Work Permits for Foreign Direct Investments with Special Characteristics
If a foreign-owned company exceeds one of the thresholds for revenue, exports, employment, or fixed investment, it is considered a "direct foreign investment of special significance," and work permits for its key personnel are evaluated according to special provisions rather than general rules. Under this framework, permits are granted for the company’s key personnel.
Why a separate regime?
For standard work permit applications, general criteria such as the employer’s capital, revenue, and the number of Turkish citizens employed are applied. In large-scale foreign investments, these criteria may not accurately reflect the nature of the investment.
For this reason, the Regulation on the Employment of Foreign Nationals in Direct Foreign Investment and the work permits falling under its scope are subject to special provisions; the aim is to make it easier to grant these permits.
Inclusion in the scope is not automatic. A company or branch covered by Law No. 4875 must meet at least one of the following thresholds.
2026 Threshold Values
The amounts are increased annually by the revaluation rate. The figures below are valid for 2026.
| Condition | The 2026 threshold |
|---|---|
| Revenue (provided that the foreign equity share is at least 21,946,007 TL) | Turnover of at least 1,648,938,600 TL in the last year |
| Exports (provided the equity stake remains the same) | Exports of at least 1 million U.S. dollars in the past year |
| Employment (assuming the same share of capital) | At least 250 employees registered with the Social Security Institution (SGK) in the past year |
| Fixed investment | The projected minimum fixed investment amount is at least 522,163,890 TL |
| Multi-country investment | The parent company must have direct foreign investments in at least one other country besides the one where its headquarters is located |
In addition, the first three conditions require that the total capital share of foreign partners be at least 21,946,007 TL. In other words, simply exceeding the turnover or export threshold is not sufficient.
Why do the threshold amounts change every year?
Amounts in Turkish lira are increased annually by the revaluation rate. The figures for 2026 were determined by applying the 25.49% revaluation rate announced for 2025. Therefore, basing your planning on the previous year’s figures would be misleading.
Who are the key personnel?
A work permit under this provision is not granted to everyone, but only to a company’s key personnel. Key personnel are employees who perform specific duties at a company established in Turkey that is a legal entity and falls under the scope described above.
This definition includes authorities such as working in the company’s senior management or in an executive position, managing the entire company or a division of it, supervising the work of auditors or administrative and technical staff, hiring new employees, or terminating the employment of existing employees.
In short, the criterion is not a title, but the authority actually exercised. The fact that a business card says "manager" is not, in and of itself, sufficient to qualify someone as a key employee; that authority must be evident in the company’s documents.
The situation at the liaison offices
Liaison offices are subject to a separate rule. At these offices, a work permit may be issued to no more than one foreign national who holds a certificate of authorization.
A prerequisite for obtaining a permit is having obtained an operating permit from the General Directorate of Incentive Implementation and Foreign Capital of the Ministry of Industry and Technology. The work permit to be issued is also limited to the duration of the office’s operations.
For this reason, plans to employ more than one foreign worker through the liaison office are unrealistic from the outset.
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The advantage of this system is that the general employment and financial eligibility criteria are not applied as they are. However, to take advantage of this benefit, the company must provide documentation proving that it falls within the scope of the system.
In practice, the following documents form the basis of the file: commercial registry records showing the capital structure and the foreign partner’s share; audited financial statements verifying revenue or exports; Social Security Institution (SGK) records, if there is a claim regarding employment; and documents indicating the size of the investment, if there is a claim regarding fixed investment.
It is important to decide from the outset which threshold to use, because what needs to be proven in the case file depends on that decision. A case file prepared based on the wrong threshold may be deemed incomplete, even if the company actually falls within the scope.
Frequently Asked Questions
My company meets the thresholds—is the requirement for five Turkish employees still in effect?
Work permits issued under this framework are subject to special provisions, and the general employment criteria do not apply in full. However, the scope and limits of the exemption are assessed on a case-by-case basis; it is mandatory to provide documentation demonstrating eligibility for the exemption. If it is determined that the applicant does not qualify for the exemption, the application will be reviewed according to the general criteria.
How many key employees can be granted leave?
For companies, a fixed upper limit does not arise from this system itself; the assessment is based on the company’s size and whether the employee qualifies as a key employee. For liaison offices, however, the limit is clear: no more than one foreign national holding a certificate of authorization.
Can a newly established company benefit from this provision?
Since the revenue, export, and employment thresholds are based on "last year's" data, they generally cannot be met by newly established companies. In such cases, the evaluation may be based on the fixed investment amount requirement or the requirement that the parent company have direct investments in other countries as well.
At what thresholds is the equity stake requirement applied?
The requirement that foreign partners’ total equity stake be at least 21,946,007 TL also applies to the turnover, export, and employment thresholds. This amount is not specified as a criterion in the fixed investment and multinational investment requirements.
Does the company submit the application, or does the employee?
Applications for work permits are submitted by the employer on behalf of the foreign national through the Ministry’s electronic system. For employees coming from abroad, an application is first filed at the consulate, and the employer then completes the process using the reference number provided. In this context, the applicant is the company.
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Ministry of Labour and Social Security — General Directorate of International Labor, Foreign Direct Investment page; Regulation on the Employment of Foreign Nationals in Foreign Direct Investment; Law No. 4875 on Foreign Direct Investment. Last updated: September 3, 2026.
This page is for general informational purposes only and does not constitute legal advice. The threshold amounts are updated annually; please check the Ministry of Labour and Social Security’s current figures before submitting your application.
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