Why is the health of a tourist in Türkiye different from planned health tourism?
The health of a tourist
A foreign national who comes to Türkiye temporarily for a holiday, a congress or business and suddenly falls ill, or needs emergency medical help, while here may fall within the scope of “the health of tourists” in the Regulation of 26.04.2025. This is different from a person who has come to Türkiye in advance to obtain medical services. The time the incident began, the purpose of entry into the country, the nature of the health need and the person’s social security status must be assessed together.
Planned international health tourism
A foreigner’s coming to Türkiye for surgery, dental treatment or another pre-planned healthcare service is connected with the activity of international health tourism. The authorisation certificates of the healthcare facility and of the intermediary organisation, the scope of the planned service, complications, pricing and contract terms may be subject to different rules. Article 11 of the Regulation provides for the price tariff determined by the Ministry for international health tourism, and Article 12 for the invoice and the itemised statement of services. It is not correct to apply this tariff automatically to all persons and transactions that the Regulation leaves outside its scope.
Persons the Regulation leaves outside its scope
Article 2 of the Regulation makes a special scope distinction for persons entitled under international social security agreements, persons with certain protection statuses and the other groups listed. For these persons, the applicable social security, international agreement and relevant regulation should be examined. The fee regime must not be determined by looking only at a foreigner’s passport.
Regulation Article 2/3: a person outside the scope voluntarily choosing a paid international health tourism service
Article 2/3 of the Regulation on International Health Tourism and the Health of Tourists of 26 April 2025 allows persons excluded under the second paragraph to receive healthcare services under this Regulation if they undertake, of their own will, to pay a fee within international health tourism. This special choice does not come about automatically merely because the person is a foreigner or has applied to a hospital; the legal status the person is in, which service he or she chose, the information given on price and scope and whether there is a genuinely declared will must be examined.
This provision does not remove the impossibility of delaying emergency intervention, the special financing of healthcare services resulting from a traffic accident, or the patient’s other mandatory rights. The forensic-case exception, brought in by law enforcement, in Article 2/2-(ğ) of the Regulation and a clearly paid health tourism service that can later be chosen under Article 2/3 are different situations. If a healthcare facility relies on a fee undertaking, the date of the undertaking, the patient’s state of health and will, whether the choice was made before or after the emergency intervention and the scope of the service provided must be documented separately.
The special position of foreigners brought in by law enforcement as a forensic case
Article 2/2-(ğ) of the Regulation of 26 April 2025 leaves outside the scope of this Regulation foreigners who are brought in by law enforcement as a forensic case and receive emergency healthcare services. This exception does not mean that every injured person arriving at a hospital by ambulance, or every victim of a traffic accident that is later investigated, is automatically outside the scope; the condition of having been brought in by law enforcement as a forensic case must be established from concrete records.
Being outside the scope does not mean that emergency medical intervention can be refused or that any fee can be arbitrarily demanded. The general healthcare services and patient rights legislation and, for traffic accidents, KTK Article 98, the SGK and any insurance regime apply separately. The person liable for the fee must not be determined without obtaining the form of application, the forensic case record, the referral and the records of the paying institution.
The authorisation certificate for continuing treatment after an emergency
Although Article 10/1 of the Regulation regulates obtaining services in a sudden illness and emergency arising within the scope of the health of tourists in Türkiye, it also states that healthcare services of a continuing nature following a sudden illness or emergency cannot be provided in healthcare facilities that do not hold an international health tourism authorisation certificate. That treatment began at the emergency stage does not mean that it can continue indefinitely in any healthcare institution under the same regime. The referral decision, the medical necessity of continuation, the nature of the service, the authorisation status of the facility and the relevant exceptions must be investigated together.
Related article: Patient Rights in Health Tourism in Türkiye: A Guide to Malpractice and Compensation for Foreign Patients.
Can emergency intervention be held back until payment is made?
Regulation Article 10/3: priority belongs to medical intervention
Under Article 10/3 of the 2025 Regulation, the admission of foreign patients who apply to receive emergency healthcare services and the necessary intervention must be carried out unconditionally, without restriction and without delay. The procedures for collecting the fee for the service are carried out after emergency intervention and care have been provided. This provision shows that the patient’s ability to pay, the card limit, obtaining pre-authorisation from the insurance company, or a delay in a foreign currency transfer cannot be grounds for postponing emergency intervention.
It should not be confused with a ban on charging
Article 10/2 of the same Regulation states that emergency healthcare services and emergency patient transfers are provided for a fee. For this reason, under the general tourist health regime, the obligation of emergency intervention does not in every case mean free treatment. By whom, according to which tariff and within what scope the fee will be paid is another legal question. Because Article 10/4 contains a separate exception for traffic accidents, emergencies should not all be assessed in a single sentence.
Can a foreign tourist be charged a treatment fee after a traffic accident?
Regulation Article 10/4 and KTK Article 98
The most important special distinction is healthcare services arising from a traffic accident. Article 10/4 of the Regulation provides that the cost of healthcare services to be provided as a result of traffic accidents is to be collected from the SGK under the relevant legislation, regardless of the person’s nationality or social security status, and that in a traffic accident the treatment fee cannot be demanded directly from the person. One of the legal bases of this rule is KTK Article 98. The service to which the rule applies, whether the incident was really a traffic accident, and the document must be tied together by the link of medical causation.
The scope of healthcare services connected with a traffic accident in Türkiye
Besides the initial intervention in the emergency room, the financing regime into which later healthcare services with a medical causal link to the accident fall must be investigated transaction by transaction and date by date. That the hospital invoices the service under a different department or day heading does not by itself remove the connection with the traffic accident.
Services unrelated to the accident or whose connection is disputed
For a service provided for the tourist’s illness independent of the accident, an optional private procedure, or treatment whose scope must be separated according to the evidence, the Article 10/4 result cannot be accepted automatically. The institution demanding the fee must explain the nature of the service and its legal basis; the burdens of proof concerning this are examined on the basis of the concrete demand.
Optional supplementary travel insurance
Article 10/4 of the Regulation also states that, if the person who received emergency healthcare services because of a traffic accident has optional supplementary travel insurance, payment within the policy cover can be collected by invoicing this insurance. It does not follow from this that an unlimited fee can be charged to the patient or that insurance payment is mandatory in every case. The ban on direct demands against the patient and the insurer’s policy obligation must be kept separate from each other.
Later treatment abroad is different
That healthcare services in Türkiye resulting from a traffic accident are covered by the SGK does not mean that all rehabilitation, care or treatment expenses arising after the tourist returns to his or her country will automatically be paid through the same SGK system. For expenses abroad, those responsible for the loss, the insurance policy, international social security agreements and the proof of foreign documents are examined separately.
Related article: Airport Transfer and Tour Bus Accidents in Türkiye: The Rights of a Foreign Tourist and the Liability of the Carrier, Hotel, Agency and Insurer.
By what criteria are the amounts in the hospital’s invoice reviewed?
Whether the service was actually provided
The examination, test, surgery, medication, consumables, bed, care and consultation items in the invoice should be compared with the patient file, order records, laboratory results, operation notes and the discharge document. A service not provided, double invoicing of the same procedure, use of consumables of unspecified quantity, or collection lacking an intelligible statement should be discussed separately.
The scope of application of the price tariff
In assessing a fee, the distinction between private, public and university hospitals, the patient’s status, the tariff in force, the contract, the insurance cover and the date on which the service was provided are decisive. That a fee looks high does not by itself prove unlawfulness; likewise, that the patient has paid does not mean that the invoicing complied with the legislation. The conditions under which the tariff price can be applied to the patient and when the information was given are investigated.
Invoice and statement within health tourism
Article 12 of the 2025 Regulation provides that, for services provided within health tourism, a document showing the itemised statement of services and unit prices is to be issued together with the invoice or sales receipt. Provisions on providing free of charge the specific lists of tests, medications and consumables requested by the patient are in the same article. A request for documents can be supported separately by other invoice, tax, patient rights and record-access obligations that apply to patients outside health tourism.
Item-by-item invoice, free medical documents and intermediary organisation costs
Article 12 of the 2025 Regulation requires that a sales receipt or invoice be issued for services provided within health tourism, and that an itemised statement of the service provided to the patient and the unit prices be attached. On request within this scope, the type/quantity list of medication and consumables for which the healthcare facility has charged the patient, paid laboratory and radiology results and necessary prescriptions are also required to be given free of charge under the conditions in the article. The exception that the originals of forensic-case records are not to be handed over shows that access to a document and the protection of official evidence are separate matters.
An itemised statement of the fees charged by the health tourism intermediary organisation for services such as accommodation, transport, transfer, interpreting and consulting can also be requested separately. This Article 12 regime should not be generalised as if it applied automatically, with the same level of detail, to all tourist health transactions; the scope of the provision concerned and the general provisions on invoices and access to patient records are assessed separately. Whether every amount invoiced in the patient’s name, collected from the insurer and notified to the SGK belongs to the same service item should be cross-checked.
Why does the date on which the emergency ended matter?
The clinical condition is not determined by an administrative label
A patient’s being taken first to the emergency room and then to a ward or intensive care does not by itself lead to the conclusion that “the emergency ended at this hour”. Danger to life, organ functions, complications, continuing surgical necessity and clinical stabilisation should be assessed on the basis of medical documents. It may not be sufficient to prove, merely by a code on the hospital cashier screen, the clinical distinction that changes the charging regime.
Emergency need continuing in separate departments
A patient’s becoming stable in one department may not remove the urgency of another trauma or complication. The periods of service accepted as emergency and not accepted as emergency should be separated on the basis of the procedures and dates. A clinical difference must be established between later planned care and the necessary continuation of the first incident.
What do Court of Cassation decisions show on emergency service fees?
Court of Cassation 3rd Civil Chamber (Yargıtay 3. Hukuk Dairesi), 16.06.2025, E.2024/3412, K.2025/3330
The verified decision concerns a dispute over the periods and procedures for which the fee charged for treatment received at a private hospital by a person seriously injured in a workplace accident could be claimed. In the file, whether the urgency continued across different treatment periods and the verifiability of the reports were debated over a long course of proceedings; the Court of Cassation rejected the appeal objections as to the report and judgment formed after a reversal and upheld the decision. This decision should be used not to carry the same result into every emergency fee dispute of a foreign tourist, but to show the importance of determining the emergency on the basis of medical documents and by department. Because the incident dates from 2015, the fee regime in the decision cannot be equated with the Regulation of 2025.
Legal assessment
In a specific case, the hospital invoice should not be examined alone; the date range to which the service belongs, the medical urgency and the applicable financing regime should be examined together. The expert report must respond to the other side’s important objections. A document in which the patient “agreed to pay” does not by itself legitimise a collection contrary to the mandatory provisions of the law; but depending on its conditions it may matter as regards the scope of the contract and acceptance of paid continuing treatment.
Are patient consent and a payment undertaking the same thing?
Informed medical consent
The Patient Rights Regulation and related legislation regulate the conditions of appropriate information and consent regarding a medical procedure. Consent to the medical risks of treatment is not conclusive evidence that each price item was explained and accepted. The patient’s not knowing Turkish, the need for translation and capacity to make decisions in an emergency should be assessed separately.
Financial undertaking and special contract
The scope of the fee undertaking, its date, the list of services, the information provided by the healthcare facility and conformity with the mandatory tariff are important. The legal effect of a financial undertaking obtained before unconditional emergency intervention is examined within the framework of the protective healthcare rules and contract law. The conclusions “I have nothing left to claim because I paid” or “all prices are lawful because I signed” do not follow automatically.
Which treatment costs does travel insurance cover?
The scope and limits of the policy
A tourist’s travel health insurance or private health policy may provide different limits for emergency treatment, hospital admission, surgical procedures, medical transport, return to the home country, a companion and, where necessary, post-discharge support. Pre-existing illness, alcohol/dangerous sports exclusions, the deductible, geographical scope and the notification period are checked in the policy. The existence of a policy does not remove the hospital’s obligation to invoice.
Distinguishing the assistance company from the insurer
A foreign tourist’s insurance policy may be administered in Türkiye through an assistance/organisation company. The authorisation number, the payment undertaking, the person providing the service and the insurer that actually bears the risk should be determined separately. Whether there is double collection for the same transaction in the payment flow between the hospital, the insurer, the organisation company and the patient should be investigated.
Absence of prior permission and emergencies
In some policies prior approval is sought for planned treatment, while in emergencies there may be a different notification regime. Making emergency medical intervention depend on the insurance company’s processing is different from the insurer’s later review of the policy conditions. After receiving the healthcare service, the tourist may apply to the insurer with the invoice, the discharge summary (epicrisis) and the policy cover.
Related article: Travel Insurance for Foreign Tourists Injured in an Accident on Holiday in Türkiye: Treatment Expenses, Exclusions, Claims to the Insurer and Compensation.
Under what conditions can a refund of an overpaid fee be requested?
Legal basis and payment records
A refund of the fee by the hospital may, depending on the specific case, be assessed on the basis of breach of contract, an unfair term, unjust enrichment, tort, consumer law or collection contrary to the legislation. The success of a refund claim is strengthened not merely by saying that the fee is high, but by explaining why a given procedure was charged unlawfully. The payment receipt, card statement, invoice, price list and health file should be submitted together.
Which losses can be raised in the same action?
The refund of the amount collected in excess, and separate loss and delay/interest claims arising from the irregular charging, depend on their legal conditions. Late or wrong provision of the healthcare service may separately give rise to medical malpractice liability; the material basis and proof of these claims differ from a fee refund. Receiving the same amount twice, as an insurance payment, an SGK collection and a patient refund, must be prevented.
Limitation and the pre-action process
The period to be applied is determined according to the legal source of the claim and the nature of the parties. Whether a private hospital–patient dispute is a consumer transaction, the possibility of insurance arbitration, compulsory mediation and the jurisdiction of the court should be assessed under the specific contract and the relevant statutory provisions. Making an administrative complaint does not by itself suspend limitation of the claim or of the action.
The periods for unjust enrichment and for a contractual refund are not the same
A demand for an unlawful collection may rest on the invalidity of the specific contract or breach of a mandatory prohibition on fees, a defective service, unjust enrichment or tort. TBK Article 82 provides, for a claim of restitution arising from unjust enrichment, a limitation period of two years from knowledge and ten years from the enrichment. By contrast, for contractual claims TBK Article 146 and any special-law periods may apply. The two-year period is not applied mechanically to all refunds of treatment fees.
A reservation of rights on payment, a payment order or undertaking letter, an objection to the invoice, the bank record and the hospital’s notice dates may matter for the legal ground and for default. A complaint to the hospital or the Health Directorate does not by itself suspend contractual or judicial limitation. Before building a single litigation strategy as to a wrong amount and a wrong legal ground, the acceptance document that the patient signed in a foreign language and the financing record should be separated.
Is the route the same against a public hospital and a private hospital?
Private healthcare facility
The court’s jurisdiction is determined by the contractual relationship, the possibility of a consumer transaction, merchant status and the nature of the healthcare service. The accuracy of the invoice, the mandatory pricing rule and the patient’s being informed are assessed. A written objection to the hospital administration, a complaint to the provincial/district health directorate and an appropriate civil action are separate processes.
Public healthcare facility and administrative act
A fee or healthcare service act of a public healthcare institution may give rise to a dispute within administrative law. However, it cannot be said that every commercial or monetary claim of a public hospital will automatically be heard in the administrative courts. The nature of the act as an exercise of public authority, the source of the claim, jurisdiction and application periods must be examined according to the specific case. Provisions such as İYUK (Administrative Procedure Law) Articles 7, 11, 12 and 13 apply only if they genuinely fit the type of act concerned.
The 2026 monetary limit of the consumer arbitration committee and mediation
If the hospital–patient relationship constitutes a consumer transaction under Law No. 6502 in respect of the specific contract, then for consumer disputes below TL 186,000 as of 2026, application to the consumer arbitration committee (tüketici hakem heyeti) comes into play. According to the Ministry of Trade’s 2026 announcement, the arbitration committee has no jurisdiction in consumer disputes of TL 186,000 and above; the route of the consumer court is taken, with the exceptions to mediation as a condition precedent to litigation under Article 73/A of Law No. 6502 also taken into account. The limit requires determining the amount sued for and the legal nature of the transaction; this amount is not a general limit for other years.
An important limit: Not every medical procedure, public hospital or insurance dispute is a consumer arbitration committee case. The nature of the healthcare service as a relationship of public authority or one regulated by a special law, whether the claim is for compensation or for a refund of the service fee, merchant status and the rules of jurisdiction are investigated separately. The procedure and application documents valid for matters the arbitration committee may decide should be prepared using the official information valid in 2026.
How is the hospital’s explanation checked?
The full file of records and documents
- The time of application, the triage code, the first emergency examination and ambulance records.
- Physician notes, nursing observation charts, operation reports, radiology, laboratory and consultation results.
- The discharge summary (epicrisis), prescription, treatment plan, the lists of medication/consumables used and the discharge records.
- Prior information, consent and fee undertaking documents, the hospital price list, the invoice, the itemised statement, and POS/bank payment records.
- The insurance policy, correspondence with the assistance company, authorisation and payment documents and, if any, SGK invoicing records.
The form of the request for the statement
In the written application to the hospital, each service’s date and time, service code, quantity, unit price, total fee, collection date and the person/institution from which it was covered should be requested. Providing only a total without the service details makes the medical and financial review of the dispute harder. In handing over the medical file to the patient or the legal representative, the rules on protection of identity and health data are observed.
Administrative complaint and judicial routes
Applying to the health administration
For allegations concerning non-provision of the service, invoice transparency, the authorisation certificate or breach of healthcare service standards, the relevant complaint channels at the Ministry of Health and the provincial/district health directorates may be considered. Making a complaint does not by itself mean a refund of the payment or preservation of the limitation period for an action. The competent authority must be determined according to the type of the specific administrative act.
Separating the Patient Rights Unit, the Patient Rights Board and the monetary claim
Under Article 42/B of the Patient Rights Regulation, there are Patient Rights Units in healthcare institutions and Patient Rights Boards within the provincial health directorates. Allegations of a violation of patient rights that cannot be resolved at the hospital may be examined by the board within the framework of a written or electronic application (Article 42/C). In the application, the patient’s identity or authority of representation, the date of the service, the name of the unit, the allegation of a violation of patient rights and the necessary documents must be notified in the proper manner. The medical record, the itemised statement of the invoice, the payment document and the hospital’s reply make the application concrete.
A patient rights application is not an enforceable private-law decision on a claim that automatically secures a refund of the fee collected in excess. While the examination by the unit or the board matters as to violation of a patient right, corrective action and administrative guidance, the refund claim is separately directed to the hospital, to the appropriate consumer dispute authority or to the competent court. A complaint to the provincial health directorate must not be read as automatically suspending the periods for insurance arbitration, the consumer arbitration committee, compulsory mediation or filing an action. Personal health documents should be shared only to the extent necessary and through secure channels.
Claim to the insurance company and arbitration
If the subject of the dispute arises from the policy cover, the law governing the policy, the insurer’s decision process and the possibility of arbitration within the framework of the Insurance Law No. 5684 may be assessed. Separate compensation claims arising from traffic insurance must not be confused with the prior-application regime in KTK Article 97.
Action for refund and compensation
In a judicial claim, it is important to state which invoice and which service item are unlawful one by one, the payment flow and the type of claim, and, where necessary, to request an expert examination in the field of medical and health legislation/financing. No automatic refund follows merely from the allegation that the price was collected in foreign currency.
Separating invoice review from direct refund and administrative sanction claims
An administrative complaint to the Ministry of Health or the health directorate about a hospital’s price may lead to administrative inspection or sanction of the healthcare facility; this process does not constitute an automatic and direct provision for a refund of money to the tourist’s account. For a refund, a written application to the hospital and, where necessary, determination of the route of legal dispute are required. For a monetary claim arising from a public service, İYUK Articles 7 and 11–13 and other special provisions are examined, depending on the nature of the act.
Payment of the fee by the insurer and the patient’s paying out of his or her own pocket are separated. The insurer’s right of recourse, the patient’s refund claim and the SGK’s invoicing inspection are not the same claim; prevention of double recovery and determination of standing to sue must be carried out.
The other side’s defences and how they are checked
The “the emergency had ended” defence
The hospital may argue that, after the emergency intervention was completed, optional or planned treatment was continuing. The tourist, in turn, may show that the urgency continued with a dated discharge summary, tests and specialist reports demonstrating continuing trauma, complications and necessary clinical intervention. Which date range falls under which medical regime must be explained in the expert report.
The “the patient accepted the price” defence
The payment made or the signature given by the patient matters in discussing the contractual fee; but where there is an applicable mandatory prohibition, an unlawful fee does not arise from a signature alone. On the other hand, for services that can be freely priced and for which full information was given, a legal consequence in the hospital’s favour may arise.
The “the insurance did not pay” defence
The insurance company’s refusal to pay does not automatically justify all the hospital’s claims against the patient; the fee contract between the patient and the hospital and the insurance policy are assessed separately. The company’s grounds for refusal, the material scope and the pre-authorisation conditions must be documented.
What rights does a foreign tourist retain when returning abroad?
A foreign tourist’s leaving the country does not by itself prevent him or her from making a compensation or refund claim in Türkiye through proper representation and submission of documents. However, the concrete rules on a document in a foreign language, a consular power of attorney, translation, apostille/certification, payment and currency conversion should be examined. Hospital records should be requested and the dispute notified at an early stage; private health data must not be put into circulation through public channels.
MÖHUK Article 48: examining the security position of a foreign tourist bringing an action in Türkiye
Article 48 of Law No. 5718 (MÖHUK) regulates security for costs and for the other side’s losses, to be determined by the court, for foreign natural and legal persons who bring a civil action, intervene in an action or start enforcement proceedings in Türkiye. However, without investigating the reciprocity exemption in Article 48/2 and applicable legal aid or security-exemption treaties to which Türkiye is a party, it cannot be asserted that a foreign patient will necessarily deposit security. The tourist’s nationality, capacity as a party, type of action and any contract terms are the inputs of this examination.
The judicial security under MÖHUK Article 48 should not be read as an automatic application fee for an administrative complaint to a patient rights unit or an application to the consumer arbitration committee. That the claim arises from a healthcare services contract, unjust enrichment, insurance or a public service relationship may affect the assessment of jurisdiction, venue, prior application and security. That the foreigner has returned to his or her country does not by itself end the monetary refund claim; power of attorney, translation, apostille and the proper submission of documents are completed separately.
Decision matrix in a fee dispute
| Event / service | Main rule or possibility | Document to examine |
|---|---|---|
| Emergency application due to a tourist’s sudden illness | Regulation Article 10/2–3: the fee regime and intervention without delay are separate | Emergency records, timeline, invoice |
| Treatment connected with a traffic accident in Türkiye | Regulation Article 10/4 and KTK Article 98: SGK financing; ban on direct demand against the patient | Accident report, medical causation, SGK/hospital statement |
| Surgery within planned health tourism | Regulation Articles 11–12; authorisation certificate and contract separately | Service contract, tariff, consent, invoice |
| Continuing treatment after an emergency | Medical urgency and the authorisation/price regime are determined separately | Department-level discharge summary, specialist report |
| Refusal decision of foreign travel insurance | Policy scope, exclusions and notification conditions | Policy, refusal letter, authorisation |
| Double collection or invoicing outside the service | Claim of collection without legal basis and conditions of refund | Itemised statement of services and payments |
To which institution, and with which document, is an application for a fee refund made?
| Type of dispute | Possible claim/application | Proof and limitation |
|---|---|---|
| Payment as a precondition in the emergency room within the Regulation | Complaint to the health administration, the timeline of the service; separate refund request | Time of first application, the moment payment was demanded, intervention record |
| Fee charged to the person for SGK-covered treatment in a traffic accident in Türkiye | SGK/hospital invoicing inspection and an appropriate refund route | Link to the accident, SGK record, invoice/payment receipt |
| Unexplained additional fee in a health tourism service | Written statement request and refund application to the hospital; appropriate consumer route | Applicability of Regulation Articles 11–12, consent, price list |
| Refund of an amount under TL 186,000 of a consumer nature in 2026 | Consumer arbitration committee | That the specific transaction falls under Law No. 6502 and the value of the dispute |
| Fee act of an administrative nature by a public hospital | Administrative application/judicial route | Administrative nature of the act, notification and special time limit |
| Refusal of authorisation under an insurance policy | Application to the insurer and, if appropriate, insurance arbitration | Policy, grounds for refusal, required documents and application period |
This table does not determine each application as a single directly applicable route; the competent authority, the statutory period, the condition precedent to action and the standing of the right-holder must be finalised case by case.
Conclusion
In a dispute over a foreign tourist’s high hospital invoice, the right question is not only “How much fee was demanded?”; it is “Which medical service was provided on which date, in which legal status, under which price regime and to be collected from whom?” While prohibiting emergency intervention being made conditional on payment, the 2025 Regulation distinguishes charging for general emergency services from the SGK financing specific to traffic accidents. Refund and compensation claims can be reliably assessed only on the basis of this distinction, the medical records, the policy and the itemised invoice.
Frequently Asked Questions
Is the emergency room free for a foreign tourist in Türkiye?
Not in every case. Article 10/2 of the 2025 Regulation states that emergency services are in general provided for a fee; Article 10/3 provides that the necessary emergency intervention cannot be delayed.
Can the hospital make payment of a fee a precondition first?
Not as regards emergency intervention. Under Regulation Article 10/3, payment procedures must be carried out after the necessary emergency intervention and care.
Will a foreign tourist injured in a traffic accident be asked for a fee?
Regulation Article 10/4 provides for the collection of in-scope traffic accident healthcare services from the SGK and that no direct treatment fee can be demanded from the person. The scope of the service and its link to the accident must be documented.
Is the whole invoice cancelled because the hospital demanded a high fee?
No. Each item must be reviewed for the existence of the service, the applicable price regime and the contract terms.
Can I ask for an itemised statement of the invoice?
Yes; it is possible to ask for an itemised statement under the applicable health tourism and general invoice/record regulations. Article 12 of the 2025 Regulation expressly regulates this obligation within health tourism.
As of which date is the emergency regarded as having ended?
This is a medical assessment. To separate emergency from continuing service, the department, the clinical condition, the discharge summary and, where necessary, an expert examination are needed.
If I have travel insurance, can the hospital not ask for any payment?
No. The scope of the policy, the insurer’s payment obligation and the contract made with the hospital are examined together. The traffic accident exception is assessed separately.
Can I ask for a refund after paying the treatment fee?
Yes, if the conditions exist. The specific items and payment documents of the collection contrary to the legislation or made twice must be shown.
Is an action brought in the same court against a public and a private hospital?
Not always. The administrative or private-law nature of the act, the capacity of the parties and the subject of the claim determine the competent court.
Can I claim a refund in Türkiye after returning to my country?
Yes; the route of claim can be assessed with appropriate power of attorney and document conditions. Jurisdiction, time limits, the legal basis and the conditions for proving foreign documents must be examined separately.
Up to what amount can the consumer arbitration committee be applied to in 2026 for a hospital invoice?
If the dispute is of the nature of a consumer transaction, application to the consumer arbitration committee comes into play for claims below TL 186,000 in 2026. For disputes at or above this amount, the appropriate consumer judicial route and the conditions of mediation as a condition precedent to litigation are assessed.
Can the hospital continue the tourist’s post-emergency treatment at a facility without a health tourism authorisation certificate?
Article 10/1 of the Regulation of 26 April 2025 states that healthcare services of a continuing nature after a sudden illness or emergency cannot be provided in a facility that has no authorisation certificate. The specific treatment, the authority of the facility and the relevant scope exceptions are examined separately.
Does the two-year period apply in every case to a refund claim after paying a fee at a hospital?
No. The two years from knowledge and ten years from occurrence in TBK Article 82 is the limitation period for an unjust enrichment claim. Different periods may arise under a service contract, consumer law or other legal grounds.
Do the fee rules apply in the same way in a forensic case brought in by law enforcement?
Article 2/2-(ğ) of the 2025 Regulation leaves foreigners who receive emergency healthcare services after being brought in by law enforcement as a forensic case outside its own scope. This does not give any authority to refuse medical intervention or to charge arbitrarily; the general health and traffic/SGK rules to be applied are determined separately.
If I apply to the patient rights board, must the hospital refund the fee I paid directly?
No. The patient rights mechanism may examine allegations of a service or rights violation; for an enforceable result on a claim/refund, an application to the hospital, an appropriate consumer route or the competent judicial authority must be assessed separately.
Can a foreign person outside the scope of the Regulation receive a paid health tourism service?
Yes, under the conditions of Regulation Article 2/3, if the person has of his or her own will chosen a paid international health tourism service and undertaken to pay. This does not mean that the mandatory rights specific to emergency intervention and traffic accidents are removed.
Must a foreign tourist who has returned abroad provide security when bringing a refund action?
The question of security may arise under MÖHUK Article 48; however, exemptions based on reciprocity and international agreements must be investigated. Security must not be confused with an administrative patient rights complaint.
Sources and legal bases
- Official Gazette (Resmî Gazete) of 26.04.2025, No. 32882, Regulation on International Health Tourism and the Health of Tourists, in particular Articles 2, 4, 6, 10–12, 15–16 and the provisional provisions. resmigazete.gov.tr
- Highway Traffic Law (Karayolları Trafik Kanunu) No. 2918, Article 98. uab.gov.tr
- Court of Cassation 3rd Civil Chamber, 16.06.2025, E.2024/3412, K.2025/3330, full text. app.dejure.ai
- Basic Law on Health Services (Sağlık Hizmetleri Temel Kanunu) No. 3359 and Law No. 1219; the Patient Rights Regulation (Hasta Hakları Yönetmeliği) published in Official Gazette No. 23420.
- Consumer Protection Law (Tüketicinin Korunması Hakkında Kanun) No. 6502; Turkish Code of Obligations (Türk Borçlar Kanunu) No. 6098; Insurance Law (Sigortacılık Kanunu) No. 5684 (the applicable provisions must be determined separately according to the claim and the capacity of the parties).
- Ministry of Trade, Information on Consumer Arbitration Committees (22.01.2026; 2026 monetary jurisdiction limit). tuketici.ticaret.gov.tr
- Turkish Code of Obligations No. 6098, in particular Articles 77–82 and 146 (refund and limitation). mevzuat.adalet.gov.tr
- Consumer Protection Law No. 6502, Articles 68, 73/A (according to the specific consumer transactions). mevzuat.adalet.gov.tr
- Official Gazette of 26.04.2025, No. 32882, Regulation on International Health Tourism and the Health of Tourists, Article 2/2–3. resmigazete.gov.tr
- Patient Rights Regulation, Articles 42/B–42/C and the Ministry of Health’s patient rights practice. tutdh.saglik.gov.tr
- Law No. 5718 on Private International and Procedural Law (Milletlerarası Özel Hukuk ve Usul Hukuku Hakkında Kanun), Article 48. mevzuat.adalet.gov.tr