Is It Possible to Remove the 3-Year Not-to-Sell Annotation for Turkish Citizenship by Investment Before 3 Years?

Foreign investors in Türkiye often ask whether it is possible to cancel the 3-year “not-to-sell” annotation on their property before the mandatory period expires when applying for Turkish Citizenship by Investment (CBI).

This annotation, required under the Turkish Citizenship Law and its implementing regulations, plays a central role in safeguarding the integrity of the investment program.

In this article, we explain the legal framework, new regulations, and the only possible exemption available.

Why Is There a 3-Year Not-to-Sell Requirement?

When Türkiye reduced the property investment threshold from 1,000,000 USD to 400,000 USD in 2018, the government introduced the rule that the purchased property must not be sold for 3 years. To ensure compliance, a “satılamaz şerhi” (not-to-sell annotation) is placed on the property deed.

This ensures that investments serve their intended purpose of strengthening the Turkish economy rather than being used for short-term speculation.

Can You Remove the Annotation Before 3 Years?

The general rule is clear: if you have already applied for Turkish citizenship using the property, you cannot remove the annotation before 3 years.

The Ministry of Environment, Urbanization, and Climate Change and the General Directorate of Land Registry and Cadastre strictly enforce this requirement. Even if the investor decides not to continue with the application after submission, the annotation remains until the 3-year term ends.

The Only Possible Exemption

The only exception is if you have not yet applied for Turkish citizenship.
If you purchased a property with the intention of applying but did not file your application, you may request the removal of the annotation through the Land Registry Office. Once removed, you are free to sell the property.

However, if you applied for citizenship and received the Certificate of Eligibility (Uygunluk Belgesi), the annotation is binding for the full 3 years.

Key Regulations and Updates

Recent amendments to the Citizenship by Investment program introduced further restrictions:

1. Foreign-to-foreign property sales:
   Properties cannot be counted towards CBI if they were previously owned by another foreigner of the same nationalityafter 12.01.2017.
   However, if the property was transferred to a Turkish citizen or a Turkish company first, it can then qualify when sold to a new foreign investor.

2. Properties purchased by companies:
   If a company is partly owned or managed by the foreign investor, their spouse, or children, its property cannot qualify for CBI. The law now also excludes companies where other foreigners of the same nationality are shareholders.

3. Re-use of property for CBI after 3 years:
   Even after the 3-year annotation period expires, a property that has already been used once for a CBI application cannot be used againfor another foreigner’s citizenship application.
   The only exception is if the property is sold back to the original construction company or a Turkish citizen after the 3-year period. In that case, the property may re-qualify for future applications.

4. Currency conversion rule:
   Since 2022, foreign investors must sell the purchase amount in USD, EUR, or GBP to a Turkish bank, which then sells it to the Central Bank. The Döviz Alım Belgesi(Foreign Exchange Purchase Certificate) must be submitted to the Land Registry before the transfer. Payments made in cash or via exchange offices are not accepted.

5. No early withdrawal for deposit-based citizenship:
   For bank deposit, treasury bonds, or investment fund options, the USD 500,000 investment must remain blocked for 3 years. Partial withdrawals reducing the balance below the threshold lead to disqualification.

Practical Example

Let’s assume a foreign investor purchased an apartment in Istanbul in January 2023 for USD 400,000 with the 3-year not-to-sell annotation.

• If they did not yet apply for citizenship, they may request the annotation’s removal and sell the property.

• If they submitted the citizenship application, they must wait until January 2026 to sell, even if they no longer wish to pursue Turkish citizenship.

Also Read; Certificate of eligibility for Turkish Citizenship by investment

Frequently Asked Questions

Can I sell my property after 2 years if I change my mind?
Not if you already applied for citizenship. The annotation is binding for the entire 3 years.

What if I withdraw my application?
Once the application is filed, the 3-year commitment remains valid even if you later withdraw.

Can multiple properties be combined for the USD 400,000 threshold?
Yes. More than one property can be purchased, provided they collectively meet the value requirement and all are annotated with the 3-year not-to-sell clause.

What about inherited or gifted properties?
Only properties purchased (not inherited or gifted) are eligible for CBI.

Can I collect rent from the property during the 3 years?
Yes. You retain all ownership rights, including rental income, as long as you do not sell or transfer the property.

Conclusion

To summarize:

• If you already applied for Turkish citizenship by investment, you cannot remove the 3-year not-to-sell annotation before the period ends.

• The only exemption applies if you purchased the property but did not yet apply for citizenship.

• Recent legal updates have further tightened restrictions to prevent misuse of the program.

At Bayraktar Attorneys, we assist foreign investors in Türkiye through every step of the Turkish Citizenship by Investment program. From property acquisition and compliance checks to citizenship applications and annotation removal guidance, our team ensures you remain fully protected.