Foreign Owner Uses a Property Management Company for Holiday Rentals in Turkey: Who Is Responsible for Violations? (2026 Updated Guide)

A foreign property owner uses a management company for short-term holiday rentals in Turkey. Learn who may be responsible for permit, advertising, guest, building and administrative violations.

A foreign property owner may purchase an apartment or villa in Turkey and appoint a local property management company to handle holiday rentals, guest communications, cleaning, advertising, payments and check-in procedures. This arrangement can make the investment easier to manage from abroad, but it does not automatically transfer every legal responsibility from the owner to the management company. If the property is offered for short-term tourism rentals without satisfying applicable requirements, authorities may examine the role of the property owner, permit holder, management company, intermediary and other persons actually involved in the rental activity. For this reason, foreign owners should not assume that signing a management agreement completely protects them from administrative penalties or other legal consequences.

Why Holiday Rental Compliance Matters for Foreign Property Owners

Short-term accommodation is different from an ordinary long-term residential lease. A property advertised to tourists for short stays may fall within a specific tourism-rental regulatory framework and may require authorization before it is marketed or rented.

The owner should therefore determine the legal status of the property before allowing a management company to advertise it.

Does Hiring a Property Management Company Transfer All Liability?

No. A private contract between an owner and management company determines contractual responsibilities between those parties, but it does not necessarily prevent public authorities from applying statutory obligations to the person whom the legislation treats as responsible.

The first question in any violation case is therefore: who had the legal obligation that was allegedly breached?

The Owner’s Role Must Be Examined Separately

Ownership can remain important even where another company manages daily operations. Authorities may examine who owns the property, who obtained or should have obtained the relevant authorization, who permitted the property to be rented and who receives the economic benefit.

A foreign owner living abroad should not assume that physical absence eliminates regulatory exposure.

The Management Company’s Role Also Matters

The management company’s liability depends on what it actually does.

A company that merely cleans the property performs a different role from a business that creates listings, determines prices, accepts reservations, receives guest payments, manages check-in and operates the property on the owner’s behalf.

The contract and actual conduct should therefore be examined together.

Tourism Rental Permit Requirements Should Be Checked First

Before a property is offered for qualifying short-term tourism rentals, the owner and manager should determine whether a tourism-purpose rental permit is required and whether the property satisfies the conditions for obtaining and maintaining it.

Operating first and attempting to regularize the property only after an inspection can expose the parties to significant risk.

A Management Contract Is Not a Substitute for a Permit

One of the most important mistakes is believing that an agreement with a professional rental company makes the activity lawful automatically.

A management company cannot replace a regulatory authorization required for the property itself.

Who Applied for the Permit?

Determine whose name appears on the relevant permit and whether the actual rental operation corresponds with that authorization.

If the management company advertises or operates the property in a manner inconsistent with the permit, responsibility should be assessed according to both the legislation and the parties’ contractual arrangements.

Advertising Can Create Evidence of the Rental Activity

Online listings can become important evidence in an administrative investigation.

Authorities may examine property photographs, nightly prices, availability calendars, guest reviews, host information, booking records and descriptions showing how the property was marketed.

Owners should therefore monitor advertisements created by management companies.

Do Not Give the Manager Unlimited Advertising Authority

The management agreement should specify which platforms may be used, how the property may be described and who is responsible for ensuring that advertisements contain legally required information.

The owner should also retain access to listings or receive regular copies.

What If the Management Company Advertises Without the Owner’s Knowledge?

This can create a factual and contractual dispute. The owner should preserve the management agreement, instructions, correspondence and evidence showing the limits of the manager’s authority.

However, lack of knowledge should not automatically be assumed to eliminate every public-law consequence. The applicable obligation and facts must still be examined.

Guest Registration Obligations Can Create Separate Risks

Short-term accommodation may involve guest identification and notification requirements in addition to tourism-rental rules.

The management agreement should identify who performs guest registration, how identification information is obtained and how compliance records are preserved.

Foreign Guests Do Not Eliminate Compliance Requirements

The fact that most guests are tourists or foreign nationals does not make the property exempt from Turkish regulatory requirements.

International booking platforms also do not replace local compliance obligations.

Building Rules Can Affect Holiday Rentals

Apartment buildings and residential complexes may create additional legal issues. Depending on the property and applicable framework, building-related approvals, condominium rules or restrictions may affect whether tourism rentals can lawfully operate.

Foreign buyers should investigate these matters before purchasing a property specifically for short-term rental income.

Villas and Apartments May Present Different Issues

A detached property and an apartment in a multi-unit building may face different practical compliance questions.

The legal analysis should therefore focus on the actual property rather than relying on generic advice received from a real estate agent.

Who Is Responsible If the Permit Was Never Obtained?

Responsibility depends on the statutory framework and the person’s role in the activity. The owner should not automatically assume that the management company bears the entire penalty merely because it handled bookings.

Likewise, the management company should not automatically be assumed responsible for obligations legally imposed on the property owner.

Who Is Responsible for Misleading Advertisements?

If a management company publishes inaccurate information, uses an incorrect permit number or advertises facilities that do not exist, contractual liability toward the owner may arise.

Depending on the nature of the conduct, regulatory or consumer-law consequences may also require separate examination.

Who Is Responsible for Unauthorized Subletting?

A particularly important scenario arises where the owner grants a conventional lease or management authority but the other party subsequently uses the property for unauthorized short-term accommodation.

The contract, actual authority granted, payment structure and owner’s knowledge become important evidence.

The Contract Should Prohibit Unauthorized Rental Models

The management agreement should state clearly whether the manager can sublet, accept reservations in its own name, appoint subcontractors or use third-party platforms.

Ambiguous authority creates unnecessary disputes.

Power of Attorney Should Be Limited Carefully

Foreign owners frequently issue powers of attorney because they live outside Turkey. The document should be reviewed carefully before signing.

Authority to manage a property does not need to become unlimited authority to enter every possible contract, collect unrestricted funds or alter the commercial use of the property.

Who Receives Guest Payments?

Payment flows can reveal how the business actually operates.

Determine whether guests pay the owner, management company, booking platform or another intermediary. Bank statements and platform settlement records should be retained.

Tax Obligations Must Be Considered Separately

Compliance with tourism-rental rules does not automatically resolve tax questions.

The owner should separately determine the tax treatment of rental income, invoicing or other obligations according to the actual commercial structure.

A Foreign Owner’s Tax Position Requires Individual Review

Residence status, ownership structure and the manner in which income is generated can affect the analysis.

Foreign owners should avoid relying on generic statements that platform income is automatically tax-free or that the management company handles every tax obligation.

What If the Management Company Collects the Income?

The agreement should explain whether the company collects funds as agent, deducts commission and transfers the balance, or operates under another contractual model.

Statements, invoices and payment records should correspond with the written agreement.

Administrative Penalties Should Be Examined Individually

If authorities impose a penalty, obtain the complete written decision. Identify the alleged violation, legal basis, responsible person, amount, inspection evidence and notification date.

Do not pay or challenge a penalty based only on an oral explanation from the management company.

Notification Date Can Be Critical

Administrative remedies are generally subject to procedural periods. The owner should preserve the envelope, electronic notification information or other evidence establishing when the decision was formally notified.

Can a Foreign Owner Challenge a Holiday Rental Penalty?

Potentially, yes. The appropriate remedy depends on the type of administrative decision, legal basis and competent authority.

Potential arguments may concern incorrect identification of the responsible party, factual errors, lack of evidence, compliance with permit requirements or other procedural and substantive issues.

Can the Owner Blame the Management Company?

The relationship between public-law liability and contractual liability must be separated.

Even if the authority lawfully imposes a penalty on the owner, the owner may potentially have a contractual claim against the management company if the penalty resulted from the manager’s breach of its contractual obligations.

Indemnification Clauses Are Important

A professionally drafted management agreement should address responsibility for regulatory violations, unauthorized advertising, guest-registration failures, permit-related breaches and penalties attributable to the manager’s conduct.

The clause should also establish notification and cooperation obligations.

An Indemnity Does Not Bind Public Authorities

A contract stating that the management company will pay all penalties does not necessarily prevent an authority from issuing a decision against a person legally responsible under the applicable legislation.

The indemnity primarily regulates financial responsibility between the contracting parties.

Evidence Should Be Preserved Immediately

When a violation is alleged, preserve the management agreement, power of attorney, permit, platform listings, reservation records, guest communications, invoices, bank transfers, inspection documents and correspondence with the management company.

Do not delete listings simply because an investigation has started. Preserve them first.

Screenshots Can Be Important

Take dated screenshots of advertisements and account information showing who controlled the listing and what information appeared at the relevant time.

Platform account records may later change.

Request Records From the Management Company

The owner should request booking histories, guest records, payment statements, invoices, advertising records and communications relating to the disputed period.

If litigation is likely, evidence preservation becomes especially important.

What If the Management Company Refuses to Provide Records?

Review the contractual access and accounting obligations and send a formal request where appropriate.

The owner may need the records both to defend an administrative case and to calculate a contractual claim against the manager.

Terminating the Management Agreement Does Not Automatically End the Problem

Termination can stop future activity but does not necessarily eliminate consequences arising from previous rentals.

Historical bookings and advertisements should therefore be reviewed.

Review Future Reservations Before Termination

If the management relationship ends, determine what happens to already confirmed reservations, deposits and guest payments.

Poorly managed termination can create additional consumer and contractual disputes.

Foreign Owners Should Conduct Periodic Compliance Audits

Owners living abroad should not operate entirely on trust. Request periodic copies of permits, listings, booking statements, guest-compliance records and payment reports.

A simple quarterly compliance review can reveal unauthorized activity before it develops into a larger dispute.

Purchasing a Property for Airbnb-Style Rentals Requires Due Diligence

Foreign investors should verify the regulatory feasibility of the intended rental model before purchasing.

A statement from a seller or real estate agent that “short-term rental is allowed” should not substitute for legal due diligence concerning the specific property.

Sale of the Property Does Not Automatically Resolve Historical Violations

If an owner sells a property after operating holiday rentals, historical administrative or contractual issues may remain relevant.

Transaction documents should address pending penalties, guest claims, management contracts and booking obligations.

2026 Risk Management for Foreign Owners

The safest structure is one in which the regulatory status of the property is confirmed before advertising begins, the management company’s authority is precisely defined, compliance duties are allocated in writing, the owner has access to booking and financial records and periodic audits are conducted.

Foreign owners should treat holiday-rental management as a regulated investment activity rather than a completely passive real estate arrangement.

Frequently Asked Questions

Does hiring a property management company remove the foreign owner’s liability?

Not automatically. Public-law responsibility depends on the applicable legal obligation and the person’s role. The management contract can separately allocate contractual responsibility between the parties.

Can a management company obtain bookings on behalf of the owner?

Potentially, but the structure must comply with applicable tourism-rental and other regulatory requirements.

Who is responsible if the property is advertised without the required permit?

The answer depends on the applicable statutory obligations and actual conduct. The owner, permit holder, manager or another participant may need to be examined separately.

Can the owner recover an administrative penalty from the management company?

Potentially, if the contract and facts establish that the penalty resulted from the management company’s breach and contractual recovery requirements are satisfied.

Is an online platform listing evidence?

It can be significant evidence of how, when and by whom a property was offered for short-term accommodation.

What if the manager exceeded the power of attorney?

The scope of authority, communications and actual conduct should be examined. Exceeding authority can create contractual and potentially other legal consequences.

Should the owner monitor guest payments?

Yes. Payment records help establish rental income, management commissions and how the operation was actually structured.

Can a foreign owner challenge an administrative penalty?

Potentially. The written decision, notification date, legal basis and evidence should be reviewed immediately to determine the appropriate remedy.

Should the owner terminate the management agreement after a violation?

Termination may be appropriate in some cases, but existing bookings, evidence, payments and contractual consequences should be reviewed before taking action.

What should a foreign owner do first after learning of a violation?

Obtain the official decision or inspection record, preserve all booking and management evidence, identify who had the legal obligation allegedly breached and separately determine whether the management company has contractual liability toward the owner.

Client-Focused Legal Support for Foreign Property Owners

Foreign property owners using professional management companies can face disputes involving tourism rental permits, unauthorized advertisements, administrative penalties, guest records, management agreements, powers of attorney, rental income and contractual liability. Fırat Fesih Kaya Law Office assists foreign property owners and investors in evaluating regulatory violations, challenging administrative decisions where appropriate, reviewing management-company responsibility and resolving disputes arising from short-term rental operations.

Lawyer Fırat Fesih Kaya provides legal assistance to foreign owners concerning property management agreements, tourism rental compliance, administrative proceedings and claims against property managers.

Phone: +90 312 434 22 22

Mobile / WhatsApp: +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