
• Sector-specific requirements
• Professional restrictions
• Salary requirements where applicable
• Accuracy of submitted information

Can Increasing Capital After Company Formation Solve the Problem?

Potentially.

Where the foreign shareholder’s capital is below the required threshold, a properly completed capital increase and corresponding corporate changes may bring the structure into compliance.

However, the increase should be genuine and properly documented.

Relevant records may include:

• Shareholders’ resolutions
• Trade registry records
• Articles of association
• Capital payment documents
• Updated shareholding records
• Financial records

The structure should be corrected before the work permit application rather than relying on an intended future increase.

What If the Foreigner’s Share Falls Below 20% After the Permit Is Granted?

Changes in ownership may affect the factual basis on which the work permit was granted.

Share transfers, capital increases, new investors, mergers, and corporate restructurings can alter the foreigner’s percentage even if their nominal investment remains unchanged.

Foreign shareholders should therefore review work permit consequences before completing major corporate transactions.

What Documents Are Particularly Important for a Foreign Shareholder?

Depending on the application, relevant documentation may include:

• Trade registry records
• Articles of association
• Shareholding documents
• Capital information
• Financial statements
• Employment records
• Social security records
• Passport
• Residence documents where applicable
• Corporate authorization documents
• Documents proving any claimed exemption

Consistency between corporate records and the work permit application is essential.

2026 Work Permit Planning for Foreign Investors

For most foreign shareholders applying under the standard company-partner criteria in 2026, the key numbers can be summarized as follows:

Minimum company paid-in capital: TRY 500,000
Minimum foreign shareholder capital: TRY 500,000
Minimum foreign ownership percentage: 20%
Standard Turkish employment requirement: 5 Turkish citizens
Employment requirement begins: Start of the seventh month of the initial permit
Major shareholder exception: Capital share of USD 100,000 or more

Foreign investors should nevertheless avoid treating these figures as a mechanical checklist. The correct application category, available exemptions, company history, employment structure and the foreigner’s actual role can materially change the analysis.

Frequently Asked Questions

1. How much capital does a foreign shareholder need for a Turkish work permit in 2026?

Under the standard shareholder criteria, the foreigner’s capital amount 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.

2. Is owning 20% of a Turkish company enough?

No. The foreign shareholder must generally satisfy both the minimum ownership percentage and the minimum monetary capital amount.

3. Is TRY 500,000 capital enough if I own only 10%?

Under the standard shareholder criteria, no. The foreigner’s shareholding must generally also reach 20%.

4. Do foreign shareholders have to employ five Turkish citizens?

Generally yes under the standard shareholder rule. For the first permit, the requirement applies from the beginning of the seventh month.

5. Do I need five Turkish employees immediately after establishing the company?

Under the initial foreign-shareholder permit framework, the five-employee requirement is not applied during the first six months. It becomes applicable from the seventh month.

6. What happens if my capital share is USD 100,000?

Under the current Ministry criteria, where the foreign shareholder’s capital share is at least USD 100,000, the standard shareholder capital/shareholding and five-Turkish-employee criteria are not applied.

7. Can company turnover replace the TRY 500,000 shareholder capital requirement?

The general workplace criteria allow certain existing businesses to satisfy financial eligibility through TRY 8 million net sales or USD 150,000 exports, but foreign company shareholders are governed by a separate specific shareholder provision. The categories should not be confused.

8. Does being a shareholder automatically give a foreigner the right to work in Turkey?

No. Company ownership and authorization to work are separate legal matters.

9. Can I increase company capital before applying?

Potentially. A properly completed and documented capital increase may bring the corporate structure into compliance, but the resulting ownership percentage must also be checked.

10. Were there important changes to the work permit criteria in 2026?

Yes. The Ministry’s current criteria include changes effective from 3 August 2026, including revised general exemptions for certain foreigners with previous lawful stay and other sector- and status-specific rules.

Client-Focused Work Permit and Foreign Investment Legal Support

The capital requirement for a foreign shareholder’s work permit should be examined before establishing the company, transferring shares, increasing capital, or submitting the work permit application. A structure that appears commercially appropriate may fail the work permit criteria because the foreigner’s individual capital contribution, ownership percentage, or employment obligations are insufficient.

Fırat Fesih Kaya Law Office assists foreign investors, entrepreneurs, company shareholders, executives, start-ups, and international businesses with company establishment and work permit procedures in Turkey.

Lawyer Fırat Fesih Kaya provides legal assistance concerning foreign shareholder work permits, capital and shareholding requirements, company restructuring, work permit refusals and appeals, Turkish employee requirements, foreign investment structures, work permit extensions, and 2026 compliance requirements.

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