

What happens if property purchased for Turkish citizenship later falls below USD 400,000 in market value? Learn the 2026 rules on valuation, investment amount, three-year holding requirement, mortgages and citizenship applications.
Foreign investors who purchase real estate in Turkey for the purpose of obtaining Turkish citizenship frequently ask what happens if the property’s market value decreases after the acquisition. This concern can become particularly important when a property purchased at or slightly above the required investment threshold later falls in value because of market conditions, exchange-rate movements, changes in the local property market or property-specific problems.
The central question is whether a later decline in market value automatically causes the investor to lose eligibility for Turkish citizenship.
Under the current framework, a subsequent ordinary decrease in the property’s market value does not, by itself, mean that the citizenship application automatically fails. The citizenship investment assessment focuses on whether the qualifying investment requirements were satisfied through the values and payment documentation required for the citizenship transaction, together with compliance with the mandatory holding commitment.
Current Land Registry guidance provides that, for property purchased on or after September 19, 2018, the required investment amount is USD 400,000 or its equivalent. The declared sale price or qualifying promise-of-sale price and the documented payments must satisfy the applicable threshold, and the qualifying amount must be confirmed under the current Investment Amount Determination Certificate framework. (Tapu ve Kadastro Genel Müdürlüğü)
This means that foreign investors should distinguish carefully between a legitimate market-value decline after a properly completed qualifying investment and a problem showing that the property never actually satisfied the citizenship requirements in the first place.
As of 2026, the qualifying property investment threshold remains USD 400,000 or its equivalent for acquisitions governed by the current threshold.
The official Land Registry guidance states that the relevant values used for the citizenship investment determination must independently satisfy the required amount. These include the sale price declared in the official deed or the qualifying price under a promise-of-sale arrangement and the relevant payment transfers. The current system uses an Investment Amount Determination Certificate to confirm the qualifying investment amount. (Tapu ve Kadastro Genel Müdürlüğü)
Accordingly, simply paying USD 400,000 to a seller does not automatically guarantee that every property transaction qualifies.
The transaction must satisfy the complete citizenship investment framework.
The rules should not be interpreted as requiring a foreign investor to guarantee that the open-market value of the property can never fall below USD 400,000 during the three-year holding period.
Property markets fluctuate.
An apartment worth USD 430,000 at acquisition may later be worth USD 390,000 because market demand declines. Another property may increase to USD 500,000. These ordinary market movements are not controlled by the investor.
The key requirements concern the qualifying investment at the relevant transaction stage and compliance with the required restriction against disposal.
Official Land Registry guidance confirms that the qualifying property is subject to a three-year non-sale commitment for citizenship purposes. (Tapu ve Kadastro Genel Müdürlüğü)
Therefore, investors should not confuse the three-year holding requirement with an obligation to maintain a constantly changing market valuation above USD 400,000.
Consider a foreign investor who purchases a qualifying apartment for citizenship purposes.
At the relevant transaction stage, the citizenship investment documentation properly confirms an eligible investment exceeding USD 400,000. The official deed, qualifying payment documentation and required investment determination satisfy the applicable requirements.
One year later, the real estate market declines and an independent valuer estimates the apartment at USD 380,000.
An ordinary subsequent market decline of this kind does not mean that the original qualifying investment is retrospectively converted into a USD 380,000 transaction.
The important issue is whether the investor genuinely satisfied the citizenship investment requirements when required and continues complying with the holding commitment.
The situation is different where the “fall in value” reveals that the original transaction itself may have been problematic.
Suppose a property was presented to a foreign investor as worth USD 450,000, but evidence later suggests that its genuine qualifying value at the relevant time was substantially below the threshold.
That is not necessarily an ordinary post-purchase market decline.
It may instead raise questions concerning the original valuation, declared transaction value, payment documentation or authenticity of the investment.
Current Land Registry procedures are specifically designed to verify the amount qualifying for citizenship through the Investment Amount Determination Certificate. (Tapu ve Kadastro Genel Müdürlüğü)
Foreign investors should therefore distinguish between subsequent depreciation and an original valuation or eligibility defect.
The current citizenship property framework places significant importance on the Investment Amount Determination Certificate.
Under the Land Registry’s current guidance, this certificate is produced through the authorized valuation infrastructure and indicates the property investment amount that may be accepted for citizenship purposes. The certificate is generated through the relevant electronic systems rather than being treated as an ordinary valuation report obtained privately by the buyer. (Tapu ve Kadastro Genel Müdürlüğü)
The current framework entered into force in December 2024 and remains directly relevant to 2026 citizenship-related property transactions.
This change makes old online articles describing earlier valuation procedures increasingly unreliable.
Under the current framework, the period between the certificate and the citizenship-related land registry transaction application must not exceed six months.
If more than six months have passed, the valuation report underlying the certificate must be renewed. (Tapu ve Kadastro Genel Müdürlüğü)
The Land Registry’s current frequently asked questions also confirm the six-month validity framework for certificates issued after December 9, 2024. (Tapu ve Kadastro Genel Müdürlüğü)
This is an important 2026 point for investors who obtain valuation documentation but delay the property transaction.
Foreign investors should not assume that only one number matters.
Official Land Registry guidance states that the relevant transaction values used for the citizenship determination must satisfy the required threshold. This includes the applicable value reflected in the citizenship investment determination, the declared sale or qualifying promise-of-sale amount and documented payment transfers. (Tapu ve Kadastro Genel Müdürlüğü)
Accordingly, artificial arrangements in which the contract states USD 400,000 while substantially less money is actually transferred create serious risks.
The safest citizenship acquisition is one in which the commercial transaction, banking documentation and official citizenship investment documentation all consistently support the qualifying investment.
Exchange-rate movements can significantly affect how investors perceive the value of Turkish property.
An investor may buy property that satisfies the USD 400,000 requirement at the relevant transaction stage but later calculate that its Turkish-lira market value converts into less than USD 400,000 because of exchange-rate movements.
That subsequent conversion does not automatically rewrite the original qualifying transaction.
The relevant citizenship assessment is conducted according to the prescribed investment and payment framework.
However, exchange-rate calculations before or during the qualifying transaction can be critical because the required USD equivalent must actually be satisfied under the applicable rules.
A fall in value does not eliminate the three-year commitment.
The official procedure requires the relevant commitment not to sell the qualifying property for three years to be registered as part of the citizenship process. (Tapu ve Kadastro Genel Müdürlüğü)
An investor who becomes concerned about falling prices should therefore not simply sell the property before the restriction period expires.
A premature transfer can create consequences for the citizenship process and should be legally reviewed before any transaction is attempted.
The investor’s desire to avoid further financial loss does not automatically override the citizenship commitment.
The precise starting point should be determined from the transaction and registered commitment rather than guessed from the date the investor first paid a reservation deposit.
For citizenship acquisitions based on completed property purchases, the relevant registered commitment and acquisition documentation should be reviewed.
For qualifying promise-of-sale structures, the rules operate differently because the commitment relates to the annotated agreement and its cancellation or transfer.
Foreign investors should therefore calculate the three-year restriction from the legally relevant records rather than from informal milestones such as signing a reservation form.
Yes, in qualifying purchase transactions the citizenship framework can allow multiple properties to contribute toward the required investment amount.
Current Land Registry guidance confirms that there is no general numerical limit on the number of properties used under the qualifying purchase route, provided the applicable value requirements are satisfied. (Tapu ve Kadastro Genel Müdürlüğü)
However, the rules for promise-of-sale transactions differ. The Land Registry states that where citizenship eligibility is based on a promise of sale, the required amount must be satisfied under a single qualifying agreement, although more than one property may be included within that agreement. (Tapu ve Kadastro Genel Müdürlüğü)
This distinction should be considered before structuring the acquisition.
Where multiple properties were properly used to satisfy the citizenship investment requirement, a later market decline affecting one of them does not automatically mean that the original qualifying investment disappears.
Again, the important distinction is between subsequent market performance and original eligibility.
However, all qualifying properties subject to the relevant commitment should be handled consistently with the citizenship restrictions.
An investor should not assume that one property can be sold early merely because the remaining properties have subsequently increased in value.
Any proposed disposal during the restricted period should be legally reviewed.
A mortgage can significantly affect citizenship investment calculations.
Foreign buyers should not assume that a property with a headline price above USD 400,000 necessarily produces the same qualifying investment amount where financing or encumbrances affect the transaction.
The citizenship-specific investment determination must be examined carefully.
This issue should be investigated before purchasing the property, not after the investor discovers that the qualifying amount may be insufficient.
Property can lose value for reasons other than ordinary market fluctuations.
An earthquake, fire, structural problem or serious construction defect may materially reduce its market value.
From the citizenship perspective, the key distinction remains whether the investment originally satisfied the applicable conditions and whether the investor continues to comply with the required commitment.
However, the investor may separately have insurance, contractual, developer or tort claims arising from the physical damage.
The citizenship analysis and compensation analysis are therefore separate legal questions.
This is considerably more serious than ordinary market depreciation.
A foreign investor may be told:
“This apartment is worth USD 450,000 and is guaranteed to qualify for citizenship.”
If the transaction later fails because the property does not satisfy the official citizenship investment determination, the investor should immediately investigate the developer’s and intermediary’s representations.
The sales contract, advertisements, messages, payment records, valuation documentation and any written citizenship guarantees should be preserved.
Depending on the circumstances, potential remedies may include repayment, contractual claims, compensation or other proceedings.
Foreign investors should be cautious about statements such as “100% guaranteed citizenship.”
A property agent can market property, but citizenship eligibility depends on compliance with the applicable legal and administrative framework.
The Land Registry procedure is only one stage. After the required property commitment is established, the transaction information is transmitted through the competent process, and citizenship-related residence and nationality procedures follow. (Tapu ve Kadastro Genel Müdürlüğü)
A buyer should therefore obtain independent legal review rather than relying solely on the seller, developer or agent whose commercial objective is completing the sale.
As of the current 2026 Land Registry guidance, the applicable threshold for property acquired under the modern citizenship-by-investment framework remains USD 400,000. (Tapu ve Kadastro Genel Müdürlüğü)
Foreign investors should be cautious with older online material referring to USD 250,000. That was a previous threshold and should not be relied upon for a new 2026 acquisition.
The current documentation framework also reflects the Investment Amount Determination Certificate system introduced in December 2024 and used for citizenship-related property transactions. (Tapu ve Kadastro Genel Müdürlüğü)
A further current issue concerns financing.
The Land Registry’s foreign affairs portal records a January 22, 2026 instruction concerning restrictions on foreign purchasers acquiring real estate using loans provided by savings-finance companies. (Tapu ve Kadastro Genel Müdürlüğü)
Foreign investors planning to finance a citizenship property purchase should therefore have the proposed financing structure reviewed before signing or transferring funds.
A transaction that meets the headline purchase-price figure can still encounter problems if the payment or financing structure does not comply with current rules.
No.
Meeting the property investment requirement is an essential component of the exceptional citizenship route, but investors should not describe citizenship as automatically guaranteed by purchasing qualifying real estate.
The property transaction and investment determination establish the relevant investment basis. The subsequent citizenship application remains subject to the applicable nationality procedures and official review.
Accordingly, contracts stating that a private developer “guarantees Turkish citizenship” should be treated cautiously.
First, determine whether this is simply a current market-value decline or whether it reveals a problem with the original transaction.
The investor should review the title deed, registered three-year commitment, Investment Amount Determination Certificate, payment receipts, banking documentation and citizenship application status.
If the original qualifying investment was properly established and the property has merely depreciated because of normal market conditions, the decline should not automatically be treated as destroying the original citizenship qualification.
If, however, the new information suggests that the original valuation was inaccurate, the payment was structured improperly or the qualifying amount was never actually satisfied, immediate legal review is advisable.
Not merely because of an ordinary subsequent market-value decline. The critical issue is whether the qualifying investment requirements were properly satisfied at the relevant transaction stage and whether the investor continues to comply with the required holding commitment.
The three-year rule is fundamentally a non-disposal commitment. It should not be confused with a requirement that the property’s fluctuating open-market value must continuously remain above USD 400,000. (Tapu ve Kadastro Genel Müdürlüğü)
For qualifying acquisitions under the current framework, the required amount remains USD 400,000 or its equivalent. (Tapu ve Kadastro Genel Müdürlüğü)
That can create a substantially more serious issue. The current framework uses the Investment Amount Determination Certificate to verify the amount acceptable for citizenship purposes. (Tapu ve Kadastro Genel Müdürlüğü)
For the current post-December 9, 2024 framework, the relevant Investment Amount Determination Certificate has a six-month transaction-related validity period under the applicable guidance. (Tapu ve Kadastro Genel Müdürlüğü)
Ordinary exchange-rate movements after a properly qualifying acquisition do not automatically rewrite the original investment amount. However, the correct USD-equivalent calculations and payment documentation are critical when the qualifying transaction is completed.
Selling during the mandatory three-year restricted period can create serious citizenship consequences. Do not dispose of a qualifying property during the restriction period without first obtaining legal advice concerning the citizenship implications.
Potentially, yes, for qualifying purchases. Current Land Registry guidance confirms that multiple properties may be used where the applicable combined investment requirements are satisfied. Different rules apply to promise-of-sale transactions. (Tapu ve Kadastro Genel Müdürlüğü)
Preserve the contract, advertisements, messages, payment records and valuation documentation immediately. Depending on the circumstances, contractual termination, repayment or compensation claims may need to be considered.
Independent legal due diligence can be particularly important because the seller, developer and real estate agent have a financial interest in completing the transaction. A legal review should cover title status, citizenship eligibility, payment documentation, investment determination and the required three-year commitment.
A decline in the market value of property purchased for Turkish citizenship does not necessarily mean that the citizenship investment has become invalid. The critical questions are whether the transaction originally satisfied the applicable USD 400,000 investment requirements, whether the required documentation was properly issued and whether the investor continues to comply with the three-year holding commitment.
Fırat Fesih Kaya Law Office provides legal assistance to foreign investors concerning Turkish citizenship by real estate investment, property due diligence, investment eligibility, valuation issues, Investment Amount Determination Certificates, title deed procedures, payment documentation, developer disputes and citizenship-related property risks.
If your citizenship property has lost value, an official valuation has raised concerns, or you believe a developer or real estate intermediary misrepresented the property’s citizenship eligibility, you may contact our office for a case-specific legal assessment. Fırat Fesih Kaya can review the title deed, investment documentation, payment records, registered commitment and application status and determine whether the change in value creates a genuine legal risk.
Early legal review is especially important where the issue is not merely market depreciation but a potential defect in the original valuation, purchase-price documentation or citizenship investment structure.
Phone: +90 312 434 22 22
Mobile Phone: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No: 221, Yildirim Tower No: 148, 06520 Balgat, Cankaya, Ankara, Turkey