What does the travel health insurance of a foreign tourist coming to Türkiye cover?
Travel health insurance is one of the types of private insurance taken out against the health risks a person traveling to Türkiye from abroad may encounter during the trip. Under the General Conditions, the insurer’s liability is limited to expenses covered by the policy that arise from an accident or an illness not attributable to a pre-existing condition occurring within the policy’s period of validity.
One of the first points a foreign tourist should check is the geographic scope. Türkiye must be within the country or region for which coverage is given in the policy. If the policy was issued after entry into Türkiye, whether a policy that came into force after the trip began covers an accident that has already occurred must be examined separately. In incoming travel policies, entry and exit dates, passport records and the policy term are particularly important.
Under the General Conditions of Travel Health Insurance, the minimum coverages are essentially the following:
- Medical treatment expenses for sudden indispositions and illnesses.
- Hospital, surgery, treatment and doctor-prescribed medication expenses.
- Travel or transfer of the insured to the nearest suitable healthcare facility.
- Transfer to another suitable healthcare facility if the necessary equipment is not available at the facility where the insured is.
- Following inpatient treatment, transfer of an insured who cannot use the normal means of travel to the place of residence by a suitable vehicle on the doctor’s decision.
- In the event of death resulting from an illness or injury covered by the policy, transport of the remains to the requested address.
These are minimum coverages. Additional protections such as companion transport, extra hotel accommodation, baggage, trip cancellation, flight change, liability coverage or personal accident coverage can be claimed only if they are separately included in the policy or the special conditions.
The basic questions that determine whether a treatment expense is covered by insurance
After an accident, having only the invoice may not be enough for payment. The following questions must be answered together with regard to the insurer’s liability:
- Did the incident occur within the policy period?
- Is Türkiye within the geographic scope of the policy?
- Is the incident an “accident” or a sudden illness within the scope of the policy?
- Is the treatment medically necessary, and is there a causal link with the incident?
- Are the treatment and medication expenses within the coverage limits?
- Is there a deductible, co-payment or special limit?
- Does the incident fall within an exclusion in the general or special conditions?
- Did the insured fulfill the notification and document submission obligations?
- Could the insurer’s or assistance company’s prior approval procedure have been applied given the urgency of the incident?
Each of these questions may lead to a different result in the same file. For example, a tourist taken urgently to hospital by ambulance who could not obtain prior approval from the assistance center at the time of the incident cannot be treated in the same way as one who never notified the insurer about a planned treatment.
When and how should the insurer be notified at the time of the accident?
Under Article 1446 of the Turkish Commercial Code, the policyholder must notify the insurer without delay once they learn that the risk has materialized. Late notification is not, on its own, a rule that leads to automatic rejection; factors such as whether the delay increased the compensation payable and the seriousness of the fault are assessed separately.
The General Conditions of Travel Health Insurance also provide that the insured must notify the company or the assistance person/company “as soon as possible.” If the insurer cannot be reached, the insured may go to the nearest emergency healthcare facility; they must then communicate to the company information on the services received and the situation.
However, some special policy conditions may contain separately regulated notification periods such as 24 hours, 48 hours or 30 days. The applicability of such a provision in the specific case must be examined together with how the provision was communicated to the insured, the insured’s urgent medical condition, the mandatory or protective provisions of the Turkish Commercial Code and whether the delay actually worsened the insurer’s position.
Which documents should be submitted to the insurer?
In travel health insurance, the chain of documents is the most important part of the dispute. If possible, the following documents should be preserved:
- The policy and the general/special conditions attached to the policy.
- Passport and Türkiye entry-exit records.
- Records showing the date and place of the incident.
- Emergency room records, discharge summary, doctor’s report and prescriptions.
- Laboratory, imaging and other medical tests.
- Invoices for hospital, ambulance, medication, medical devices and rehabilitation.
- Payment receipts and credit card statements.
- Telephone, email and message correspondence with the insurer or assistance company.
- Claim file number, rejection letter and the grounds for rejection.
- The incident report relating to the hotel or tour operator and any accident records.
In its decision of 23.10.2019, No. K.2019/86638, the Insurance Arbitration Commission (Sigorta Tahkim Komisyonu) upheld the claim in a dispute over payment of health expenses incurred for bronchitis that arose during travel, finding that the insured had obtained the documents that could normally be obtained, that the ground of “no doctor’s report was submitted” is not directly regulated as an exclusion in the General Conditions, and that the insured had not been adequately informed of this document requirement. This decision is important in showing that not every missing document automatically means lack of coverage.
Why are pre-existing conditions one of the most common grounds for rejection?
Under the General Conditions of Travel Health Insurance, medical conditions determined by an authorized doctor to have existed before the policy start date, and acute crises related to them, are generally excluded from coverage. The policy’s special conditions may regulate this area in more detail.
The decisive issue here is not only “did the insured have an illness before?” Whether the treatment claimed has a causal link with the earlier illness must also be examined. For example, treatment that arises as a direct complication, during travel, of an old chronic illness cannot be treated in the same way as a completely independent traumatic accident.
In its decision of 24.03.2025, No. K.2025/144260, the Insurance Arbitration Commission referred to expert examination the relationship between a pulmonary embolism that developed during travel and the insured’s lung cancer known before the policy; in the specific file it accepted that there was a causal link with the earlier condition and rejected the application. This decision shows that the “pre-existing condition” exclusion must be assessed not in the abstract but through the medical causal link.
Dangerous sports and holiday activities may fall outside insurance
The General Conditions of Travel Health Insurance list certain sports and activities among the general exclusions. Races, rallies, hunting activities, deep diving, horse riding, mountaineering, parachuting, paragliding and, in general, sports or entertainment activities known to be dangerous may be assessed within this scope. Some risks, such as skiing, may be covered by a special condition.
For this reason, in a file where the tourist took part in a jeep safari, ATV, buggy, jet ski, parasailing, scuba diving or a similar activity, it is not enough to say only “an accident occurred.” Whether the policy covers the relevant activity, whether there is additional sports coverage and the special exclusions must be checked.
This area is directly connected with our earlier tourism articles: the compensation liability arising from an operator’s fault and the tourist’s claim under their own travel insurance are separate legal relationships. The rejection of one does not by itself remove the other.
Alcohol use does not automatically mean lack of coverage in every incident
The alcohol exclusion in the General Conditions is a provision covering illnesses or pathological conditions arising from voluntary consumption of alcohol, drugs or similar substances other than under a medical prescription. For this reason, the fact that the insured consumed alcohol before the incident should not, on its own, be interpreted as an automatic ground for rejection in every accident.
In the specific case, whether there is a causal link between alcohol use and the injury, how the policy’s special condition is drafted and any medical findings must be assessed together. The insurer must set out its grounds for rejection in connection with the policy and the incident, not merely on assumption.
What is the consequence of being unable to obtain approval from the assistance company in an emergency?
Travel health policies in practice often involve an assistance company. Hospital referral, payment guarantee, transfer organization and similar procedures may be handled through the assistance company.
However, the General Conditions expressly allow the insured to go to the nearest emergency healthcare facility if the company cannot be reached. For this reason, in a life-threatening or urgent situation, the ground that “provision approval was not obtained first” may not be sufficient on its own. Urgent medical necessity, whether the insured was in a position to communicate and the notification made afterwards are assessed together.
The outcome may be different for planned treatment, follow-up examinations or procedures known before the trip.
What is the first step if the insurance company rejects the claim?
Merely stating “it is outside the scope of the policy” in the rejection letter is not a sufficient explanation. If possible, the insured should request the following in writing:
- The policy and article number on which the rejection decision is based.
- Whether the general conditions or the special conditions were applied.
- If there is a medical ground, the document on which this assessment is based.
- If a pre-existing condition is alleged, an explanation of the causal link.
- If a document is missing, which document is required and why.
- If a coverage limit, deductible or ratio is applied, the calculation breakdown.
- If a partial payment has been made in the file, which items were accepted.
An application to the insurance institution must be made before applying to the Insurance Arbitration Commission. If the insurance institution’s final answer does not satisfy the claim, or if, as a rule, no answer is given within 15 business days, an application to the Commission may come into play, provided the other conditions are also met.
Can a foreign tourist apply to the Insurance Arbitration Commission?
Yes. A person who derives a benefit from the insurance contract may apply to the Insurance Arbitration Commission if they meet the necessary conditions. However, because under the Commission’s current practice the online application requiring identity verification via e-Devlet cannot be used by foreign nationals, foreign nationals must apply in person.
If the application is to be made through a representative, the power of attorney must contain the special authority required for alternative dispute resolution routes or for applying directly to the Insurance Arbitration Commission.
An application to the Commission may not be possible for the same dispute that has previously been taken to a court, to HMK arbitration (arbitration under the Code of Civil Procedure) or to a consumer arbitration committee. For this reason, before choosing the application route, one should check to which forum the dispute was previously taken.
Why do the monetary limits matter in Insurance Arbitration Commission decisions?
According to the current information published by the Commission as of 2026, arbitrator decisions on disputes up to TL 35,000 are final; for decisions of TL 35,000 and above, an objection before the Commission is available; and for disputes exceeding TL 383,000, an appeal against the decision of the objection arbitration panel may come into play.
Because these limits can change every year, the current amounts should be checked separately on the date of application. If the claim is in foreign currency, the Central Bank of the Republic of Türkiye (TCMB) foreign exchange selling rate on the application date is used to calculate the Commission’s application fee.
Does an insurance payment remove the claim for compensation against the hotel or tour operator?
No, but the same damage cannot be recovered twice. As regards the part of health insurance that covers actual treatment expenses, Article 1519/2 of the Turkish Commercial Code allows the provisions on indemnity insurance to apply. For the actual items of loss paid by the insurer, subrogation/recourse against the liable third party may come into play, if the conditions are met.
For example, if the travel insurer has fully paid EUR 5,000 in treatment expenses arising from the hotel’s fault, the tourist cannot recover the same EUR 5,000 a second time from the hotel as a “treatment expense.” On the other hand, deductibles not covered by the insurance, amounts exceeding limits, loss of income or other pecuniary losses, and claims for non-pecuniary damages may be assessed under separate legal bases.
The insurer’s subrogation also does not mean that it takes over all of the insured’s personal rights. Subrogation has effect to the extent of the loss paid and the applicable insurance provisions.
What happens if there is more than one travel or health insurance?
The General Conditions of Travel Health Insurance provide that if other insurance has been taken out against the same risk for the same period, this must be notified to the insurers. Where there is more than one insurance, the same treatment expense cannot be recovered twice.
Travel insurance linked to a credit card, a group policy offered by the tour operator and the person’s own travel health policy may all exist in the same incident. In that case, the definition of the insured, geographic scope, limits, deductibles and “other insurance” provisions of each policy must be compared separately.
How should health documents issued in a foreign country be used in Türkiye?
Hospital records, reports and invoices drawn up in a foreign language should be submitted in a form that the insurance company or the dispute resolution body can understand. A simple translation may be sufficient in the insurer’s own process, whereas a Turkish translation may be requested at the judicial or arbitration stage.
It cannot be said that an apostille is automatically required for every foreign health document. Whether the document is a private or an official document, the purpose for which it is submitted and the procedural rules of the relevant body must be assessed separately.
In the Insurance Arbitration Commission’s decision No. K.2019/86638, the translation of documents in a foreign language was also raised; however, the decision concluded that the clinical and payment documents submitted by the insured were sufficient for assessing coverage in the specific file.
Travel insurance and hotel liability insurance are not the same thing
A foreign tourist’s own travel health insurance is their personal insurance contract. A hotel’s liability insurance, on the other hand, may be a separate contract covering the hotel’s legal liability toward third parties.
In a hotel accident, the following insurance relationships may exist at the same time:
- The tourist’s travel health insurance.
- The tourist’s personal accident coverage.
- The hotel’s third-party liability insurance.
- The activity operator’s liability insurance.
- Compulsory/optional insurance relating to vehicles or watercraft.
- Group or assistance coverages arranged as part of the package tour.
Each policy may cover a different item of loss, with different limits and exclusions. When preparing the claim file, all the policies must be mapped together.
Which documents should a foreign tourist collect before leaving Türkiye?
To prevent loss of rights, if possible, the following records should be obtained:
- Hospital discharge summary and emergency room records.
- Doctor’s report, prescriptions and test results.
- Itemized invoices and payment receipts.
- Ambulance or transfer documents.
- The incident report of the hotel or tour operator.
- Photographs and videos of the accident site.
- Contact details of witnesses.
- A copy of the policy, certificate and special conditions.
- The record number of conversations with the assistance company.
- The date of, and proof of, the claim notification made to the insurer.
- Passport entry-exit records and travel documents.
Expenses and health records should also be kept in an orderly manner for physiotherapy, follow-up and additional procedures continuing after returning to one’s country.
Related articles: Injury at a Hotel Mini Club or Children’s Activity: Supervision, Handover and the Operator’s Liability; The Rights of a Foreign Tourist Renting a Car on Holiday in Türkiye After an Accident or Damage: Rental Company, Insurance, Deposit and Compensation; Accidents on Jeep Safari, ATV and Buggy Tours: The Liability of the Tour Organizer, Vehicle Operator and Guide
Conclusion
For a foreign tourist who has had an accident on holiday in Türkiye, the review of travel insurance cannot be carried out by looking only at the policy limit. The type of coverage, geographic scope, date of the incident, the causal link between the accident and the treatment, general and special exclusions, the notification process and the documents submitted must be assessed together.
Grounds for rejection such as a pre-existing condition, a dangerous sport or late notification should not be accepted automatically either. It must be investigated whether the ground for rejection rests on an express provision of the policy, on the real nature of the incident and on applicable Turkish insurance law.
An insurer’s payment, in turn, does not remove all claims for compensation against the hotel, the tour operator or other liable persons. The rule against recovering the same loss twice, the insurer’s subrogation and the items of loss falling outside the insurance coverage must be addressed together.
Frequently Asked Questions
Does travel health insurance cover private hospital expenses in Türkiye?
It may, if the policy covers Türkiye and the date of the incident, and the expense arises from a sudden illness or injury within the coverage. The limit, deductible, contracted institutions and special conditions are checked separately.
If I have a pre-existing condition, will I receive no payment at all?
Not always. The causal link between the treatment claimed and the earlier illness is important. The policy’s special condition is also examined separately.
If I drank alcohol before the accident, will the insurance automatically not pay?
It is not an automatic result. The scope of the exclusion in the policy and the connection between alcohol use and the incident/damage must be assessed.
Is a jet ski, parasailing or ATV accident covered by travel health insurance?
It varies by policy. The general conditions contain exclusions for dangerous sports and entertainment activities; if there is additional coverage, the result may be different.
If I could not call the insurance company at the time of the accident, do I lose my rights?
Loss of rights does not arise in every case on this ground alone. The emergency, the time of notification, the effect of the delay and the policy’s special condition are assessed together.
What should I do if the invoices are sent to me months later?
It is important to notify the insurer of the incident itself as soon as possible, to explain that the invoices will arrive later and to keep all correspondence.
Can the insurer refuse to pay because a doctor’s report is missing?
Whether the document is really necessary, whether the insured was informed about it and whether the other available documents prove the incident are examined in the specific file.
Can a foreign tourist apply to the Insurance Arbitration Commission?
Yes. However, under the Commission’s current practice, foreign-national applicants must apply in person.
Is it mandatory to apply to the insurance company before going to arbitration?
Yes. As a rule, a written application must first be made to the insurance institution; a negative final answer must be received or, in other branches, no answer must have been given within 15 business days.
If the travel insurance pays, can I also claim compensation from the hotel?
For losses not covered by the insurance, the claim may continue if the conditions are met; however, the same treatment expense cannot be recovered twice.
Does travel health insurance pay non-pecuniary damages?
The minimum health coverage of standard travel health insurance is not non-pecuniary damages. Non-pecuniary harm may be assessed on a separate legal basis against the person or operator responsible for the accident.
Are a companion’s hotel and flight expenses paid by the insurance?
Only if there is such an additional coverage in the policy or special conditions. Companion expenses are not among the minimum coverages in every case.
If treatment continues after I leave Türkiye, are the expenses covered?
It depends on the policy’s term and geographic scope, the causal link of the treatment with the incident and the special conditions. Expenses incurred in a country outside the policy or after the term has expired are not automatically covered.
What should I look out for in the insurance company’s rejection letter?
The general/special condition on which the rejection decision is based, the article number, the medical ground, the missing document, the limit and the calculation method should be clear.
Which documents must I keep?
The policy, passport, discharge summary, report, prescription, invoice, payment receipt, correspondence with the insurer, incident report and records showing the accident site are the basic documents.
Sources and legal bases
- Law No. 6102 Turkish Commercial Code, in particular Articles 1423, 1446, 1472 and 1519.
- Law No. 5684 on Insurance, in particular Article 30.
- General Conditions of Travel Health Insurance, effective 1 March 2006.
- Insurance Arbitration Commission, “How to Apply?”, “Application Form”, “Documents Required During the Application” and current monetary limit notices.
- Insurance Arbitration Commission, K.2019/86638, dated 23.10.2019.
- Insurance Arbitration Commission, K.2025/144260, dated 24.03.2025.
- Insurance and Private Pension Regulation and Supervision Agency (SEDDK), Insurance General Conditions page.
- Insurance Association of Türkiye (Türkiye Sigorta Birliği), General Conditions of Travel Health Insurance and the texts on insurance law of the Turkish Commercial Code.