Work Permits for Foreign Healthcare Workers in Türkiye: Prior Authorization, Equivalence and Private Healthcare Facilities

Why is the regime for foreign healthcare workers multi-staged?

Because healthcare services are directly connected with a person's life and bodily integrity, the work of a foreign healthcare professional lies at the intersection of two separate administrative controls. The first control concerns whether the profession may be practised in Türkiye. At this stage the diploma, specialization, equivalence, registration, language proficiency, any professional impediment and the scope of duty are examined. The second control concerns the foreign national's employment with a specific employer and is conducted under the International Labor Force Law No. 6735. [1][2]

For this reason the following documents do not produce the same legal result:

• A diploma or specialization certificate shows the person's education.
• An equivalence certificate shows that the foreign education has been recognized as corresponding to its Turkish counterpart.
• Ministry of Health prior authorization allows the application to be carried to the work permit stage in terms of professional competence and the healthcare sector.
• The work permit enables the foreign national to work with a specific employer and within a specific scope of duty.
• The staff employment certificate is the institutional document issued or approved by the competent health authority so that healthcare services may actually be provided at the healthcare facility.
• Registration with the professional chamber is completed separately where the legislation requires it.

The absence of any link in this chain of documents does not make it lawful for the foreign national to actually admit patients or provide healthcare services.

A work permit and authority to practise a profession are not the same thing

A work permit is the general administrative document concerning a foreign national's right to work in Türkiye. However, for medicine, nursing and other healthcare professions, special laws and Ministry of Health regulations also apply. The fact that the title in the work permit is written as "health consultant", "coordinator" or similar does not give the foreign national authority to practise medicine or another regulated healthcare profession. The annotations to work permits also state expressly that some permits are not sufficient for practising the profession of medical doctor. [4]

The facility's activity and the foreign national's professional authority are examined separately

It may change the outcome whether the workplace that wishes to employ the foreign national is a private hospital, medical centre, polyclinic, laboratory, oral and dental health facility, rehabilitation centre or another healthcare facility. The facility's operating licence, its staffing and unit authorizations, and the foreign national's professional authority must complement one another in the same application. If the facility has no authority to admit patients in a particular branch, it is not sufficient on its own that the foreign national has equivalence and a work permit in that branch.

Which foreign healthcare professionals are assessed under this process?

The possibility for foreign healthcare professionals to work is regulated separately for each profession. Doctors and some non-physician healthcare professionals may work at private healthcare facilities with the necessary permits. However, for dentistry, pharmacy, and the professions that the legislation reserves for Turkish citizens or subjects to special restrictions, the relevant special laws must be examined separately. It therefore cannot be concluded that "all foreign healthcare workers can work by the same method". [2][5]

Doctors and specialist doctors

The foreign doctor's medical diploma and, if any, specialization certificate must be recognized in Türkiye, the Ministry of Health registration procedures must be completed, Turkish proficiency must be demonstrated, and there must be no circumstance preventing the practice of the profession. Additional obligations, such as professional liability insurance and membership of the medical chamber, may also arise for the doctor. Work permit annotations may make the validity of the permit conditional on the foreign doctor registering with the relevant medical chamber within a certain period. [2][4][6]

Non-physician healthcare professionals

For nurses, physiotherapists, dietitians, psychologists, health technicians or any other healthcare professional defined in the legislation, the diploma level, job description, method of equivalence or registration, and the facility's authority for the relevant position are examined separately. The field of the healthcare professional's diploma and the duty written in the work permit and in the staff employment certificate must be the same. Obtaining prior authorization under one professional title and actually working in another duty may amount to a breach of the scope of the permit.

Foreign nationals who will work in administrative or support roles in the healthcare field

A foreign national who will take on a human resources, foreign patient coordination, interpreting, marketing, IT or administrative management role at a healthcare facility may not need professional health prior authorization if he or she does not actually provide healthcare services. However, the job description and the actual work must be consistent. A person who obtains a permit with the title "coordinator" but examines patients or performs clinical interventions may face both the risk of unauthorized practice of the profession and the risk of working outside the scope of the work permit.

How are diploma equivalence and professional registration assessed?

A diploma obtained abroad does not by itself create authority to practise a profession in Türkiye. Before the work permit application or during the prior authorization process, the equivalence and registration procedures required by the competent authority for the relevant profession must be completed. The current explanation of the Ministry of Labor and Social Security (ÇSGB) also states that submitting a diploma equivalence certificate is mandatory for foreign doctors and nurses who graduated abroad. [7]

Medical diploma and specialization certificate

Medical education and specialization training are different documents. Even if the equivalence of the foreign doctor's basic medical diploma is accepted, the specialist title may need to be recognized separately. In the application file:

1. The original or a duly certified copy of the diploma and specialization certificate,
2. The apostille or, where applicable, the certification of the foreign mission,
3. The sworn Turkish translation,
4. The equivalence and registration documents,
5. The identity document, passport and foreign identification number,
6. Professional history and good conduct documents

must be consistent with one another. Differences in name, date of birth, diploma number and field of specialization must be explained before the application.

Healthcare fields involving clinical practice

In fields involving clinical practice, equivalence is not merely an academic registration procedure; it is also decisive for the authority to intervene on patients. In Council of State decisions, the link between requiring a diploma equivalence certificate in healthcare fields with clinical practice and patient safety and professional competence has been discussed. Receiving training, observing, or being enrolled in a postgraduate programme does not on its own confer authority for independent intervention on patients. [8]

Separating training status from working status

For foreign nationals receiving specialization training in medicine or dentistry, there may be a work permit exemption or provisions specific to training status. This status is not the same as working freely at a private healthcare facility. The scope of the specialization training, the training institution, the exemption certificate and the authority to take part in patient care must be examined together.

How is Ministry of Health prior authorization obtained?

In a work permit application made on behalf of a foreign national who will work in occupations and duties requiring professional competence in the healthcare sector, prior authorization from the Ministry of Health is mandatory. For a foreign healthcare professional who will work at a private healthcare facility, the ÇSGB document list requires a prior authorization document showing professional competence from the Provincial Health Directorate of the province where the facility is located, together with the employer's operating licence. [3][9]

Who makes the application?

In practice, the private healthcare facility where the foreign national will work applies to the provincial health directorate through its responsible manager or authorized representative. The application is not merely the foreign national's personal request; the facility's staffing, field of activity and the duty of the staff to be employed are also examined. The relevant documents are evaluated by the provincial health directorate and, where necessary, by the Ministry of Health.

Which documents should the prior authorization file contain?

Although it varies according to the profession and the facility, the file generally contains the following groups:

Leaving the application open-ended in the expectation that a missing document can be submitted later may cause the prior authorization and work permit periods to become detached from each other. In particular, if the equivalence procedure has not been completed, what the outcome of the application depends on should be clearly recorded.

How is Turkish proficiency handled?

Turkish proficiency is required so that the foreign healthcare professional can communicate safely with patients, the team and the records system. The type and level of the document requested may vary according to the profession and current practice. Some practice announcements have provided for at least B-level proficiency and an opportunity to submit the certificate within a certain period; however, the criterion valid on the date of application should be verified with the provincial health directorate and the Ministry of Health. Whether graduation from an institution providing education in Turkish constitutes an exception should also be shown with documents. [10]

In what order is the work permit application made?

After prior authorization is obtained, the employer submits the work permit application through the e-İzin system of the Ministry of Labor and Social Security. In addition to the general documents, the healthcare-sector prior authorization and the operating licence are uploaded with the application. [3][9]

Applications from within Türkiye and from abroad

An application from within Türkiye may be made for a foreign national holding a residence permit that is valid in Türkiye and suitable for the application. In an application from abroad, the foreign national initiates the procedure at a Turkish diplomatic mission, and the employer completes the e-İzin application with the reference number. The validity of the passport affects the maximum period for which the work permit may be issued. [9]

Pay and evaluation criteria

For applications concerning duties requiring professional competence at public institutions in the healthcare sector, the employment, pay and financial adequacy criteria are not applied. For private healthcare facilities, however, the general and sector-specific criteria do not disappear by themselves because prior authorization has been granted. Prior authorization does not create an absolute right to a work permit; the Ministry separately assesses the employer, the pay, the duty and the other conditions of the application. [3]

Prior authorization is not a work permit

Prior authorization does not mean that the foreign national may start work. Until the work permit decision is made and the staff employment certificate at the healthcare facility is approved, it creates legal risk for the foreign national to examine patients, issue prescriptions, perform treatment or provide healthcare services.

When is the staff employment certificate obtained?

After the work permit is issued, the private healthcare facility completes the staff employment certificate procedures with the provincial health directorate so that the foreign national can begin duty in the facility's staff. The current private healthcare regulations provide that a healthcare worker for whom no staff employment certificate has been issued cannot perform duties, and that the start and departure of staff must be notified to the provincial health directorate. [11][12]

Can patients be admitted before the employment certificate is approved?

No. The special authorization system in the healthcare field requires, after the work permit, that an employment certificate also be issued on a facility basis. In decision E.2015/3765, K.2018/2148 of the 15th Chamber of the Council of State, too, it was stated that newly starting healthcare staff may work at the facility from the date on which the employment certificate is approved. Although the decision relates to the period of the former regulation, it shows the constitutive importance of the employment certificate for the actual commencement of work. [13]

What happens upon a change of facility or branch?

The staff employment certificate is issued for a specific facility and duty. A foreign doctor's moving to another healthcare facility in the same city, taking on-call duty at a second place, or working in a different branch must be assessed separately under both the health legislation and the work permit. The existing certificate cannot be used automatically for a new employer or a new unit.

How should the employment contract and job description be prepared?

In the contract of healthcare staff, the professional title, field of specialization, place of work, working time, pay, on-call arrangements, professional liability and leave terms must be stated clearly. The duty in the contract must be the same as in the prior authorization, the work permit and the staff employment certificate.

Pay, full-time work and secondary employment

The pay declared in the work permit application must be consistent with the payroll and the SGK notification. A doctor or other healthcare worker's working at more than one facility is not possible merely by agreement of the parties; the restrictions in the private healthcare legislation and the employment certificate required for each facility are taken into account. If there are special provisions on healthcare staff taking on-call duty elsewhere, their scope must not be exceeded.

Professional liability and patient data

Foreign healthcare staff are subject to the rules in Türkiye on patient rights, personal health data, medical records, advertising and professional ethics. The transfer of patient information to a system abroad, remote consultation, records in a foreign language and telehealth activities must also be assessed separately under the KVKK (Personal Data Protection Law) and health data legislation.

How are departure from work and the ending of permits carried out?

When the employment contract ends, SGK deregistration is not the only step. The employer must:

1. Notify the ÇSGB of the end of the employment relationship within the statutory period,
2. Carry out the work permit termination procedure,
3. Notify the provincial health directorate of the departure and have the staff employment certificate cancelled,
4. Submit the SGK notice of departure from work,
5. Assess the effect on the facility's staffing and its authority to admit patients.

The current private healthcare regulations provide that the departure of staff be notified to the provincial health directorate within ten working days at the latest and that the employment certificate be cancelled. For the ÇSGB, the start and end of work and circumstances requiring cancellation must be notified within fifteen days. These periods are not substitutes for one another. [1][11]

What remedies are available against a refusal or cancellation decision?

Prior authorization, the work permit and the staff employment certificate may be three separate administrative acts. First, it must be determined which authority took which act. Against a refusal of a work permit application by the ÇSGB or a decision cancelling the permit, an objection may be made to the Ministry within thirty days of notification; upon rejection of the objection, recourse may be had to the administrative courts. [1]

Dispute over prior authorization or the healthcare employment certificate

The route of application against prior authorization, registration or staff employment certificate acts taken by the provincial health directorate or the Ministry of Health is assessed according to the nature and notification of the act. An objection made to the ÇSGB does not by itself preserve the time limit against a separate decision of the health administration. If the same event involves two different administrative acts, the notification and the subject of the suit for each must be recorded separately.

Does an annulment action automatically confer a right to work?

No. The filing of a suit does not by itself stop the refusal or cancellation act. To obtain a stay of execution, the conditions of clear unlawfulness and of damage that is difficult or impossible to remedy must be substantiated. In healthcare services, patient safety and professional competence are areas in which the administration has a strong defence; the applicant must document that equivalence, duty, the facility's authority and his or her personal situation were correctly assessed.

What do the Council of State decisions show?

In decision E.2019/9940, K.2023/7508 of the 10th Chamber of the Council of State, a dispute over the cancellation of a work permit issued for work as a cardiology specialist at a private healthcare facility was examined, and the regional administrative court decision dismissing the action was upheld. The short reasoning of the decision shows that the employment certificate is not an acquired and unlimited right and that the conditions of the facility and the legislation must continue to be met. [14]

In decision E.2020/5510, K.2024/3115 of the 10th Chamber of the Council of State, sanctions connected with unauthorized persons performing procedures at a healthcare facility and with staff working without an employment certificate issued in their name were assessed. The decision is not specific to applications concerning foreign staff; however, it clearly shows that actual healthcare services must be carried out only within professional and institutional authority. [12]

Checklist for the employer and the foreign national

Before the application

• Has it been checked whether there is any special provision preventing the profession from being practised by foreign nationals?
• Has diploma and specialization equivalence been completed?
• Have the Ministry of Health registration and language proficiency conditions been met?
• Are the employer's operating licence and the staffing for the relevant branch suitable?
• Is the title and duty in the employment contract consistent with the professional certificate?

Before starting work

• Has the Ministry of Health or provincial health directorate prior authorization been obtained?
• Has the ÇSGB work permit become final?
• Has the staff employment certificate been issued and approved?
• For doctors, have the medical chamber and professional insurance procedures been completed?
• Has the SGK notice of entry into employment been submitted?

During employment and upon departure

• Are the pay and the SGK notification consistent with the work permit?
• Has there been a change of duty, employer, facility or branch?
• Have departure, termination of the work permit, notification to the health administration and SGK deregistration each been carried out separately?
• Have patient data and medical records been stored securely?

Common mistakes

• Mistaking an equivalence certificate for a work permit.
• Having the person start work after Ministry of Health prior authorization is issued, without waiting for the ÇSGB decision.
• Thinking that a staff employment certificate is not needed because a work permit card has been obtained.
• Examining patients under an administrative-duty permit.
• Working at another facility with a permit issued for one healthcare facility.
• Using a specialist title without specialization equivalence.
• Making the SGK deregistration but forgetting the notifications to the health administration and the ÇSGB.
• Applying to the wrong authority against a refusal decision and missing the time limit for filing suit.

Conclusion

The work of foreign healthcare staff in Türkiye requires professional recognition, health administration prior authorization, the work permit and the facility-based employment certificate to be completed together. The central question of the process is not merely the foreign national's diploma, but to which professional and specialist title in Türkiye that diploma corresponds, whether the facility where he or she will work is authorized to provide this service, and whether the actual duty remains the same as in the permit documents. Each administrative record must also be completed separately upon a change of employer, a change of branch and departure. Establishing the wrong order of documents may lead not only to the refusal of the application but also to the consequences of unauthorized healthcare services, suspension of operations, administrative fines and professional liability.

Frequently Asked Questions

Can a foreign doctor work in Türkiye?

Yes; however, diploma and specialization equivalence, Ministry of Health prior authorization, the ÇSGB work permit, the staff employment certificate and, where applicable, medical chamber registration and professional insurance obligations must all be completed. [2][4][7]

Is diploma equivalence required for a foreign nurse?

The professional diploma obtained abroad must be recognized in Türkiye and professional registration must be completed. The name of the document and the procedure are determined under the Ministry of Health's practice according to the profession. [6][7]

Can foreign healthcare staff start work once prior authorization is obtained?

No. Prior authorization only allows the ÇSGB work permit application to be made in respect of the healthcare sector. The work permit and the facility-based staff employment certificate must also be completed. [3][9]

Is a work permit card sufficient to examine patients?

No. The duty shown on the card is assessed together with professional authority, equivalence, registration and the staff employment certificate.

Can a foreign doctor open a private practice?

In the private healthcare legislation, the route for foreign healthcare professionals to work is regulated essentially through permitted private healthcare facilities. The possibility of opening a private practice must be examined separately according to the profession and the current special provisions; no automatic conclusion should be drawn from the general work permit. [2][11]

Is the Turkish proficiency certificate the same for every healthcare profession?

No. The accepted document and level may vary according to the profession and current Ministry of Health practice. The condition valid on the date of application should be verified with the provincial health directorate. [10]

Can a person work at another hospital with a permit obtained for one hospital?

As a rule, no. The work permit and the staff employment certificate are tied to a specific employer, facility and duty. The procedures required for the new facility must be completed.

Within how many days must the departure of foreign healthcare staff be notified?

Under the current private healthcare regulations, departure must be notified to the health administration within ten working days at the latest; for the ÇSGB, the end of work must be notified within fifteen days. SGK deregistration is also carried out separately within its own period. [1][11]

What is the time limit against a refusal of the work permit?

An objection may be made to the Ministry within thirty days of notification of the ÇSGB decision. If a prior authorization or staff employment certificate decision has been made by another authority, the time limit for application and for filing suit for that act is calculated separately. [1]

Can foreign healthcare staff continue working after filing suit?

No. The filing of a suit does not by itself stop the act. Healthcare services must not be provided without a valid permit and employment certificate.

Sources

1. Law No. 6735 on International Labor Force (6735 sayılı Uluslararası İşgücü Kanunu), in particular Arts. 6, 7, 12, 15, 21 and 22. Official text: mevzuat.gov.tr
2. Regulation on the Procedures and Principles of Work of Foreign Healthcare Professionals at Private Healthcare Facilities in Türkiye (Yabancı Sağlık Meslek Mensuplarının Türkiye’de Özel Sağlık Kuruluşlarında Çalışma Usul ve Esaslarına Dair Yönetmelik). Ministry of Health: teftis.saglik.gov.tr
3. Ministry of Labor and Social Security (Çalışma ve Sosyal Güvenlik Bakanlığı), Work Permit Evaluation Criteria (Çalışma İzni Değerlendirme Kriterleri), "Healthcare sector": csgb.gov.tr
4. Ministry of Labor and Social Security, List of Work Permit Annotations (Çalışma İzni Şerhleri Listesi): csgb.gov.tr
5. Law No. 1219 on the Manner of Practising Medicine and Allied Arts (1219 sayılı Tababet ve Şuabatı San’atlarının Tarzı İcrasına Dair Kanun). Official text: mevzuat.gov.tr
6. Ministry of Health, institutional information and documents on the Diploma and Registration Procedures of Healthcare Professionals (Sağlık Meslek Mensuplarının Diploma ve Tescil İşlemleri): shgmtescildb.saglik.gov.tr
7. Ministry of Labor and Social Security, Work Permit Frequently Asked Questions (Çalışma İzni Sıkça Sorulan Sorular), foreign doctors and nurses: csgb.gov.tr
8. Council of State 8th Chamber, E.2022/4452, K.2022/4506, dated 29.06.2022: app.dejure.ai
9. Ministry of Labor and Social Security, Information and Documents Required in the Work Permit Evaluation Process (Çalışma İzni Değerlendirme Sürecinde Gerekli Bilgi ve Belgeler): csgb.gov.tr
10. Current practice announcements of the Ministry of Health and provincial health directorates on Turkish proficiency for foreign healthcare professionals: saglik.gov.tr
11. Regulation on Private Healthcare Facilities (Özel Sağlık Kuruluşları Hakkında Yönetmelik) and current practice explanations: saglik.gov.tr
12. Council of State 10th Chamber, E.2020/5510, K.2024/3115, dated 18.09.2024: app.dejure.ai
13. Council of State 15th Chamber, E.2015/3765, K.2018/2148, dated 28.02.2018: app.dejure.ai
14. Council of State 10th Chamber, E.2019/9940, K.2023/7508, dated 27.11.2023: app.dejure.ai