What is a qualifying foreign direct investment?
Law No. 4875 regulates the ability of foreign investors to set up companies, branches and similar structures in Türkiye. For the work permit, a special facilitation comes into play only for an investment that meets the criteria in the legislation and for its key personnel. Having a foreign partner, or belonging to an international group, is not sufficient on its own.
The 2026 criteria
According to the values announced by the Ministry of Labor and Social Security for 2026, at least one of the following alternatives is required: [3]
| Criterion | 2026 condition |
|---|---|
| Turnover | Total capital share of the foreign partners of at least TL 21,946,007 and turnover in the last year of at least TL 1,648,938,600 |
| Exports | The same capital threshold and exports in the last year of at least USD 1 million |
| Employment | The same capital threshold and at least 250 employees registered with the SGK in the last year |
| Fixed investment | Projected minimum fixed investment amount of at least TL 522,163,890 |
| Multinational structure | The parent company having a direct investment in at least one country outside its country of headquarters |
These amounts change from year to year. In the application, the balance sheet, income statement, export, SGK, investment and group company documents must be submitted for the current period and for the correct legal entity.
How should group data be used?
Turnover or the number of employees belonging to another company of the group cannot be used as though they belonged to the applicant Turkish company. If a consolidated statement is used, the group structure and the applicant company's share must be explained.
Who is key personnel?
A person with senior management or executive authority
Persons who manage the whole or a part of the company, who influence personnel decisions, who supervise technical or administrative staff and who take senior management decisions may be regarded as key personnel. The title of general manager, manager, board member or director is not sufficient on its own; the trade registry, signing authority, management decision, organization chart and the actual duty are examined together.
A specialist with knowledge essential to the company
Specialists with knowledge essential to the company's products, production techniques, software, devices, research method or management may also be covered. Besides the diploma and the CV, a direct link must be established between the foreigner's knowledge and the project in Türkiye.
General expertise versus company-specific knowledge
Being experienced in the sector is not sufficient on its own. For an engineer who will set up the parent company's special production line, a specialist who will adapt the group's own software or a person who will manage the international operation, the project, the assignment and a technical explanation should be submitted.
Liaison office representative
A work permit comes into question for at most one foreigner authorized by the parent company in a liaison office holding a valid activity permit. The Ministry's list of documents asks for the activity permit, the parent company's authorization document and bank records showing the foreign currency brought in from abroad in the last year. Because a liaison office cannot engage in commercial activity, the job description should be consistent with representation, research and coordination. [4]
The five-Turkish-employee requirement for the first key personnel
According to the Ministry's explanation, the general employment criterion is not applied to the first foreigner in a key personnel position at an enterprise that meets the qualifying investment criteria. This facilitation does not automatically extend to all foreigners and to later applications. The salary, the special professional requirements, the documents and the consistency of the duty continue to apply. [5]
The salary criterion
For senior executive, manager and specialist duties, the salary coefficients on the date of application are taken into account. The salary must be consistent with the contract, the application and the SGK notification. A high salary does not on its own prove key personnel status.
Are a company partner and key personnel the same thing?
No. Partnership shows a capital relationship; key personnel shows a management or critical specialist role. A passive partner is not regarded as key personnel merely because they are a shareholder. For a managing partner or a board member, the partnership, the power of representation and the actual duty are assessed together.
The application file
| Document group | Examples | What is proved |
|---|---|---|
| Investment status | Balance sheet, turnover, export, SGK, investment and group documents | That one of the 2026 criteria is met |
| Management authority | Trade registry, board resolution, signing authority, organization chart | Senior management role |
| Critical expertise | Diploma, employment records, project and technical explanation | That the knowledge is essential to the company |
| Liaison office | Activity permit, authorization document, foreign currency transfer | The special requirements for the office and the foreigner |
| Employment relationship | Contract, salary, duty, workplace | Scope of the permit |
The title, salary, duty, signing authority and workplace in the documents must all tell the same legal story.
Change of duty or employer
The permit is issued for a particular employer and duty. A foreigner's move to another company within the same group, a company merger, or a change of duty or authority may require a new application or an examination of the scope of the permit. Belonging to "the same holding" does not on its own mean that the employer legal entity is the same.
Refusal and objection
A refusal may rest on grounds such as failure to prove the investment criteria, the foreigner's key personnel status remaining abstract, inconsistency of salary or duty, wrong documents or a special professional restriction. An objection may be filed through e-İzin within thirty days of notification. The objection should be prepared with financial, commercial and technical documents that respond directly to the grounds of refusal. [6]
Related articles: Work Permits in Türkiye; Foreign Work Permits in R&D, Design and Technology Development Zones.
Conclusion
A key personnel work permit is not an automatic foreign investment facilitation. That the company meets one of the 2026 criteria, and that the foreigner has a management or critical expertise role, must be shown together with the financial records, trade registry, authority resolution, job description, salary and project documents.
Frequently Asked Questions
Is every company with a foreign partner treated as a special investment?
No. At least one of the official criteria must be met.
Is the title of general manager sufficient?
No. Real management, supervisory or personnel authority must be documented.
Are five Turkish employees required for the first key personnel?
According to the current explanation, the general employment criterion is not applied to the first key personnel at an enterprise that meets the criteria.
How many foreigners can work at a liaison office?
Under the special regulation, a work permit comes into question for at most one authorized foreigner.
Within what time limit can a refusal decision be objected to?
The objection is filed through e-İzin within thirty days of notification.
Sources
- Law No. 6735 on International Labor Force (Uluslararası İşgücü Kanunu): resmigazete.gov.tr
- Law No. 4875 on Foreign Direct Investment (Doğrudan Yabancı Yatırımlar Kanunu): goc.gov.tr
- ÇSGB, Foreign Direct Investments and 2026 values (Doğrudan Yabancı Yatırımlar): csgb.gov.tr
- ÇSGB, Documents Required in the Work Permit Evaluation Process (Çalışma İzni Değerlendirme Sürecinde Gerekli Belgeler): csgb.gov.tr
- ÇSGB, Work Permit Evaluation Criteria (Çalışma İzni Değerlendirme Kriterleri): csgb.gov.tr
- ÇSGB, Work Permit Frequently Asked Questions (Çalışma İzni Sık Sorulan Sorular): csgb.gov.tr