Insights Valuation

How property valuation actually works in the citizenship process

Since March 2024 the valuation report for a citizenship-route purchase can be drawn by one designated company only, and no party to the transaction chooses it. This is what that changes, and what it does not.

Weldenor Research Desk

Updated · 8 min Change history

1. The question people actually arrive with

Buyers arrive expecting valuation to be a negotiation — something a seller arranges, an agent influences, or a buyer can shop around for. In a citizenship-route transaction it is none of those things, and the gap between that expectation and the rule is where most of the confusion and some of the fraud sits.


2. What changed on 4 March 2024

Under TKGM Genelge 2024/2, dated 1 March 2024 and in force from 4 March 2024, the authority to draw up the valuation report required in a sale or promise-to-sell directed at acquiring citizenship by the exceptional route was conferred on GEDAŞ Gayrimenkul Değerleme A.Ş., a subsidiary of the Housing Development Administration. For citizenship files the buyer cannot choose the valuer and cannot substitute a privately commissioned report.

For everything else — ordinary foreign-buyer purchases not directed at citizenship — the circular expressly preserves the previous position: any valuation company licensed by the Capital Markets Board may draw the report.


3. What this is not

The framing that circulates in English-language marketing — a state monopoly replacing the licensed system — is wrong, and the correction matters for reader trust. GEDAŞ is itself a company licensed by the Capital Markets Board; it was, in fact, the first company the Board listed, in 1995. What changed in 2024 is not that valuation left the licensed framework but that citizenship-route reports may come from one designated licensed company only.


4. Which file the rule applies to

The circular’s temporal rule keys on the date the report was requested, not the date of the deed. Two transactions completing on the same day can fall on different sides of the line if their reports were commissioned weeks apart. On the wording of the circular, a report requested before 4 March 2024 from another licensed firm remains usable for a citizenship claim — a reading that should be confirmed for a specific file with a Turkish avukat rather than taken from an article.


5. How the report reaches the file

Reports are commissioned and delivered through the official land-registry channels and pass directly into the registry system. A report produced off-system, however competent, is disregarded. This is the mechanical reason a valuation cannot be pre-arranged, pre-agreed or brought to the transaction by a seller.


6. Why the valuation is only one of three tests

The valuation figure does not stand alone. Land Registry guidance requires three amounts to reach the threshold separately — the price declared in the deed, the value in the valuation report, and the total payments documented through the banking system. The guidance says they must satisfy the amount ayrı ayrı, separately, which in practice means the weakest of the three governs the file.

This is also the reason no listing anywhere, including ours, can carry an eligibility verdict: two of the three figures do not exist until the transaction happens.


7. What a buyer should take from this

Four practical consequences follow from the mechanics above.

A narrow margin above the threshold is a real risk. The valuation is drawn by a company nobody in the transaction chooses, and the file passes only if the report — independently of the price and the payments — reaches the threshold. A purchase engineered to clear USD 400,000 by a whisker is betting the file on a figure no party controls.

Currency movement between agreement and deed day matters. The dollar figure that counts is fixed by the conversion mechanics, not by the day you shook hands. A margin that existed at agreement can be gone by completion.

Any offer that includes or promises a valuation figure is describing something that cannot lawfully be delivered. Reports are commissioned through the official channel and pass directly into the registry system; nobody can bring one to the table.

Ask a seller who says a report already exists when it was requested, and through which channel. A report requested before 4 March 2024 sits under the previous regime; one produced off-system is disregarded whatever it says.


8. The honest caveat

Designating a single provider did not by itself eliminate valuation-fraud risk. The enforcement files made public in August 2026 concern transactions that post-date the 2024 designation. Saying so plainly is what makes the rest of this article credible.


What this article does not tell you

  • We do not publish the designated valuer’s fee, because we hold only an industry estimate — and this site does not publish estimates as figures.
  • Whether a report can be challenged, by whom, and with what effect on a pending file, is a question for your own bar-registered avukat on your specific file.
  • Whether the designated company subcontracts field work is not verified from any record we hold, so we assert nothing about it either way.

Sources

  1. [1]Türkiye Değerleme Uzmanları Birliği (TDUB)TKGM Genelge 2024/2, full text, hosted PDFPublished1 Mar 2024Accessed24 Aug 2026Source accessible
  2. [2]T.C. İçişleri BakanlığıSahte Değerleme/Ekspertiz Operasyonu ve Usulsüz Vatandaşlık İşlemleri Hakkında Basın Açıklaması — present-tense confirmation of the regimePublished4 Aug 2026Accessed24 Aug 2026Source accessible
  3. [3]GEDAŞ Gayrimenkul Değerleme A.Ş.GEDAŞ Hakkında — corporate disclosureAccessed24 Aug 2026Secondary source
  4. [4]LexperaTürk Vatandaşlığı Kanununun Uygulanmasına İlişkin Yönetmelik Hakkında Kılavuz, reproduction of the 01.02.2024 textPublished1 Feb 2024Accessed24 Aug 2026Secondary source
  5. [5]Tapu ve Kadastro Genel MüdürlüğüKılavuz 01.02.2024, official PDFPublished1 Feb 2024Accessed24 Aug 2026Mirror copy

This article is general information reviewed against the sources above on the stated date. It is not legal advice, and rules may change after the review date. For a decision, obtain advice from independent Turkish counsel.

Reviewed against primary sources Change history