When Does a Foreign Shareholder or Company Director Need a Work Permit in Turkey?

A foreign shareholder or company executive falls into one of three cases. Work permit required: a shareholder who is the manager (müdür) of a limited company (limited şirket), a shareholder who sits on the board of directors (yönetim kurulu üyesi) of a joint-stock company (anonim şirket) and a salaried foreign executive must, as a rule, obtain a work permit (çalışma izni) if they are to perform their duties in Turkey. Exemption: board members of a joint-stock company who do not reside in Turkey, shareholders who hold no executive position and non-shareholder representatives at the highest level may instead work under a “work permit exemption” (çalışma izni muafiyeti), provided their work in Turkey will not exceed three months. The exemption is also a document obtained from the Ministry by application; it does not arise automatically. If the work will exceed three months, a work permit is required. Shareholding only: merely holding shares, without doing any work in Turkey, is not regulated in the legislation as a situation that requires a work permit.

This article is based on the International Labour Force Law No. 6735 (6735 sayılı Uluslararası İşgücü Kanunu), the Implementing Regulation of the International Labour Force Law (Uluslararası İşgücü Kanunu Uygulama Yönetmeliği, hereinafter “Yönetmelik”; Official Gazette of 2 February 2022, as amended on 15 October 2024) and the work permit evaluation criteria of the General Directorate of International Labour Force (Uluslararası İşgücü Genel Müdürlüğü) of the Ministry of Labour and Social Security (Çalışma ve Sosyal Güvenlik Bakanlığı, ÇSGB).

Key Concepts

• Work permit: A permit that gives a foreign national the right to work in Turkey for a specific period. It may be dependent (tied to an employer) or independent (for the foreigner’s own name and account).
• Independent work permit (bağımsız çalışma izni): A permit that allows a foreign national to work in their own name and for their own account, without being tied to an employer (Yönetmelik m. 4/1-a).
• Work permit exemption: A document that gives a foreign national the right to work and reside in Turkey for a specific period and activity without obtaining a work permit (6735 m. 3/1-ç).
• Residence permit (ikamet izni): A permit granted under the Law on Foreigners and International Protection No. 6458 (6458 sayılı Yabancılar ve Uluslararası Koruma Kanunu) that gives the right to stay in Turkey. A residence permit alone does not give the right to work.

Who Needs a Work Permit, and When?

The Yönetmelik contains two separate provisions for company shareholders and executives. One lists the persons who may be granted an independent work permit (Yönetmelik m. 29/1-c and ç). The other lists the persons who are granted a work permit exemption (Yönetmelik m. 48/1-ç). The table summarises these two provisions by role. The outcomes in the table are of three kinds: work permit, work permit exemption, and no permit because there is no work in Turkey.

Shareholders Without an Executive Role

The Yönetmelik brings work in Turkey by “shareholders of other companies who do not hold an executive position” within the exemption for up to three months (Yönetmelik m. 48/1-ç). The Ministry’s frequently asked questions page also states that these shareholders are assessed under the exemption. The exemption is intended for cases where the shareholder will carry out an activity in Turkey. The legislation contains no explicit provision stating that merely holding shares, by a foreign national who lives abroad and does no work in Turkey, does not count as work. However, the Law covers foreign nationals who apply to work or who work in Turkey (6735 m. 2/1). For this reason, merely being a shareholder is not, on its own, regulated as a situation that requires a work permit. If the shareholder comes to Turkey to do work for the company, an exemption is required where the period does not exceed three months, and a work permit where it does.

Managers of Limited and Joint-Stock Companies

A shareholder who is the manager of a limited company and a shareholder who is a board member of a joint-stock company obtain a work permit if they are to perform their duties in Turkey. The Ministry states that these persons “may be granted” an independent work permit (Yönetmelik m. 29/1-c). In other words, this permit is not a right; it is granted following an assessment. The assessment takes into account the foreign national’s education, professional experience, the effect of their activity on the economy and employment and, for shareholders, their share of the capital (Yönetmelik m. 29/5). An independent work permit is issued without being tied to an employer (Yönetmelik m. 24/2). Foreign nationals who are shareholders or executives of other companies may also benefit from the same option (Yönetmelik m. 29/1-ç).

A salaried general manager or manager who holds no shares in the company, by contrast, works under a dependent work permit (bağımlı çalışma izni) applied for by the company as employer.

Executives Residing and Not Residing in Turkey

The Yönetmelik draws a residence distinction only for board members of joint-stock companies. Not residing in Turkey does not, by itself, mean that no work permit is needed. If a board member who does not reside in Turkey will perform duties in Turkey, the exemption conditions in Yönetmelik m. 48/1-ç are checked first:

• If the work in Turkey will last no more than three months, an application for a work permit exemption is made and the member works under the exemption document.
• If the work will exceed three months, or the member will perform their duties while resident in Turkey, a work permit is required. If the member is a shareholder, an independent work permit may be granted (Yönetmelik m. 29/1-c).
• A new exemption application in the same category cannot be made until twelve months have passed from the date the previous exemption was issued (Yönetmelik m. 53/1). Recurring assignments during the year should therefore be assessed separately for a work permit.

The Yönetmelik contains no similar residence exception for limited company managers.

Limits of the Work Permit Exemption

• Duration: The exemption under Yönetmelik m. 48/1-ç is for a maximum of three months. The exemption is issued so that it ends sixty days before the passport’s expiry date (Yönetmelik m. 51/2).
• Extension: No extension application can be made for an exemption. If the work will exceed the exemption period, a work permit must be obtained from the Ministry.
• Re-application: A new application in this category cannot be made until twelve months have passed from the date the exemption was issued (Yönetmelik m. 53/1).
• Application: If made in Turkey, the application is filed with the Ministry through the system; if made abroad, with the Turkish diplomatic mission (dış temsilcilik) (Yönetmelik m. 49/2). An application made from within Turkey must be filed while the foreign national is legally present in Turkey (Yönetmelik m. 49/3, amendment of 15 October 2024). According to the Ministry’s announcement, exemption applications made from 17 September 2026 are filed via calismaizni.csgb.gov.tr. Applications made before that date are tracked via emuafiyet.csgb.gov.tr.
• Fee: No fee (harç) is charged for exemptions requested for a period shorter than three months (Yönetmelik m. 58/8).
• Notification: Exemptions of up to three months are exempt from the obligation to notify the start and end of employment (Yönetmelik m. 61/3).

Evaluation Criteria: Capital, Shareholding and Employment

The Ministry assesses applications under Article 7 of the Law. Applications that do not meet the criteria may be rejected (6735 m. 9). For foreign nationals who are company shareholders, the current criteria, with the amounts applied from 1 January 2025, are as follows (evaluation criteria C.1.1, D.3.2):

• Capital: The company’s paid-in capital must be at least TL 500,000. The foreign national’s capital contribution must be at least TL 500,000, and their shareholding must be at least 20 percent.
• Employment: At least five Turkish citizens must be employed at the workplace. The first work permit granted to the shareholder is issued with an annotation (şerhli, i.e. recorded subject to this condition). From the beginning of the seventh month of the first permit period, at least five Turkish citizens must be employed every month.
• Exception: These two conditions do not apply to a foreign shareholder whose capital share is USD 100,000 or more (evaluation criteria C.1.2).

For a non-shareholder salaried executive, the general criteria apply (evaluation criteria A):

• At a workplace subject to the balance-sheet basis (bilanço esası), at least five Turkish citizens must be employed for each foreign national (A.1.1).
• At a workplace with net sales of TL 50,000,000 or more in the last year, the employment condition does not apply for up to five foreign nationals (A.1.2).
• A newly established workplace must have paid-in capital of at least TL 500,000 (A.2.1). For existing workplaces, one of the following three conditions is sufficient: paid-in capital of at least TL 500,000, net sales of TL 8,000,000, or exports of USD 150,000 (A.2.2).
• The salary must be at least 5 times the gross minimum wage at the application date for senior executives, and at least 3 times for other executives (A.3).

When extending a permit granted before 1 January 2025, the Ministry applies the financial criterion of the initial application (D.2.1). Meeting the criteria does not mean that the permit will be granted.

Example 1: Capital Requirement for a Foreign Shareholder (2026)

Assumption: A limited company has paid-in capital of TL 1,000,000. The foreign shareholder’s share is 30 percent. This shareholder will work in Turkey as the company manager. It is assumed that their share is below USD 100,000.

1. Company capital: TL 1,000,000 ≥ TL 500,000. The condition is met.
2. Shareholding: 30 percent ≥ 20 percent. The condition is met.
3. Foreign national’s capital contribution: 1,000,000 × 0.30 = TL 300,000. Since this amount is below TL 500,000, the condition is not met.
4. For this shareholder to meet the condition with a share of at least 30 percent, paid-in capital must be at least 500,000 ÷ 0.30 = TL 1,666,667. Alternatively, their share must be USD 100,000 or more.

Example 2: Minimum Salary of a Non-Shareholder General Manager (2026)

For calendar year 2026, the gross minimum wage is TL 33,030 per month. This amount applies for the period 1 January – 31 December 2026.

1. Lower limit for a senior executive: 33,030 × 5 = TL 165,150 gross per month.
2. Lower limit for other executives: 33,030 × 3 = TL 99,090 gross per month.

Application Process: e-İzin and the Consular Route

Work permit applications are made electronically through the system (Yönetmelik m. 11). Under the Law, applications are filed directly with the Ministry within Turkey, and with Turkish diplomatic missions abroad (6735 m. 7). There are two routes.

Application from abroad (consular route):

1. The foreign national applies for a work visa (çalışma vizesi) to the Turkish diplomatic mission in the country of which they are a citizen or in which they are legally present (Yönetmelik m. 15/1, m. 17/1-a). They receive a reference number with this application.
2. Within thirty days of the visa application, the employer applies to the e-İzin system via e-Devlet (Yönetmelik m. 17/2). The workplace’s SGK e-Bildirge user acts on behalf of the employer. The employer must have an electronic notification address (elektronik tebligat adresi) (Yönetmelik m. 16).
3. After a positive outcome, the work permit fee and the valuable paper fee (değerli kâğıt bedeli) are paid. Payments are made via the Digital Tax Office (Dijital Vergi Dairesi). The foreign national then enters Turkey on the work visa.
4. The foreign national must start work within one month of entering Turkey. In any case, work must start within six months of the permit’s start date (Yönetmelik m. 25/2). The permit of a foreign national who does not arrive within six months may be cancelled (Yönetmelik m. 56/1-a).

Application from within Turkey: The foreign national must hold a residence permit valid for at least six months and valid on the application date (Yönetmelik m. 15/4). Certain foreign nationals designated by the General Directorate may apply without a valid residence permit (Yönetmelik m. 15/3).

Assessment period: Applications with complete information and documents are concluded within thirty days (6735 m. 7). Missing documents must be completed within thirty days. The assessment is suspended during this period (Yönetmelik m. 19/2).

Duration and extension: On the first application, a work permit is granted for a maximum of one year (6735 m. 10). An independent work permit is issued for a fixed term without being bound by these duration limits (Yönetmelik m. 24/4). Extension applications made after the permit has expired are rejected (6735 m. 7). A rejection may be appealed to the Ministry within thirty days of notification (6735 m. 21).

Since the capital and shareholding conditions are set when the company is formed, the shareholder and executive structure can be considered together with these criteria at the formation stage. For details, see our Company Formation with Foreign Shareholders page and our article on the first 90 days after company formation.

Relationship With the Residence Permit

A work permit or work permit exemption issued by the Ministry replaces a residence permit for as long as it is valid (Yönetmelik m. 57/1). For this reason, a foreign national holding a work permit does not need a separate residence permit. If the permit loses its validity, the right of residence based on it also ends (Yönetmelik m. 57/2). A separate residence permit obtained by the foreign national on other grounds is not affected (Yönetmelik m. 57/3). The rule is equally clear in the opposite direction: a residence permit, for example a short-term residence permit (kısa dönem ikamet izni), does not give the foreign national the right to work. A dependent work permit is valid only for the workplace and address stated in the permit (Yönetmelik m. 57/4).

SGK Registration and Notifications

• Salaried foreign employee: Foreign nationals working under an employment contract (hizmet akdi) are insured with the Social Security Institution (Sosyal Güvenlik Kurumu, SGK) (5510 m. 4). For citizens of countries that have a social security agreement with Turkey, the provisions of the agreement are reserved. The employer submits the employment start notification (sigortalı işe giriş bildirgesi) to the SGK before work begins (5510 m. 8).
• Executive who is a shareholder: Shareholders of a joint-stock company who are board members, and shareholders of other companies, are treated as working in their own name and for their own account (kendi nam ve hesabına çalışan) (5510 m. 4/1-b). For limited company shareholders, insurance coverage begins on the date of registration with the trade registry (ticaret sicili) (5510 m. 7/1-b). Persons residing abroad and subject to that country’s social security legislation are outside the scope, subject to international agreements (5510 m. 6/1-e).
• Notification to the Ministry: Employers, and foreign nationals with an independent or indefinite permit, notify the Ministry within fifteen days of the start and end of work and of any circumstances causing the permit to be cancelled (6735 m. 22). Employment start and termination notifications made to the SGK are deemed to have been made to the General Directorate (Yönetmelik m. 61/2).
• Change of workplace: A foreign national holding an independent work permit notifies a change of workplace or position no later than ten days before starting work at the new workplace (Yönetmelik m. 26/3).

For payroll and SGK procedures, see our Payroll Services page.

Penalties for Working Without a Permit (2026)

The penalty amounts set out in the Law (6735 m. 23) are increased every year by the revaluation rate (yeniden değerleme oranı) under Article 17/7 of the Law on Misdemeanours (Kabahatler Kanunu m. 17/7). The rate applied for 2026 is 25.49 percent. The 2026 amounts published by the Ministry are as follows:

If these offences are repeated, the penalties are doubled. Penalties are payable within one month of notification (6735 m. 23). A foreign national found to be working without a permit is reported to the Ministry of Interior (İçişleri Bakanlığı) for deportation proceedings. The employer also bears the foreign national’s accommodation and return travel costs and, where necessary, health costs (6735 m. 23). The regulation on collecting these costs from the employer was published on 23 July 2025. It entered into force six months after its publication.

Example 3: Non-Shareholder Manager Working Without a Permit (2026)

Assumption: A joint-stock company employed a non-shareholder foreign general manager without a work permit in 2026. This is the first finding.

1. Penalty imposed on the company: TL 102,503 × 1 foreign national = TL 102,503.
2. Penalty imposed on the foreign national (dependent work): TL 40,977.
3. Total: 102,503 + 40,977 = TL 143,480. Return travel and, if any, accommodation costs are added to this.
4. If the offence is repeated, the penalties are doubled: TL 205,006 for the company and TL 81,954 for the foreign national.

Practical Checklist

• Determine the foreign national’s role in the company: shareholder, shareholder-manager, board member or salaried executive.
• Determine whether the person will actually work in Turkey. If they only hold shares, no permit is needed; if they will perform duties in Turkey, a permit or an exemption is needed.
• Determine how long they will work in Turkey. If the period exceeds three months, the exemption is not sufficient.
• If the exemption applies, file the application via calismaizni.csgb.gov.tr and start work only after the exemption document has been issued.
• Check the shareholder’s capital contribution and shareholding: at least TL 500,000 and at least 20 percent, or at least USD 100,000.
• Plan for the condition of employing five Turkish citizens and the seventh-month timeline of the annotated permit.
• File the extension application before the permit expires.
• Monitor SGK registration and the fifteen-day notifications.

For your company’s specific situation, you can write to us via our contact page.

Last legislation check: 9 November 2026 · Period covered: calendar year 2026 (new exemption application system from 17 September 2026; 2026 minimum wage and administrative fine amounts)