Türkiye CBI 50-Job Creation: Requirements and Regulations

The Türkiye CBI 50-job creation option is one of four qualifying investment routes under the citizenship by investment programme of Türkiye. This option requires investors to establish or acquire a business in Türkiye and create official employment for a minimum of 50 Turkish citizens — maintained continuously for 3 years and fully registered with the Social Security Institution (SGK).

This is the least common of the four options for the Türkiye Citizenship by Investment programme – accounting for only about 1-2% of all applications approved each year. The reason is the requirement for actual business operations, high legal complexity, and greater financial risk compared to the other three passive options. However, for investors who already have a business plan in Türkiye or own a multinational company looking to expand into this market, the job creation option can offer significant long-term benefits.

Legal framework for the Türkiye CBI 50-employee job creation route

The legal basis for this option is found in Article 20 of the Regulation on the Implementation of the Turkish Citizenship Law No. 5901 and Law No. 6735 on International Workforce. These two documents clearly define the threshold condition of 50 full-time jobs, the requirement for Turkish citizenship, and the 3-year continuous maintenance period.

The implementing and certifying authority is the Turkish Ministry of Labour and Social Security (Çalışma ve Sosyal Güvenlik Bakanlığı – MLSS) through the General Directorate of International Workforce (Uluslararası İşgücü Genel Müdürlüğü). According to announcements from the Turkish Ministry of Labour and Social Security, investors must submit an application for a Certificate of Conformity to the Ministry – accompanied by full documentation proving employment and business activity.

Important note regarding Ministry structure: since 21 April 2021, the Turkish Government has separated the Ministry of Family, Labour and Social Services into two distinct ministries – the Ministry of Family and Social Services and the Ministry of Labour and Social Security. Some older documents still list the former name; all current decisions and certifications are issued by the Ministry of Labour and Social Security.

Core requirements for the 50 jobs

The 50-job regulation has five core requirements that investors must fully meet.

Requirement 1: All 50 employees must be Turkish citizens

This is a legal condition with no exceptions. Employees must be Turkish citizens at the time of hiring and throughout the entire 3-year period. Foreigners with long-term residence permits, refugees, or dual citizens of Türkiye do not count towards these 50 employees.

Investors may hire additional foreign staff for the business, but they do not count towards the 50-job threshold required for the CBI application. Furthermore, if the business hires foreign staff, the investor must comply with a 5:1 ratio (5 Turkish citizens per 1 foreigner) – a separate regulation under the International Labour Law. Businesses with a net revenue of TRY 50,000,000 per year or more are exempt from this ratio for the first 5 foreign employees.

Requirement 2: Full-time employment and registration with the SGK from day one

All 50 employees must be full-time (40 hours/week under Turkish law) and registered with the Social Security Institution (SGK) from their very first day of work. Part-time employment, freelance work, or service contracts outside the SGK do not qualify.

Each SGK-registered employee entails obligations for two types of contributions: the employer’s contribution (approximately 22-23% of gross salary) and the employee’s contribution (approximately 14-15% of gross salary). The total social security cost for the employer is approximately 35-37% of each employee’s gross salary – this is the largest expense outside of salary that must be factored into the business budget.

Requirement 3: Maintain 50 employees continuously for 3 years

The maintenance obligation is the strictest condition of this option. The total number of employees must not fall below 50 at any point during the 3 years – even if an employee resigns. Investors must hire replacements immediately upon any personnel changes.

The Ministry of Labour and Social Security periodically checks files through the SGK data system. If the number of employees falls below 50 for an extended period (usually more than 30 consecutive days), the Ministry may revoke the Certificate of Conformity and request the revocation of citizenship if discovered after it has been granted.

Requirement 4: Salaries and working conditions must comply with labour law

Salaries paid to the 50 employees must meet at least the national minimum wage. In 2026, the Turkish minimum wage is approximately TRY 22,104/month (the 2025 rate applied to 2026, subject to annual adjustment). The total direct salary cost for 50 employees is at least approximately TRY 1,105,200/month – equivalent to US$26,000-30,000 at 2026 exchange rates.

Adding approximately 35-37% for employer social security costs, the actual cost for 50 employees is at least approximately US$35,000-40,000/month. Over 3 years, the total cost of salaries and social security reaches US$1,260,000-1,440,000 – excluding other operating expenses such as premises, machinery, services, and marketing.

Requirement 5: Business must be duly registered in Türkiye

Investors must own or co-own a business duly registered with the Turkish Trade Registry (Ticaret Sicili). The business can be a limited liability company (Limited Şirket – Ltd. Şti.) or a joint-stock company (Anonim Şirket – A.Ş.). All recognized business types are eligible to participate in the programme.

Investors can be the sole shareholder, a controlling shareholder, or a minority shareholder with management rights. The regulation does not require a specific minimum shareholding, but in practice, the Ministry of Labour checks ownership ratios to determine if the investor is the primary person responsible for job creation.

Process for obtaining the Certificate of Conformity

The process for implementing the Türkiye CBI 50-employee job creation route goes through 5 main stages, lasting a total of 6-9 months from the start of recruitment to receiving the Certificate.

1. Establish or acquire a business: open a limited liability/joint-stock company in Türkiye or acquire an existing business. Duration: 2-4 weeks
2. Recruit 50 Turkish employees and register with the SGK: carried out through local recruitment agencies, with full registration with the SGK from day one. Duration: 1-3 months depending on the sector
3. Operate the business for at least 1-2 months: accumulate operational records (bank statements, invoices, contracts) to prove genuine business activity, not a shell company
4. Submit application for the Certificate of Conformity: send to the General Directorate of International Workforce under the Ministry of Labour and Social Security. The file includes: trade registry certificate, SGK records for 50 employees, GİB tax records, bank statements, standard employment contracts, and a sworn list of employees
5. Review and issuance of the Certificate of Conformity: the Ministry assesses the file within 4-6 weeks. During this stage, the Ministry may conduct an on-site inspection at the business address to verify actual employment. Total duration: 2-3 months

After receiving the Certificate of Conformity, the investor proceeds to apply for a short-term residence permit under the investment category and submits the citizenship application – the process is similar to other CBI options.

Detailed documentation required

The application for the Certificate of Conformity for the job creation option must be complete and accurate. Errors often lead to requests for additional information and extended processing times.

• Official application form: accompanied by the notarized signature of the investor or an authorized representative
• Trade Registry Certificate: Certificate of business registration issued by the Trade Registry, valid for no more than 3 months
• Trade Registry Gazette: Copy of the Trade Registry Gazette publishing information on the establishment or changes to the business
• Shareholder documentation: share structure and management rights proving the investor is the primary responsible party
• SGK Workplace Employee List: Updated list of employees from the SGK system, showing 50 Turkish citizens currently working
• GİB Tax Compliance Letter: Confirmation of tax payment status of the business and the investor from the Tax Authority (Gelir İdaresi Başkanlığı)
• Financial statements for the last 1-2 years: if the business has been operating for over 1 year
• Sample employment contracts and payroll for 50 employees: detailed by month to verify continuity
• Business bank statements: for the last 6 months, proving actual business cash flow

All documents must be in Turkish or notarized translations into Turkish. For personal documents of investors from Vietnam, they must be consularly legalized (before 11/09/2026) or Apostilled (from 11/09/2026 when the Hague Apostille Convention comes into effect in Vietnam).

Actual costs and ROI analysis

The 50-employee job creation option has significantly higher actual costs than the nominal investment threshold.

Direct costs for 50 employees on the minimum wage over three years range from US$1,260,000 to US$1,440,000, including salaries and social security. However, very few businesses can actually operate with 50 staff members on the minimum wage, as most roles in accounting, sales, engineering and management require an average salary of 1.5 to 3 times the minimum. Total actual costs over three years frequently exceed US$2,500,000 to US$4,000,000 in personnel expenses alone.

Adding other operational costs including premises where 50 staff require approximately 500-1,000 m² of office space or workshop area, machinery and equipment, legal and accounting services, marketing, and 25% corporate tax, total three-year costs can reach US$4,000,000 to US$8,000,000. This is why this option is only suitable for investors who already have a viable business plan in place in Türkiye, rather than a purely transactional citizenship-by-investment route.

Nevertheless, business revenue and profits can offset these costs if the venture succeeds. Investors also benefit from access to the EU-Türkiye Customs Union market, a strategic Eurasian bridging location, and labour costs significantly lower than those in the EU. For investors building a long-term business, this approach turns the cost of obtaining citizenship into a genuinely profitable investment.

Risks and important considerations

The Turkish CBI 50-job creation route comes with four major risk categories, which are considerably higher than the other three passive options.

Risks audits and back-tax recovery represent a primary concern. The Ministry of Labour may conduct unannounced inspections at the business address to verify that 50 employees are actually working rather than being ghost-hired to meet application requirements. If fraud is uncovered, such as ghost hiring, salaries below the minimum wage, or faux full-time work, the Certificate is revoked and citizenship may be withdrawn if already granted.

Risks business volatility and mandatory layoffs occur when the business faces financial hardship. Over three years of operations, economic fluctuations such as recessions, competition and tax policy shifts can force a company to cut costs. Reducing staff means losing the compliance certificate and risking the revocation of citizenship.

Risks exchange rates and Lira inflation directly affect operating costs. Total payroll expenses rise in line with annual inflation, as the minimum wage was adjusted upwards by 25-50% annually between 2022 and 2025. Investors holding USD or EUR bear this risk if their revenue is generated primarily in Lira.

Risks labour law and tax compliance increase in scale alongside the business. Fifty employees mean 50 employment contracts to manage, 50 monthly social security schedules, personal income tax filings, VAT, and corporate tax. Any violation identified by labour or tax inspectors can jeopardise CBI status.

Comparison with the other 3 Türkiye CBI options

To select the right path, investors must compare the job creation route against the other three alternatives across criteria such as capital, complexity, ROI and risk.

Compared to the US$400,000 real estate, the job creation route involves much higher actual capital (≥US$4,000,000 vs US$400,000) and greater legal complexity. However, the potential ROI is higher if the business succeeds, whereas real estate only yields 4–6% in rental returns.

Compared to the two financial options US$500,000 government bonds and a US$500,000 bank deposit, the differences are stark. The two passive routes require US$500,000 in fixed capital and generate a cash flow of US$60,000 to US$120,000 over three years. The job creation route demands a financial and time commitment 5 to 10 times greater, making it suitable for entrepreneurial investors rather than passive financial applicants.

Conclusion and next steps

The job creation route presents the highest entry barrier yet holds the greatest long-term value potential among the four options. It suits three specific groups of investors: multinational business owners looking to expand into Türkiye, investors with existing industry connections and networks in the Middle East and Central Asia, and entrepreneurs with a long-term vision for the market.

For ordinary Vietnamese investors seeking Turkish citizenship purely for the passport, the passive routes involving real estate or government bonds are far more efficient in terms of cost and risk profile.

Before deciding to proceed, investors should carefully evaluate their operational capabilities in Türkiye, sectors with competitive advantages, and local partner networks. Refer to the comprehensive framework in Turkish CBI overview 2026 and Turkish passport and the US E-2 route — an article providing a strategic angle on travel benefits and the pathway to combining US investment through a Turkish passport.

For investors determined to pursue this route, opening a Turkish bank account and obtaining a Defter tax number are the first two mandatory procedures before company incorporation. In addition, Vietnamese paperwork required for business registration and residency permit applications must undergo three-step consular legalisation prior to 11 September 2026, or Apostille certification from 11 September 2026 when the Apostille Convention takes effect in Vietnam.