The Approval of the Republic of Turkey Ministry of Environment, Urbanization and Climate Change, dated 18.09.2026 and numbered 36189470-125.01.01/21900458, has introduced a significant change regarding the valuation reports used in citizenship applications based on real estate acquisition carried out under the Regulation on the Implementation of the Turkish Citizenship Law. With the aforementioned regulation, it has been made possible for the valuation reports to be used in citizenship applications to be issued by any valuation company authorized by the Capital Markets Board (SPK). The regulation has been incorporated into Circular No. 2024/2, thereby ending the obligation to proceed through GEDAŞ, which was previously the sole institution encountered in practice during the valuation process.
Freedom in Choosing a Valuation Company
With the new regulation, it has become possible for the applicant to make a choice among valuation companies that meet the conditions stipulated in the legislation. As a matter of fact, in accordance with the Circular, valuation report applications are carried out via Web Tapu, as in the previous system, and any valuation company can be selected through a preferential or automatic algorithm in line with the purpose of the request.
Required Conditions: SPK Authorization and TADEBİS Registration
An important point to note here is that the introduced freedom does not mean the opportunity to work with every valuation company in the market. The valuation company must be authorized by the Capital Markets Board, have an active membership in the Turkish Appraisers Association (TDUB), and be integrated into the TADEBİS system. Therefore, when selecting a valuation company for citizenship files, it will not be sufficient for it to merely be a commercially operating company; whether the relevant institution meets the technical and administrative requirements sought in the legislation will also be checked separately.
Advantage in Process Management and Coordination
For Nexpo Legal, the most important outcome of the new practice is that it allows the valuation process to be managed more effectively within the general processing schedule of the file. Particularly in the process consisting of interconnected stages such as the purchase of the real estate, completion of payment transactions, preparation of the valuation report, execution of title deed transactions, and subsequently making the citizenship application, the ability to choose a suitable valuation company will provide advantages in practice in terms of time and coordination. However, the expansion of the opportunity to choose a company does not mean that the technical standards to which valuation reports are subject have changed. Valuation reports must still be prepared in accordance with international valuation standards, TDUB regulations, and the procedures and principles determined by the General Directorate of Land Registry and Cadastre (TKGM).
The Value to be Based On: Market Value and Standards
A fundamental issue that needs to be emphasized regarding citizenship applications is the market value based on in the valuation report. In the Circular, market value is defined as the estimated value in a sales transaction expected to take place between an informed and willing buyer and seller under appropriate market conditions as of the valuation date; and it is explicitly stated that the value to be based on in Land Registry and Cadastre transactions is the Market Value. The Market Value Based on Legal Use, on the other hand, is also shown separately in the report but serves the purpose of informing the relevant parties.
In this context, while the introduction of the opportunity to choose a valuation company provides greater flexibility in the preparation of the valuation report in citizenship files, it does not eliminate the sensitivity regarding the compliance of the report’s content and valuation with the legislation. Valuation companies must compare the legal and actual status of the real estate, reveal the differences between the current situation and the architectural project when necessary, and report in a way that reflects the true condition of the real estate. Furthermore, it is also stipulated that valuation reports must include photographs that clearly demonstrate aspects such as the condition and construction level of the real estate.
Validity Period of Valuation Reports
In accordance with the Circular, the validity period of valuation reports to be used in title deed transactions has been set as 12 months. However, if title deed registry changes that could affect the value of the real estate occur after the report is issued, it may be necessary to obtain a new valuation report even if the 12-month period has not yet expired. For this reason, merely obtaining the report is not sufficient for citizenship files; it is also crucial to monitor the legal and actual status of the real estate during the period between the report and the title deed transaction.
Conclusion and Evaluation
In conclusion, the regulation introduced by the Ministry Approval dated 18.09.2026 constitutes a significant change in terms of making the valuation process more flexible and customizable in Turkish citizenship applications based on real estate acquisition. In particular, allowing choices to be made among SPK-licensed valuation companies that meet the conditions specified in the legislation, replacing the valuation process previously conducted through a single institution in practice, will enable law firms working in the field of citizenship to act more effectively in file management.
However, the new system does not imply that any standardization in the valuation process has been abandoned. On the contrary, while the selection of the valuation company has been liberalized, the obligations regarding the technical content of the valuation report, the accurate presentation of the true and legal status of the real estate, the determination of the market value in accordance with the legislation, and the proper finalization of the report through TKGM systems remain exactly the same. Therefore, for the sound execution of citizenship files in the new era, it is important not only to select an appropriate valuation company but also for the report issued by the chosen company to be carefully reviewed by the law firm alongside the general conditions of the file.
In summary, significant freedom has been introduced in choosing a valuation company with the new regulation; however, the conditions of legislative compliance and technical supervision have been preserved regarding the determination of the real estate value, which forms the basis of citizenship applications. In this respect, the regulation can be considered the beginning of a new implementation era that allows the valuation stage to be managed more effectively in the citizenship practice for both applicants and law firms conducting the process professionally.
