New Amendments to the Real Estate Valuation System in Turkey

On September 28, 2026, the General Directorate of Land Registry and Cadastre (TKGM) updated Circular No. 2024/2 regulating real estate valuation reports, based on the approval of the Ministry of Environment, Urbanization and Climate Change issued on September 18, 2026. Under this update, valuation reports for Turkish citizenship files are no longer restricted to GEDAŞ, and the validity of the report has become 12 months.

This article explains what officially changed compared to the previous system, the background of the decision, and circulating information that has not yet been confirmed by official texts. It also outlines the new technical conditions for the report, and the impact of these amendments on investors purchasing property with the aim of obtaining citizenship.

What Changed? A Comparison Between the Previous and New Systems

Item	Before Amendment	After September 2026 Amendment
Entity preparing the citizenship report	GEDAŞ alone	Any valuation company licensed by the Capital Markets Board (SPK), with active membership in the Turkish Appraisers Association (TDUB), and registered in the TADEBİS system
Selecting the valuation company	Handled by the system	Selected by the applicant through direct choice or automated distribution
Validity of the Amount Determination Document (TTB)	6 months	12 months
Responsibility for report accuracy	—	Rests on the valuation company and signing experts; TKGM's role is limited to formal review

The Amount Determination Document (Tutar Tespit Belgesi) is the document proving that the property value meets the minimum required threshold for citizenship ($400,000). It was previously built on a report issued exclusively by GEDAŞ, forcing the buyer to deal with a single entity.

How to Submit a Valuation Request?

• The request is submitted via the Web Tapu platform by the property owner if an individual, or by the company's authorized representative if the owner is a company.
• If the owner is a Turkish citizen, they can also submit the request through the ALO-181 call center.
• Fee details, payment deadlines, and application numbers arrive via SMS or email; the request is not referred to the valuation company prior to payment.
• In jointly owned property, it is sufficient for one of the partners to apply, and the report is used for all partners.

Why the Amendment Now? Background of the Decision

The amendment came following a major case that shook the citizenship-by-real-estate process:

• August 4, 2026: A security operation was executed across 16 provinces, in which 72 suspects were detained and a judicial custodian was appointed over 7 companies. It was revealed that 687 foreigners obtained citizenship irregularly through low-value properties whose prices were inflated with forged or non-compliant valuation reports.
• May 22, 2026: Law No. 7579 was published in the Official Gazette, adding Additional Article 4 to the Land Registry Law. Pursuant to it, valuation reports prepared by companies licensed by SPK and the Banking Regulation and Supervision Agency (BDDK) are transmitted electronically to TKGM.

The goal, therefore, is to expand the base of accredited companies while tightening oversight on report content, rather than restricting preparation to a single entity.

Circulating Information Not Yet Confirmed by Official Government Websites

Summaries of the amendment circulated across social platforms that have not been verified from an official source:

• Report approval by the GABİM platform: The official text does not mention this. The mechanism specified within it is that the report is electronically signed in accordance with Electronic Signature Law No. 5070, transmitted to the land registry, and then reviewed by the Real Estate Valuation Department at TKGM. This department may accept it, request its amendment, order a supervisory report, or request a new report via automated distribution.
• Abolishing the valuation exemption for Real Estate Investment Companies (GYO): This item did not appear in the text of the published updated circular. Until a clear official text is issued, investors should verify with the Land Registry Directorate before relying on any exemption. We previously explained the former exemption mechanism in the article on Companies Exempt from Real Estate Valuation in Turkey.

New Technical Conditions for Valuation Reports

The updated circular set detailed standards to which valuation companies must adhere, most notably:

1. The report must bear the signatures of at least three persons: the responsible expert, the auditor, and the valuation expert.
2. It must include at least three photos of the property, one of which must be internal, showing its condition and completion level.
3. The expert compares the approved architectural plan with reality on the ground, indicating differences by measurement against the plan.
4. Market price is adopted as the basis for land registry transactions, and the "market value for legal use" is mentioned for informational purposes only.
5. If the location of the unit on the ground does not match its number in the approved plan, its value is not estimated and "not calculated" is written in the report.

Under-Construction Properties: When Can They Be Valuated?

The circular established time-based rules linked to the building permit date:

Building Permit Age & Project Status	Rule
Less than two years and construction has not started	Valuation permitted
Between two and five years and construction is ongoing	Valuation permitted if photos document the construction stage
More than two years and construction has not started	Cannot be valuated, as the permit requires renewal
More than five years and construction is still ongoing	Cannot be valuated, as the permit requires renewal
Stalled or abandoned project at risk of halting	Value is not estimated

These rules are important for off-plan buyers aiming for citizenship. A stalled project may not obtain a report at all, and consequently no Amount Determination Document will be issued for it.

When Do You Need a New Report Before 12 Months Expire?

A longer validity period does not mean the report remains valid under all circumstances. If a change affecting property value is recorded on the title deed between the report date and the date of submitting the sale or promise-of-sale request, a new report must be obtained regardless of the duration. Examples of such changes include:

• Changing the property type in the registry.
• Deducting part of the land for a public road.
• Registering an easement right.
• Annotations registered under special laws.
• A statement indicating the property is located within a restricted military zone.

Impact of Amendments on Investors Seeking Citizenship

Positives:

• A larger number of accredited companies is expected to shorten waiting times caused by restricting preparation to a single entity.
• A 12-month validity gives a broader margin to complete bank transfers and land registry appointments, especially in phased transactions.

Points requiring attention:

• Company selection is in the owner's hands: The application is submitted by the property owner, usually the seller, who chooses the valuation company. Therefore, it is advisable for both parties to agree in advance in the contract on the company or the selection method.
• The amount is verified from three sources: According to TKGM, each of the following values must reach the required threshold individually: the Currency Purchase Certificate value, the sale price declared on the deed, the valuation report value, and total bank transfers. If any of them falls below $400,000, the file is halted.
• The report is not required for every purchase: Outside citizenship files, valuation reports are no longer required in foreign purchase transactions since the 2024 amendments, unless requested by the competent authority.

The cost of the report remains part of the total transaction costs, which we detailed in the guide to VAT and Title Deed Fees for Foreigners in Turkey 2026. Documents for the subsequent stage can be found in the report on Documents Required for Turkish Citizenship.

Frequently Asked Questions

Is a GEDAŞ report still acceptable?

Yes. GEDAŞ remains one of the accredited companies, but it is no longer the sole entity.

Can a report issued before the amendment be used?

The published text does not specify an explicit transitional rule for previous reports. Therefore, it is recommended to consult the Land Registry Directorate regarding any report approaching the end of its former validity.

Who pays the valuation fee?

The fee request is sent to the applicant, and both parties can agree otherwise in the contract.

Is a new report required upon title transfer after registering a promise of sale?

No. According to TKGM, a new report is not required when registering the property in the buyer's name if the promise of sale was previously registered in the land registry.

Skyline Holding Recommendations for Investors

• Specify the valuation company in the purchase contract or agree on selecting it via automated distribution to reduce potential conflicts of interest.
• Leave a safety buffer above $400,000 in price and transfers, because any value below the threshold halts the file.
• Verify the age of the building permit in off-plan projects prior to contracting.
• Do not rely on a GYO exemption before receiving written confirmation from the competent authority.
• Monitor the property registry until the title deed appointment, as any new annotation invalidates the report.

Contact the Skyline Holding team to assist you in studying investment opportunities and calculating returns accurately.