CANCELLATION AND REVOCATION OF TURKISH CITIZENSHIP BY INVESTMENT 2026: LEGAL PROCESS AND LITIGATION ROUTES
Processes related to the acquisition of Turkish citizenship through real estate investment have recently become the subject of comprehensive administrative and judicial investigations, particularly regarding real estate valuation reports and allegations of collusive sales.
In the statement made by the Republic of Turkey Ministry of Interior on September 21, 2026, it was announced to the public that, as a result of investigations into fake or irregular valuation reports, the investment eligibility certificates and the subsequent citizenship decisions of numerous investors have been canceled; furthermore, criminal investigations are ongoing regarding transactions where irregular citizenship was allegedly granted through collusive real estate sales.
These developments have once again brought to the agenda the question of under what conditions the legal status of individuals who acquired Turkish citizenship by investment can be subject to cancellation or revocation proceedings.
However, the fact that a transaction was carried out through the same project, seller, valuation firm, or intermediary structure does not mean that all relevant investors are legally in the exact same position. Every administrative action regarding citizenship status must be evaluated individually, within the framework of the concrete situation of the relevant person and the material and legal conditions present at the time the citizenship was acquired.
2026 Turkish Citizenship Cancellation Investigation: The Legal Status of Investors in Babacan Group, Gül İnşaat, Beyaz İnşaat, and LİV İnşaat
The names Babacan Group (Babacan İnşaat), Gül İnşaat, Beyaz İnşaat, and LİV İnşaat have come to the fore in the Turkish citizenship by investment investigations reflected in the press in August and September 2026.
For foreign investors who acquired Turkish citizenship through real estate investment, these developments have brought along legal questions regarding the possibility of their citizenship being canceled or revoked.
However, the mention of a company’s name in investigation news does not mean that the citizenship of all investors who purchased real estate from that company has been canceled or that they have engaged in unlawful transactions.
The legal status of investors who acquired Turkish citizenship by purchasing real estate from the projects of Babacan Group, Gül İnşaat, Beyaz İnşaat, or LİV İnşaat must be evaluated individually within the circumstances of each file.
In this evaluation, the actual value of the real estate at the date of purchase, whether the investment amount was actually paid, bank transfers, valuation reports, and the investor’s connection to possible irregularities are of particular importance.
In legal examinations regarding the cancellation or revocation of citizenship, general investigation findings and the individual legal status of the investor must be separated from each other.
The Legal Distinction Between Cancellation and Revocation of Citizenship
The Turkish Citizenship Law No. 5901 attributes the subsequent annulment of decisions regarding the acquisition of citizenship to different legal grounds.
Pursuant to Article 31 of the Law, the decision to acquire Turkish citizenship may be canceled if it was made as a result of the person’s false declaration or concealment of important matters constituting the basis for acquiring citizenship.
In terms of this regulation, not only the presence of an unlawful element in the application file is important, but also the relationship of the said element with the investor’s declaration, knowledge, or behavior.
Article 40 of the Law, on the other hand, regulates the revocation of a decision regarding the acquisition or loss of citizenship if it is later understood that the decision was made without the legal conditions being met or was issued redundantly.
Therefore, the concepts of “cancellation” and “revocation” differ from each other not only terminologically but also in terms of the legal grounds they are based on and their judicial review.
Irregularities in the Valuation Report and the Investor’s Legal Status Must Be Separated
In the citizenship by real estate investment system, valuation reports play an important role in determining whether the investment condition has been fulfilled.
However, if an error, forgery, or irregularity is subsequently detected in a valuation report, the legal status of the valuation report and the personal legal status of the investor should not be considered the same.
In particular;
- the actual market value of the real estate at the date of purchase meeting the investment amount required for citizenship,
- the sales price having been genuinely paid,
- money transfers reflecting a genuine economic transaction,
- the sales price not having been returned to the investor,
- the investor not having interfered with the preparation or content of the valuation report,
- the investor not having participated in any collusive or fake transaction
such matters are of great importance in evaluating the legal status of the relevant investor.
For this reason, in such files, not only “whether the valuation report is irregular” but also whether the investor fulfilled the actual investment conditions stipulated in the legislation at the date citizenship was acquired must be examined.
The Existence of a Genuine Investment is a Crucial Point of Distinction
In practice, two completely different legal situations must be distinguished.
In the first situation, even though the actual value of the real estate is below the investment amount required for citizenship, there may be allegations that the investment condition was formally created through a false valuation, fake money movements, or collusive transactions.
In the second situation, the investor may have purchased a real estate property that genuinely covers the required amount for citizenship, genuinely paid the sales price, and been completely unaware of a possible irregularity in the valuation process.
It is not possible to evaluate the legal consequences of these two situations in the same way.
Although the fact that the actual value of the real estate meets the investment amount required for citizenship does not alone yield an automatic result that eliminates all legal problems, it is one of the fundamental elements in evaluating whether the material conditions for acquiring citizenship truly exist.
Similarly, the investor merely claiming good faith is not sufficient on its own. What is important is that the economic reality of the investment and the investor’s legal and factual position within the concrete event are presented together.
The Reason for the Administrative Action Must Be Individual and Concrete
Investigations into fake valuations or organized real estate sales can encompass a large number of investors over the same project, seller, valuation firm, or intermediary structure.
However, the addressee of the cancellation or revocation of citizenship action is the individual investor.
Therefore, it is important that the administrative action is based on a concrete and legally verifiable reason that can be associated with the relevant investor’s own actions and behaviors.
The decisions of the 10th Chamber of the Council of State regarding the revocation of citizenship also emphasize the necessity of presenting the facts relied upon by the administration in a concrete, objective, and legally verifiable manner.
Furthermore, in the assessment of whether the legal conditions are met, it is generally accepted that the material and legal conditions existing on the date the citizenship was acquired should be taken as the basis.
This approach shows that general investigations emerging later and the individual legal status of the investor at the time they acquired citizenship must be separated from each other, especially.
Criminal Investigation and the Citizenship Process Are Subject to Different Legal Regimes
Another dimension of the current examinations regarding valuation reports and real estate sales is criminal investigations.
It is possible that investigations are carried out against valuation companies, sellers, intermediaries, or other individuals on allegations of forgery, fraud, or collusive transactions.
However, the mere fact that an investor has purchased a real estate property subject to an investigation does not mean that they bear criminal liability.
Criminal liability is personal, and the investor’s knowledge, intent, contribution, and role in the event must be evaluated separately.
Likewise, the existence of a criminal investigation and the legal criteria of the administrative process regarding citizenship status are different from each other.
However, since both processes may stem from the same material facts, it is important that the investor’s legal position in both administrative and criminal processes is evaluated in harmony with each other.
Every Investor File Must Be Examined Within Its Own Material Reality
The Ministry of Interior statement dated September 21, 2026, reveals that a comprehensive administrative and judicial examination process is ongoing in the field of citizenship by investment.
However, in this process, general investigation findings must be separated from the legal statuses of individual investors.
Especially;
- the investment having genuinely been made,
- the actual value of the real estate meeting the required amount for citizenship,
- the investment amount having been actually paid,
- the investor not having participated in any collusive or fake transaction,
- no knowingly false or misleading declarations having been made to the citizenship authorities
in such cases, the legal status of the relevant investor must be examined separately and individually.
Cancellation of Turkish Citizenship by Investment: Legal File Review
If you have received a notification regarding the cancellation of your Turkish citizenship or if you want to learn the legal status of your investment file, you can apply to the Nexpo Legal Immigration and Citizenship Law Department. Each file is examined separately within the framework of available documents and personal legal conditions.
In this evaluation, not only the valuation report should be considered; the actual economic value of the real estate, the payment process, the economic reality of the investment, the conditions at the date citizenship was acquired, and the concrete legal reason on which the administrative action is based for the investor must all be looked at together.
As Nexpo Legal, we approach disputes related to Turkish citizenship by investment with a holistic legal perspective that considers the dimensions of citizenship law, administrative law, real estate law, valuation processes, and, when necessary, criminal law together.
Our fundamental approach in such disputes is to separately evaluate under what material and legal conditions each investor acquired citizenship, the reality of the investment, and whether there is any illegality that can be individually attributed to the investor, independent of general investigation findings.
This work has been prepared for general legal information purposes. Each concrete case must be evaluated separately by taking into account the date citizenship was acquired, the nature of the investment, the actual value of the real estate, the payment process, the relevant administrative action, and the scope of the criminal investigation, if any.
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