Opening an Esenlik Centre or Esenlik Unit: Set-Up, License and Staffing Guide

To open an Esenlik centre or Esenlik unit, one must choose a suitable business model, prepare the premises in accordance with the law, meet the requirements for the responsible manager and staff, and obtain a license from the Provincial Directorate of Health. A tourism operation certificate for a hotel, a permit for a sports facility or a "wellness" brand does not replace this license. A unit located within an existing establishment and a centre operating in a standalone building are not subject to the same physical conditions.

The Regulation on Esenlik Services, published in the Official Gazette No. 33300 dated 4 July 2026, introduces a specific framework that covers everything from the design of the investment to its day-to-day operation. As of 11 October 2026, this guide is based on the regulation and its annexes. It examines together the room and area conditions, the application file, the employment of physicians, the limits of services and the problems that may be encountered during inspection. The Ministry announcement dated 6 July does not change the date on which the regulation entered into force: the regulation took effect on the day it was published. [1]

For which activities does the Esenlik license matter?

The trade name and the scope of the license are assessed separately

Esenlik is a field in which services are organized to support a person's physical, mental and social well-being. However, not every yoga studio, massage room, gym, spa or nature camp is, by that fact alone, a centre or unit within the meaning of this regulation. The assessment is based on the content of the service, the role of health professionals, programmes tailored to the individual, the equipment and the form of organization, before the name used. Writing "retreat centre" on a business's website does not create a new type of license. [1]

The investor should first put the list of services in writing. Instead of a broad expression such as "healthy living programme", it should be specified who will carry out the assessment, which procedure will be applied, which device will be used, where the service will be provided and how records will be kept. This list, submitted to the Provincial Directorate of Health, ensures that the architectural project and the staffing plan describe the same activities. The fact that a service falls within the Esenlik category does not mean that anyone may perform it.

An Esenlik license cannot be read as a general permission for medical procedures that require separate authorization under their own legislation. For example, the fact that a device is sold on the market does not show that every procedure with that device may be carried out in an Esenlik centre. Professional authority, Ministry permission and the scope of the facility license are examined together. The approach "we have a doctor, so we can provide all health services" overlooks the nature of the establishment and the limits of its services. [1, Art. 10]

What do tourism, care and sports permits do?

A tourism operation certificate concerns the status of an accommodation facility under tourism legislation; an Esenlik license concerns the provision of Esenlik services. A permit for an elderly or disabled care institution does not replace an Esenlik service either. These documents may complement one another, but they do not substitute for one another. The transfer of the Esenlik unit to a separate operator does not automatically end the host establishment's responsibilities arising from the regulation. [1, Art. 4–6]

For this reason, it is not enough for an investment contract merely to state that "space within the hotel has been leased". The contract should expressly regulate who will apply for the license, who will employ the staff, the use of a shared emergency room, access to health records and the obligation to submit documents during inspection. The allocation of duties in the contract may not be used as a provision that prevents the administration from approaching the legal persons responsible.

How is the choice made between a centre and a unit?

Room and floor-area requirements vary according to the set-up option

The regulation defines separately the option of opening within an existing establishment and the option of opening as a standalone facility. For a centre, a standalone building is required; for a unit, the phrases used are a closed area of at least 300 m² and a separate entrance. It should not be concluded from this definition that the unit must in every case use the whole building. The concept of an accommodation facility is based on a tourism operation certificate obtained from the Ministry of Culture and Tourism. The statements "I have a simple accommodation certificate" or "my license application is ongoing" should not be assessed on the assumption that this condition is met. The name, holder, address and scope of the document should be checked before the application. [1, Art. 4]

The conditions in the table arise from the definition of the set-up. The calculation of the area, and which independent sections and shared areas it covers, must be clarified by comparing the use shown in the project with the title and building documents. Reaching 500 m² by renting several independent sections together does not by itself satisfy the "standalone building" condition. Basements, storage rooms, open terraces or area belonging to a neighbouring business cannot be counted to satisfy the advertising calculations and do not replace the licensing review. [1, Art. 4] [2]

In the sports club option, the specific definition in the regulation applies: sports clubs and sports joint-stock companies registered under Law No. 7405 and included with the relevant sports federation are the basis. Not every fitness room license is equivalent to this status. Although the Darülaceze Presidency is also counted in the definition of "institution", the wording of the centre and unit definitions does not repeat the same list word for word. For this special institution, the application of the model should be clarified with the Ministry and the Directorate, without concealing the difference between the definitions. [1, Art. 4]

Must the owner of the facility be a physician?

The regulation allows public institutions and organizations, natural persons and private law legal persons to open centres or units. This arrangement does not mean that the investor must necessarily be a physician. On the other hand, the requirements for the responsible manager and staff prescribed for managing health services must be fully met. The legal roles of the owner of the capital and of the person who assumes professional responsibility should be set up separately. [1, Art. 5, 11]

In a model where the business is transferred to a third party, the brand, premises, equipment and service organization may be held by different persons. This fragmented structure must not conflict with the identity of the operator shown on the license. A change of company, transfer of the business and a change of ownership of the host establishment are not the same transaction; the notification and re-licensing provisions of the regulation apply separately. [1, Art. 9]

What does the application file consist of?

The eight groups of documents in EK-1

The application is made to the Provincial Directorate of Health of the province in which the facility is located. Annex EK-1 of the regulation contains eight groups of documents. Unlike general advisory lists, the table below keeps the annex's own divisions. The main text uses the term "license", while the heading of EK-1 uses the expression "application for an authorization certificate"; EK-3 is the license document to be issued for the Esenlik centre or unit. It should not be concluded from this difference in terminology that there are two separate permits to open an Esenlik facility. [1, Art. 7] [2]

The heading of the trade registry document must not be completed on the assumption that every natural person can submit the same company document. Conversely, the fact that the annex mentions a particular building document only for a standalone centre does not give a unit a right to operate in an unlicensed building. A document index in the file that explains which legal condition each document proves makes these implementation problems visible. [1, Art. 7]

Use purpose and renovation license in an existing building

The fact that a hotel, a sports facility or a workplace to be rented already exists does not show that the part to be used for Esenlik services is architecturally ready. The use purpose in the approved project, the boundaries of independent sections and shared areas, wet areas, access and escape arrangements should be compared with the new service plan. The layout plan prepared for the Esenlik regulation does not replace the project and licensing review under zoning legislation. [1] [2] [9]

Article 4 of the Regulation on Planned Areas Zoning (Planlı Alanlar İmar Yönetmeliği) defines a substantial renovation as one that covers, in addition to load-bearing elements, operations that change the use purpose, the number of independent sections, the relevant areas or the projects annexed to the licence. Accordingly, not touching the columns does not mean that every conversion is a simple renovation. Read together with Articles 58 and 59 of the regulation, the distinctions between changes requiring a licence, simple repairs and other permits must be made. Painting work and merging two sections, or changing an approved use, are not the same operation. [9]

In practice, the architect may be asked for a comparison that overlays the existing approved project with the proposed layout. Work to be carried out under the lease, the documents and projects to be provided by the owner, the consequences of being unable to obtain the necessary permits, and the costs of restoring the premises to their former state should be clearly regulated. Where there is interference with a common area, the need for a decision or consent arising from the management plan and the property regime is examined separately; a health license does not resolve these private law relationships by itself.

On-site inspection and the license process

After the file is completed, a team of at least two persons carries out an on-site inspection. The conformity assessment is not carried out only on paper; the address, areas and service organization that are the subject of the license are actually checked. Where the application is found to be in order, the Provincial Directorate of Health issues the license and notifies the General Directorate of Health Services. [1, Art. 7]

No guarantee can be drawn from the regulation that all applications will be concluded within a fixed number of days. An architectural deficiency, an institutional permit, a personnel document or the inadequacy of the contracting party are separate grounds for delay. Keeping separate dates in an application tracking table for "submitted", "deficiency notified", "completed" and "on-site inspection carried out" makes it possible to plan sales, rental and staff costs more realistically.

After a license has been issued, failure to begin operation within six months leads to the cancellation of the license. It is wrong to start this period from the date of application or the date the building was rented. The opening timetable should be managed together with the license date, the date the responsible manager takes up the post, the staff work certificates and the commissioning of the records system. [1, Art. 8]

How should the responsible manager and health staff be planned?

The sixty-year condition does not apply to all physicians

Article 10(6) of the regulation provides that specialist physicians employed in centres and units must be over sixty years of age. The text does not say "sixty years of age or over" and does not make all physicians subject to this condition. The distinction between a physician and a specialist physician directly affects the investment's staffing budget and the assessment of candidates. The generalization "every centre must have a specialist physician over sixty" overlooks the option that the responsible manager may be a physician. [1, Art. 10–11]

The responsible manager must be a citizen of the Republic of Türkiye, must be authorized to practise the profession under Law No. 1219, must have worked in professional activity in Türkiye for at least three years, and must not be banned from the profession. The basic rule is full-time work; a prohibition on working at another health institution is also taken into account. If a specialist physician is appointed, the age condition for specialists is also assessed. Obtaining only a photocopy of a diploma does not prove that all of these conditions are met. [1, Art. 11]

EK-2 governs the certificate of the responsible manager; EK-5 the work certificate of non-physician health staff; and EK-6 the work certificate of physicians and specialist physicians. Concluding an employment contract or giving notice of entry to SGK does not replace the work certificate to be issued by the Provincial Directorate of Health. Staff who leave must be notified to the Directorate within ten working days from the date of departure. [1, Art. 10] [2]

Periods without a responsible manager are not free working periods added together

In this table, working days and calendar months are different measures. The annual upper limit of forty working days does not restart with each change of physician. In addition, apart from the temporary appointment exception in the regulation, operation without a responsible manager is a separate subject of sanctions in EK-4. The reasoning "I have thirty days to find a new manager" cannot be read as permission to provide health services without first establishing the necessary temporary responsibility. [1, Art. 11] [2]

Emergencies, outsourcing and everyday operating conditions

An emergency intervention room and a referral agreement should be established together

An Esenlik centre or unit must have a suitable room for emergency intervention. The regulation allows the use of a suitable emergency room within the establishment where one exists. However, shared use must be practically possible; a room shown on the project that is closed, under the control of another operator or inaccessible during an intervention should not be regarded as sufficient. In an emergency, first aid and the necessary intervention, followed by referral by ambulance, must be operational. [1, Art. 10, 13]

Institutions with which cooperation may be arranged include public hospitals, university hospitals and private hospitals. Where an agreement is to be made with a medical centre, the conditions of at least 3,000 m² of closed area and at least ten specialist physicians on the staff apply together. This condition is not the same for all types of institution covered by the contract for the replacement of a responsible manager. The existence of a public hospital suitable for emergency referral does not in every case give the right to provide a temporary responsible manager from outside. [1, Art. 11, 13]

Laboratory or imaging services may be obtained externally; the responsibilities of the authorized institution providing the service and of the Esenlik operator are assessed together within the scope of the regulation. Writing "all responsibility lies with the laboratory" in the contract does not remove the responsibility that the legislation imposes. The taking of samples, transmission of requests, evaluation of reports, data access and notification of urgent findings must also be regulated. [1, Art. 12]

Limits of services and sales prohibition

Operating without a license, providing services outside the licensed place, employing staff without work certificates and having services performed by persons not assigned to the institution are all prohibited. The regulation also prohibits providing services to patients in the convalescence period and the sale of products within a centre or unit. For this reason, an income item such as "sale of supplementary products to the programme" should not be written into the business plan as ordinary Esenlik income. [1, Art. 10]

The fact that a guest staying at the hotel has recently undergone surgery does not mean that the service is automatically lawful. The label "guest" does not remove the need to examine to whom and in which health condition the Esenlik service is provided. The criteria for accepting programmes, the professional assessment and the process of referral to a suitable institution where necessary should be set out in writing; a sales team should not be permitted to make a health suitability decision on its own.

Health data, promotion and international services

Health records should be separated from the hotel customer database

The regulation governs the use of a health information management system registered with the Ministry's registration and recording system, the recording of all services, secure archiving and the provision of a person's own records on request. The security of electronic records and the relevant electronic signature conditions must also be observed. A hotel's reservation software or an ordinary customer tracking spreadsheet does not by itself meet all of these obligations. [1, Art. 14]

Health data is special category personal data under Law No. 6698 on the Protection of Personal Data (KVKK). The processing condition, disclosure notice, access authority, retention, transfer and security are assessed separately. It is not appropriate to rely on the same broad "explicit consent" form for every processing operation; processing that has a legal basis must be separated from use for promotional purposes. The transfer of health information to a foreign reservation or cloud service raises a separate question about the regime for transfers abroad. [3]

The amendment of 4 July 2026 added a mechanism for a review of past diagnoses on the basis of the current health status, through an application and a health board report. Where a suitable report exists, the relevant transactions are, in principle, carried out in accordance with that report; it cannot be concluded that old diagnoses have been deleted automatically. The provision also does not mean that an Esenlik centre is authorized to issue every type of health board report. In recruitment assessments, the old records should not produce an automatic negative result; the relevant legislation and the current report should be considered together. [4]

Advertising language and admission of foreign guests

The promotion of Esenlik services is subject to the regulation on promotion and information in health services of 12 November 2025. Information describing the content of a programme must be separated from promises of a treatment result, superiority or certain success. Promotion of services not included in the license, misleading titles and the conversion of a person's health data into promotional material are also assessed separately. The fact that the facility operates in the tourism sector does not remove the rules on promoting health services. [1, Art. 16] [5]

Article 17 of the regulation provides that the Ministry will determine the procedures and principles for international Esenlik services. This article does not give every licensed operator an automatic medical tourism authorization. Providing only accommodation to a foreign guest and organizing an international health service are different things. The regulation on international health tourism of 26 April 2025 and the Ministry's current practice must be examined separately according to the scope of the service planned. [1, Art. 17] [6]

What sanctions may be applied on inspection?

EK-4 is not a single penalty schedule

EK-4 provides for different amounts, rates, correction periods and activity sanctions for different violations. The examples below show the financial result of a first finding; repetition of the violation, suspension of services or notification to the public prosecutor are considered separately. The amounts are the 2026 values in EK-4 and may not be used unchanged in subsequent years. [2]

In the calculation, it is wrong to use the word "turnover" and to take the whole of the hotel's revenue directly as the tax base, or to rely on net profit alone. The gross service revenue relied on in the decision must be shown with its period, its supporting documents and the rate. The minimum amount and the revenue-based calculation are compared; these two elements are not automatically added together as two separate penalties. Where there are multiple violations and repetition is assessed, the date of each act, its legal basis and its earlier notification must be shown separately.

Where there is an urgent risk that cannot be remedied, the governorate may suspend activities, with reasons stated, until the deficiency is remedied. A forged document, concealed information or a false declaration may lead to cancellation of the license and to other liabilities. On the other hand, every deficiency cannot be treated as a ground for indefinite closure without distinction; the relevant sanction row and the special danger provision are examined together. [1, Art. 18] [2]

How to approach a refusal of license or a closure decision

First, the transaction letter, the inspection report, the notice of deficiency and the record of notification should be obtained. Where the dispute concerns only the area calculation, the architectural measurement is decisive; where it concerns the responsible manager, the appointment and work certificates; and where it concerns a financial sanction, the revenue calculation is decisive. In administrative actions the general period is sixty days; the special period and the competent judicial branch for the administrative fine are also checked separately. Making an application does not in itself confer a right to continue the activity. [7]

It should not be assumed that every provision of the new Esenlik regulation is covered by settled, directly applicable case law. The Constitutional Court's tourism decision of 17 October 2024, E.2021/100, K.2024/174, shows the importance of the legal framework in interference with freedom of enterprise. However, that decision did not annul the Esenlik regulation. In an Esenlik file, the use of the general legal approach of the decision must be distinguished from the direct application of an annulment outcome under a different licensing regime. [8]

Which items should appear in the investment and contract plan?

The initial investment calculation should not be reduced merely to the cost of architectural decoration and equipment. The full-time cost of the responsible manager, the permitted health staff, the records system, data security, emergency organization, external service contracts, maintenance, insurance and fixed costs during any delay in opening should be calculated together. A statutory limit on the sale of services or products may directly change the revenue forecast.

Before premises are rented, the use purpose, existing building documents, the possibility of renovation and conformity with the set-up model should be checked. For the period between the start of the lease and the grant of the license, a rent exemption or staged payments may be agreed; for the case where the license cannot be obtained, termination and cost-sharing; and for the removal of fixtures, access may be arranged. These are not guarantees of a licence; they ensure that the risk of not obtaining the permit is clearly allocated between the parties.

Staff contracts should cover the obtaining of work certificates, the limit on the responsible manager working elsewhere, the notice of departure and the handover of records. The availability of the service under a cooperation agreement must also be tested in practice: the existence of a signed page for urgent referral does not show that out-of-hours transport and reception arrangements have been put in place. This preparation turns licensing inspection from a paperwork exercise into a sustainable operating arrangement.

Conclusion

The first decision in an Esenlik investment is, together with the question "centre or unit?", within which establishment and with which services the business will operate. Once the appropriate model has been determined, the architectural conditions, the EK-1 file, the responsible manager, the staff work certificates, the emergency cooperation and the records system should be prepared within the same scope. Rather than a fast opening plan based on a promise of success, a timetable in which each condition has an assigned document and an assigned person reduces investment risk.

The three most important distinctions are: not applying the standalone-institution floor-area condition to every model; not applying the age condition for specialist physicians to all physicians; and not using a tourism certificate in place of an Esenlik license. The outcome of a specific application is assessed on the basis of the facility's documents and the services to be provided.

Frequently Asked Questions

Must one be a physician to open an Esenlik centre?

The investor may be a natural person or a private law legal person. Ownership and the role of responsible manager are separate roles. The business must have a responsible manager and health staff that comply with the regulation. [1]

Must every Esenlik centre be at least 500 m²?

The 500 m² closed-area condition relates to the standalone centre option. The same threshold does not apply automatically to the model within an accommodation facility or other institutions listed in the regulation. The obligation to provide services in suitable areas continues to apply in any event. [1]

Can an Esenlik unit be opened in an eight-room hotel?

The condition of ten rooms sought in an accommodation facility for a centre is not carried over to the definition of a unit. However, the hotel's tourism operation certificate and the other institutional and service conditions must be met. The number of rooms alone does not secure a favourable licensing outcome. [1]

Must all physicians be over sixty?

No. The regulation imposes this condition on the employment of specialist physicians. The distinction between physician and specialist physician and the other qualifications of the responsible manager are assessed separately; the phrase "over sixty years of age" in the text must be preserved. [1]

If the responsible manager leaves, can the business operate without a manager for thirty working days?

No. The period for a new appointment is not permission to continue operating without a suitable temporary appointment. The substitution conditions inside and outside the facility and the continuous and annual limits of the regulation apply together. [1] [2]

Can the hotel's emergency room be used?

The regulation allows the use of a suitable shared room. The room must be practically accessible and the emergency organization must be established. The existence of the room does not remove the referral cooperation and the other emergency obligations. [1]

Can supplements or cosmetic products be sold during a programme?

The regulation prohibits the sale of products within a centre or unit. It is not appropriate to add sales revenue to the business plan as an ordinary and permitted activity of the Esenlik business; the concrete organization must be assessed separately. [1]

Does an Esenlik license also grant authority for medical tourism?

It does not do so automatically. The Ministry's regulations on international Esenlik services and the medical tourism authorization that applies to the planned activity must be checked separately. [1] [6]

Is converting part of an existing hotel into an Esenlik unit a simple renovation?

Not always. Where the use purpose, the project annexed to the license, the independent sections or the layout of common areas change, a substantial renovation review is required. The renovation license required under zoning law for the layout submitted for the Esenlik license must be assessed separately. [2] [9]

Sources

• [1] Regulation on Esenlik Services (Esenlik Hizmetleri Yönetmeliği), Official Gazette 4.7.2026, No. 33300, in particular Arts. 4–18 and the provision on entry into force. Full text published by the Provincial Directorate of Health.
• [2] Regulation on Esenlik Services, Annexes EK-1 to EK-6: application documents, certificate of the responsible manager, license, inspection and sanctions form and staff work certificates. Accessible PDF copy of the Official Gazette annex — Private Hospitals Platform. The eight-page annex was examined for the distinctions between documents and sanctions.
• [3] Law No. 6698 on the Protection of Personal Data (KVKK), in particular Arts. 4–6 and 9–12. Personal Data Protection Authority legislation page.
• [4] Regulation Amending the Regulation on Personal Health Data, Official Gazette 4.7.2026, No. 33300; in particular the new Art. 13/A. Full text published by the Ministry of Health.
• [5] Regulation on Promotion and Information Activities in Health Services (Sağlık Hizmetlerinde Tanıtım ve Bilgilendirme Faaliyetleri Hakkında Yönetmelik), Official Gazette 12.11.2025, No. 33075. Text published by the Provincial Directorate of Health.
• [6] Regulation on International Health Tourism and the Health of Tourists (Uluslararası Sağlık Turizmi ve Turistin Sağlığı Hakkında Yönetmelik), Official Gazette 26.4.2025, No. 32882. Ministry of Health announcement and regulation.
• [7] Law No. 2577 on Administrative Procedure (İdari Yargılama Usulü Kanunu), in particular Arts. 7, 10–11 and 27. Current consolidated text.
• [8] Constitutional Court, 17.10.2024, E.2021/100, K.2024/174, in particular paras. 46–55. Official Gazette 24.3.2025, No. 32851. Full text of the decision. It is not a direct annulment decision concerning the Esenlik regulation.
• [9] Regulation on Planned Areas Zoning (Planlı Alanlar İmar Yönetmeliği), Official Gazette 3.7.2017, No. 30113, Arts. 4, 58–59; Zoning Law No. 3194 (İmar Kanunu), Art. 21. Annotated copy of the regulation published by the Konya Metropolitan Municipality; Zoning Law.