Turkey

Country score (EU Average*)

35(72) Political Financing
61(57) Financial Disclosure
22(49) Conflict of Interest
55(59) Freedom of Information
71(63) Public Procurement
37(66) Anti Money Laundering
40(71) Asset Recovery

Country Facts data not yet available.

Political Financing

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Bans and limits on private income						22
Public funding						50
Regulations on spending						0
Reporting, oversight and sanctions						67

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Bans and limits on private income
Bans on donations from foreign interests	Yes. See subindicators
Is there a ban on donations from foreign interests to political parties?	Yes. Political parties may not receive in-kind or cash aid or donations from foreign states, international organisations, or non-Turkish natural or legal persons. (Constitution of the Republic of Türkiye, Art. 69(10); Political Parties Law No. 2820, Art. 66(3))
Is there a ban on donations from foreign interests to candidates?	No. The only explicit candidate rule found is for presidential candidates; parliamentary and local candidates are not covered by an equivalent general donation rule. (Presidential Election Law No. 6271, Art. 14(1))
Bans on corporate donations	No. See subindicators
Is there a ban on corporate donations to political parties?	No. Political parties may receive donations from legal persons under Article 66, subject to the statutory annual cap. (Political Parties Law No. 2820, Art. 66(1)-(2), Additional Art. 6)
Is there a ban on corporate donations to candidates?	No. The express legal-person ban applies only to presidential candidates, not to candidates generally. (Presidential Election Law No. 6271, Art. 14(1))
Is there a ban on donations from corporations with government contracts to political parties?	No. The law does not single out corporations with government contracts as prohibited party donors; party donations by legal persons are governed by the general rules in Article 66. (Political Parties Law No. 2820, Art. 66(1)-(2))
Is there a ban on donations from corporations of partial government ownership to political parties?	No. The law does not establish a specific ban on donations from partly state-owned corporations to political parties. (Political Parties Law No. 2820, Art. 66(1)-(2))
Is there a ban on donations from corporations with government contracts to candidates?	No. The only express legal-person ban applies to presidential candidates; there is no equivalent rule for candidates generally that specifically targets government contractors. (Presidential Election Law No. 6271, Art. 14(1))
Is there a ban on donations from corporations of partial government ownership to candidates?	No. The only express legal-person ban applies to presidential candidates; there is no equivalent rule for candidates generally that specifically targets partly state-owned corporations. (Presidential Election Law No. 6271, Art. 14(1))
Bans on donations from trade unions	No. See subindicators
Is there a ban on donations from Trade Unions to political parties?	No. Trade unions and their upper organisations may donate to political parties if their own special laws permit it. (Political Parties Law No. 2820, Art. 66(1))
Is there a ban on donations from Trade Unions to candidates?	No. There is no explicit trade-union ban for candidates generally; only presidential candidates are covered by a broader ban on all legal-person donations. (Presidential Election Law No. 6271, Art. 14(1))
Bans on anonymous donations	Yes. See subindicators
Is there a ban on anonymous donations to political parties?	Yes. A political party may not accept a donation unless the party receipt clearly identifies the donor or the donor’s authorised representative or proxy. (Political Parties Law No. 2820, Art. 66(2))
Is there a ban on anonymous donations to candidates?	No. There is no explicit anonymous-donation rule for candidates generally. Presidential-candidate aid is regulated through bank-account or receipt-based cash donations, but the law does not create a general all-candidate rule matching this indicator. (Presidential Election Law No. 6271, Art. 14(4))
Other bans on donations	No. See subindicators
Is there a ban on state resources being given to or received by political parties or candidates (excluding regulated public funding)?	No. There is no single general rule matching this indicator. Election law instead contains specific campaign-period restrictions, such as barring use of certain public and publicly linked premises as election offices. (Law No. 298 on Basic Provisions of Elections and Voter Registers, Art. 51/A(1))
Is there a ban on any other form of donation?	No. No additional explicit category of prohibited donation, beyond the source-based restrictions already identified, was found in the binding legal texts reviewed.
Donation limits	Yes. See subindicators
Is there a limit on the amount a donor can contribute to a political party over a time period (not election specific)?	Yes. Each natural or legal person is subject to an annual cap on donations to a political party; the monetary amount is updated under the revaluation rule. (Political Parties Law No. 2820, Art. 66(2), Additional Art. 6)
Is there a limit on the amount a donor can contribute to a political party in relation to an election?	No. The donation cap for political parties is annual, not election-specific. No separate party-election contribution limit was identified. (Political Parties Law No. 2820, Art. 66(2), Additional Art. 6)
Is there a limit on the amount a donor can contribute to a candidate?	No. The only explicit candidate contribution cap found is for presidential candidates and applies per round; there is no equivalent rule for candidates generally. (Presidential Election Law No. 6271, Art. 14(3))
Public funding
Eligibility criteria for direct public funding to political parties	Yes. See subindicators
Eligibility criteria for direct public funding to political parties: Share of votes in previous election	Yes. The law ties eligibility to the party’s share of valid votes in the previous parliamentary general election: parties above the national threshold, and separately parties above 3%, qualify under different paragraphs. (Political Parties Law No. 2820, Additional Art. 1; Law No. 2839 on Parliamentary Elections, Art. 33)
Eligibility criteria for direct public funding to political parties: Representation in elected body	No. The funding rule is not framed as eligibility based on representation in an elected body. The operative criteria are participation rights and prior-election vote thresholds. (Political Parties Law No. 2820, Additional Art. 1)
Eligibility criteria for direct public funding to political parties: Participation in election	Yes. The party must have been granted by the Supreme Election Council the right to participate in the last parliamentary general election. (Political Parties Law No. 2820, Additional Art. 1)
Eligibility criteria for direct public funding to political parties: Number of candidates	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Share of seats in previous election	No. No direct public-funding rule conditions eligibility on the party’s share of seats from the previous election. (Political Parties Law No. 2820, Additional Art. 1)
Eligibility criteria for direct public funding to political parties: Share of votes in next election	No. No direct public-funding rule makes eligibility depend on vote share in the next election. (Political Parties Law No. 2820, Additional Art. 1)
Eligibility criteria for direct public funding to political parties: Registration as a political party	No. A registered party does not qualify solely by being a political party; the funding rule requires election-participation entitlement and specified vote thresholds. (Political Parties Law No. 2820, Additional Art. 1)
Eligibility criteria for direct public funding to political parties: Share of seats in next election	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Number of members	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Other	No. No additional eligibility criterion beyond election-participation entitlement and prior-election vote thresholds was identified in the funding provision. (Political Parties Law No. 2820, Additional Art. 1)
Allocation calculations for direct public funding to political parties	Yes. See subindicators
Allocation calculations for direct public funding to political parties: Proportional to votes received	Yes. Funding is allocated in proportion to the valid votes parties received in the previous parliamentary general election. (Political Parties Law No. 2820, Additional Art. 1)
Allocation calculations for direct public funding to political parties: Equal	No. The law does not allocate annual direct public funding equally among eligible parties. (Political Parties Law No. 2820, Additional Art. 1)
Allocation calculations for direct public funding to political parties: Proportional to seats received	No. The allocation rule is based on votes, not on the number or share of seats won. (Political Parties Law No. 2820, Additional Art. 1)
Allocation calculations for direct public funding to political parties: Flat rate by votes received	No. No flat-rate payment per vote is prescribed; the law provides proportional allocation by votes within the statutory appropriation. (Political Parties Law No. 2820, Additional Art. 1)
Allocation calculations for direct public funding to political parties: Share of expenses reimbursed	No. Annual direct public funding is not allocated as reimbursement of a share of expenses in this provision. (Political Parties Law No. 2820, Additional Art. 1)
Allocation calculations for direct public funding to political parties: Proportional to candidates fielded	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Number of members	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Other	No. No separate allocation formula outside vote-based proportionality was identified for annual direct public funding in force in 2024. (Political Parties Law No. 2820, Additional Art. 1)
Earmarking provisions for direct public funding to political parties	No. See subindicators
Earmarking provisions for direct public funding to political parties: Campaign spending	No. Election-year Treasury aid is increased in election years, but the law does not require that party state aid be spent on campaign costs. (Political Parties Law No. 2820, Additional Art. 1)
Earmarking provisions for direct public funding to political parties: Ongoing party activities	No. Treasury aid is granted to eligible parties without any explicit statutory earmark for routine or ongoing party activity. (Political Parties Law No. 2820, Additional Art. 1)
Earmarking provisions for direct public funding to political parties: Intra-party institution	No. No provision earmarks party state aid for intra-party institutions or party foundations. (Political Parties Law No. 2820, Additional Art. 1)
Earmarking provisions for direct public funding to political parties: Other	No. The Treasury-aid rule sets eligibility and amounts, but does not earmark the money for any other specified purpose. (Political Parties Law No. 2820, Additional Art. 1)
Allocation criteria for free or subsidized access to media for political parties	Yes. See subindicators
Allocation criteria for free or subsidized access to media for political parties: Equal	Yes. Each political party attending the election is entitled to two radio/television speeches, and the broadcast sequence and times are determined by lot among applicant parties. (Law No. 298 on Basic Provisions of Elections and Voter Registers, Arts. 52, 54)
Allocation criteria for free or subsidized access to media for political parties: Number of candidates	No. The media-allocation rule does not use the number of candidates as a criterion. (Law No. 298 on Basic Provisions of Elections and Voter Registers, Art. 52)
Allocation criteria for free or subsidized access to media for political parties: Share of seats	No. The law gives extra airtime to parties with a parliamentary group, governing parties, and the main opposition, but it is not framed as allocation by share of seats. (Law No. 298 on Basic Provisions of Elections and Voter Registers, Art. 52)
Allocation criteria for free or subsidized access to media for political parties: Share of votes in preceding election	No. No provision allocates free or subsidized media time to parties according to their share of votes in the preceding election. (Law No. 298 on Basic Provisions of Elections and Voter Registers, Arts. 52, 54)
Allocation criteria for free or subsidized access to media for political parties: Other	Yes. Additional airtime is allocated by other statutory categories: parliamentary-group status, governing-party status, and main-opposition status. (Law No. 298 on Basic Provisions of Elections and Voter Registers, Art. 52)
Are there provisions for free or subsidized access to media for candidates?	No. The law allows party representatives and independent candidates to join radio and television programs and permits live broadcasting of meetings, but it does not create a clear free or subsidized campaign-media allocation rule for candidates. (Law No. 298 on Basic Provisions of Elections and Voter Registers, Art. 55/A(2))
Are there provisions for any other form of indirect public funding?	Yes. See subindicators
Provisions for any other form of indirect public funding: Premises for campaign meetings	No. Parties and independent candidates may hold closed meetings, but no rule requires free or subsidized premises for campaign meetings. (Law No. 298 on Basic Provisions of Elections and Voter Registers, Art. 51)
Provisions for any other form of indirect public funding: Space for campaign materials	Yes. District Election Boards allocate fixed advertisement places for election materials, and free-of-charge places are distributed equally among parties and candidates. (Law No. 298 on Basic Provisions of Elections and Voter Registers, Art. 60)
Provisions for any other form of indirect public funding: Tax relief	Yes. Propaganda publications in the nature of handbills are exempt from charges and fees, and certain campaign announcements and advertisements are exempt from taxes and charges. (Law No. 298 on Basic Provisions of Elections and Voter Registers, Arts. 59, 60)
Provisions for any other form of indirect public funding: Free or subsidised transport	No. The law does not provide free or subsidized transport; instead it forbids political propaganda in public transportation vehicles and related passenger spaces during the election period. (Law No. 298 on Basic Provisions of Elections and Voter Registers, Art. 61)
Provisions for any other form of indirect public funding: Free or subsidised postage cost	No. Absent from legal framework
Provisions for any other form of indirect public funding: Other	No. Beyond tax/fee exemptions and campaign display-space rules, no other indirect public-funding form is clearly established. (Law No. 298 on Basic Provisions of Elections and Voter Registers, Arts. 59, 60)
Is the provision of direct public funding to political parties related to gender equality among candidates?	No. Treasury aid eligibility and amount depend on participation rights and prior-election results, not on gender equality among candidates. (Political Parties Law No. 2820, Additional Art. 1)
Are there provisions for other financial advantages to encourage gender equality in political parties?	No. Absent from legal framework
Regulations on spending
Is there a ban on vote buying?	No. No explicit vote-buying prohibition was identified in the political-finance framework. Election law punishes propaganda that can affect free voting, but not an exact vote-buying rule. (Law No. 298 on Basic Provisions of Elections and Voter Registers, Art. 151)
Are there bans on state resources being used in favour or against a political party or candidate?	No. Narrow rules restrict some officials from campaigning while on duty or in official uniform, but no clear general ban on using state resources for or against parties or candidates was identified. (Law No. 2839 on Parliamentary Elections, Art. 18)
Are there limits on the amount a political party can spend?	No. Absent from legal framework
Are there limits on the amount a candidate can spend?	No. Absent from legal framework
Reporting, oversight and sanctions
Reporting standards	Yes. See subindicators
Do political parties have to report regularly on their finances?	Yes. Political parties must submit their consolidated final accounts and the final accounts of provincial organisations including districts by the end of June each year. (Political Parties Law No. 2820, Art. 74)
Do political parties have to report on their finances in relation to election campaigns?	No. Absent from legal framework
Do candidates have to report on their campaign finances?	No. Absent from legal framework
Is information in reports from political parties and/or candidates to be made public?	No. No binding rule was identified requiring party or candidate financial reports themselves to be made public. The law regulates submission for audit, not publication of the underlying reports. (Political Parties Law No. 2820, Art. 74)
Must reports from political parties and/or candidates reveal the identity of donors?	No. No explicit rule was identified requiring party or candidate financial reports to disclose donor identities as such. (Political Parties Law No. 2820, Arts. 66, 74)
Institutions receiving financial reports from political parties and/or candidates	Yes. See subindicators
Institutions receiving financial reports from political parties and/or candidates: Electoral Management Board	No. Political party accounts are not submitted to the electoral management board under the party-finance audit rules identified. (Political Parties Law No. 2820, Art. 74)
Institutions receiving financial reports from political parties and/or candidates: Auditing agency	No. The Court of Accounts assists the Constitutional Court in auditing, but the law does not require parties to submit their reports directly to an auditing agency. (Law No. 6216 on the Establishment and Rules of Procedures of the Constitutional Court, Art. 55)
Institutions receiving financial reports from political parties and/or candidates: Ministry	No. Absent from legal framework
Institutions receiving financial reports from political parties and/or candidates: Special institution	No. Absent from legal framework
Institutions receiving financial reports from political parties and/or candidates: Court	Yes. Consolidated party final accounts and provincial accounts are submitted to the Constitutional Court for financial audit. (Political Parties Law No. 2820, Art. 74; Constitution of the Republic of Türkiye, Art. 69)
Institutions receiving financial reports from political parties and/or candidates: Other	Yes. The same accounts must also be sent for information to the Chief Public Prosecutor at the Court of Cassation. (Political Parties Law No. 2820, Art. 74)
Political finance oversight	Yes. See subindicators
Is it specified that a particular institution(s) is responsible for examining financial reports and/or investigating violations?
Institution responsible for examining financial reports and/or investigating violations: Court	Yes. The Constitutional Court is the institution expressly tasked with auditing party acquisitions, revenues, expenditures and related sanctions. (Constitution of the Republic of Turkey, Art. 69; Political Parties Law No. 2820, Arts. 74-76)
Institution responsible for examining financial reports and/or investigating violations: Ministry	No. No ministry is expressly assigned to examine party financial reports or investigate political-finance violations. (Political Parties Law No. 2820, Arts. 74-75, 100, 102, 104, 106)
Institution responsible for examining financial reports and/or investigating violations: Auditing agency	No. The Court of Accounts assists the Constitutional Court in audit work, but the law does not make it the institution responsible for examining party financial reports or investigating violations. (Constitution of the Republic of Turkey, Art. 69; Political Parties Law No. 2820, Art. 75)
Institution responsible for examining financial reports and/or investigating violations: Electoral Management Body	No. The Supreme Election Council is relevant to election participation and state-aid eligibility, but no provision makes it responsible for examining party financial reports or investigating violations. (Political Parties Law No. 2820, Additional Art. 1)
Institution responsible for examining financial reports and/or investigating violations: Institution for this purpose	No. Oversight is allocated to existing institutions rather than to a dedicated institution created specifically for political-finance oversight. (Constitution of the Republic of Turkey, Art. 69; Political Parties Law No. 2820, Arts. 74-75, 100, 102, 104, 106)
Institution responsible for examining financial reports and/or investigating violations: Other	Yes. The Chief Public Prosecutor of the Court of Cassation has formal powers to request documents and bring proceedings concerning party-law violations to the Constitutional Court. (Political Parties Law No. 2820, Arts. 100, 102, 104, 106)
Other institutions with a formal role in political finance oversight
Institutions with a formal role in political finance oversight: Court	Yes. The Constitutional Court conducts the financial audit and decides on related sanctions, including Treasury forfeiture. (Constitution of the Republic of Turkey, Art. 69; Political Parties Law No. 2820, Arts. 74-76)
Institutions with a formal role in political finance oversight: Ministry	No. No ministry is expressly given a political-finance oversight role in examining reports or enforcing party-finance rules. (Political Parties Law No. 2820, Arts. 74-75, 100, 102, 104, 106)
Institutions with a formal role in political finance oversight: Auditing agency	Yes. The Court of Accounts is formally assigned to assist the Constitutional Court in auditing political parties. (Constitution of the Republic of Turkey, Art. 69; Political Parties Law No. 2820, Art. 75)
Institutions with a formal role in political finance oversight: EMB	No. No provision gives the Supreme Election Council a formal oversight role over party financial reporting or political-finance violations. (Political Parties Law No. 2820, Additional Art. 1)
Institutions with a formal role in political finance oversight: Institution for this purpose	No. The law does not establish a dedicated special-purpose institution for political-finance oversight. (Constitution of the Republic of Turkey, Art. 69; Political Parties Law No. 2820, Arts. 74-75, 100, 102, 104, 106)
Institutions with a formal role in political finance oversight: Other	Yes. The Chief Public Prosecutor of the Court of Cassation and local prosecutors are given formal roles in initiating and transmitting party-law violation proceedings. (Political Parties Law No. 2820, Arts. 100, 102, 104, 106)
Sanctions for political finance infractions
Sanctions for political finance infractions: Fines	Yes. Several provisions impose monetary penalties, including judicial fines and monetary sanctions, for party-law breaches. (Political Parties Law No. 2820, Arts. 111, 114, 115)
Sanctions for political finance infractions: Loss of public funding	Yes. State aid may be withheld in proceedings under Article 102, and future Treasury aid is reduced by twice the value of revenues or property confiscated under Article 76. (Constitution of the Republic of Turkey, Art. 69; Political Parties Law No. 2820, Art. 102; Additional Art. 1)
Sanctions for political finance infractions: Penal/Criminal	Yes. The law creates criminal penalties, including imprisonment, for several political-finance and party-law offences. (Political Parties Law No. 2820, Arts. 111, 112, 113, 114, 116)
Sanctions for political finance infractions: Forfeiture	Yes. Unlawful donations, income and excess property value are explicitly subject to Treasury forfeiture or registration in the Treasury’s name. (Political Parties Law No. 2820, Arts. 75-76)
Sanctions for political finance infractions: Deregistration of party	No. The framework provides closure and invalidation of unlawful names, emblems or abbreviations, but no deregistration sanction specifically for political-finance infractions was identified. (Constitution of the Republic of Turkey, Art. 69; Political Parties Law No. 2820, Arts. 104, 107)
Sanctions for political finance infractions: Loss of elected office	No. Absent from legal framework
Sanctions for political finance infractions: Suspension of political party	No. The law provides party closure in specified cases, but no temporary suspension sanction for political-finance infractions was identified. (Constitution of the Republic of Turkey, Art. 69; Political Parties Law No. 2820, Art. 107)
Sanctions for political finance infractions: Loss of nomination of candidate	No. Absent from legal framework
Sanctions for political finance infractions: Loss of political rights	No. The Constitution bars certain persons from founding or serving in another party after party dissolution, but no loss of political rights sanction for political-finance infractions was identified. (Constitution of the Republic of Turkey, Art. 69)
Sanctions for political finance infractions: Other	Yes. For breaches of mandatory party-law provisions, the Constitutional Court may issue a warning, which is a sanction not otherwise listed in the coding categories. (Political Parties Law No. 2820, Art. 104)

Legislation

*Last update: 2017

Financial Disclosure

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Disclosure items						64
Filing frequency						75
Sanctions						67
Monitoring and Oversight						100
Public access to declarations						0
Alternative Metric	2012	2015	2016	2017	2020	2024	Trend
Head of State						61
Ministers						61
Members of Parliament						61
Civil servants						61

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Head of State
Disclosure items
Spouses and children included in disclosure	Yes. Asset declarations include spouse and dependent children. (Art 2 and 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Income and Assets
Real estate	Yes. Real estate must be declared. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Movable assets	Yes. Includes vehicles, valuables, etc. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Cash	No. Cash and deposits declared above certain thresholds. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Loans and Debts	Yes. Liabilities must be declared. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Income from outside employment/assets	Yes. Income sources included in declaration. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Incompatibilities
Gifts received as a public official	No. Absence of legal framework
Private firm ownership and/or stock holdings	Yes. Shares and financial interests must be declared. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Ownership of state-owned enterprises (SOEs)	No. Covered under general asset declaration (shares), not specifically distinguished. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Holding government contracts	No. Absence of legal framework
Board member, advisor, or company officer of private firm	No. Covered under general asset declaration (shares), not specifically distinguished. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Post-employment	No. Absence of legal framework
Simultaneously holding policy-making position and policy-executing position	No. Absence of legal framework
Participating in official decision-making processes that affect private interests	No. Absence of legal framework
Concurrent employment of family members in public sector	No. Absence of legal framework
Filing frequency
Filing required upon taking office	Yes. Mandatory upon entry into office. (Art 6, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Filing required upon leaving office	Yes. Final declaration required. (Art 6, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Filing required annually	No. Absence of legal framework
Ad hoc filing required upon change in assets or conflicts of interest	Yes. Required when significant changes occur. (Art 6, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	Yes. Administrative and criminal consequences possible. (Art 10, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	Yes. Criminal liability for false declarations. (Art 10, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Monitoring and Oversight
Depository body explicitly identified	Yes. Declarations submitted to competent administrative authority (e.g. Presidency / relevant body) (Art 7, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Enforcement body explicitly identified	Yes. Public prosecutors and administrative authorities. (Art 10 and 12 Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Some agency assigned responsibility for verifying submission	Yes. Authorities check submission compliance. (Art 8, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Some agency assigned responsibility for verifying accuracy	Yes. Investigations possible in case of discrepancies (Art 9, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Public access to declarations
Public availability	No. Absence of legal framework
Timing of information release specified	No. Absence of legal framework
Location(s) of access specified	No. Absence of legal framework
Cost of access specified	No. Absence of legal framework
Ministers
Disclosure items
Spouses and children included in disclosure	Yes. Asset declarations include spouse and dependent children. (Art 2 and 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Income and Assets
Real estate	Yes. Real estate must be declared. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Movable assets	Yes. Includes vehicles, valuables, etc. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Cash	No. Cash and deposits declared above certain thresholds. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Loans and Debts	Yes. Liabilities must be declared. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Income from outside employment/assets	Yes. Income sources included in declaration. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Incompatibilities
Gifts received as a public official	No. Absence of legal framework
Private firm ownership and/or stock holdings	Yes. Shares and financial interests must be declared. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Ownership of state-owned enterprises (SOEs)	No. Covered under general asset declaration (shares), not specifically distinguished. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Holding government contracts	No. Absence of legal framework
Board member, advisor, or company officer of private firm	No. Covered under general asset declaration (shares), not specifically distinguished. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Post-employment	No. Absence of legal framework
Simultaneously holding policy-making position and policy-executing position	No. Absence of legal framework
Participating in official decision-making processes that affect private interests	No. Absence of legal framework
Concurrent employment of family members in public sector	No. Absence of legal framework
Filing frequency
Filing required upon taking office	Yes. Mandatory upon entry into office. (Art 6, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Filing required upon leaving office	Yes. Final declaration required. (Art 6, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Filing required annually	No. Absence of legal framework
Ad hoc filing required upon change in assets or conflicts of interest	Yes. Required when significant changes occur. (Art 6, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	Yes. Administrative and criminal consequences possible. (Art 10, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	Yes. Criminal liability for false declarations. (Art 10, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Monitoring and Oversight
Depository body explicitly identified	Yes. Declarations submitted to competent administrative authority (e.g. Presidency / relevant body) (Art 7, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Enforcement body explicitly identified	Yes. Public prosecutors and administrative authorities. (Art 10 and 12 Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Some agency assigned responsibility for verifying submission	Yes. Authorities check submission compliance. (Art 8, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Some agency assigned responsibility for verifying accuracy	Yes. Investigations possible in case of discrepancies (Art 9, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Public access to declarations
Public availability	No. Absence of legal framework
Timing of information release specified	No. Absence of legal framework
Location(s) of access specified	No. Absence of legal framework
Cost of access specified	No. Absence of legal framework
Members of Parliament
Disclosure items
Spouses and children included in disclosure	Yes. Asset declarations include spouse and dependent children. (Art 2 and 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Income and Assets
Real estate	Yes. Real estate must be declared. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Movable assets	Yes. Includes vehicles, valuables, etc. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Cash	No. Cash and deposits declared above certain thresholds. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Loans and Debts	Yes. Liabilities must be declared. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Income from outside employment/assets	Yes. Income sources included in declaration. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Incompatibilities
Gifts received as a public official	No. Absence of legal framework
Private firm ownership and/or stock holdings	Yes. Shares and financial interests must be declared. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Ownership of state-owned enterprises (SOEs)	No. Covered under general asset declaration (shares), not specifically distinguished. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Holding government contracts	No. Absence of legal framework
Board member, advisor, or company officer of private firm	No. Covered under general asset declaration (shares), not specifically distinguished. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Post-employment	No. Absence of legal framework
Simultaneously holding policy-making position and policy-executing position	No. Absence of legal framework
Participating in official decision-making processes that affect private interests	No. Absence of legal framework
Concurrent employment of family members in public sector	No. Absence of legal framework
Filing frequency
Filing required upon taking office	Yes. Mandatory upon entry into office. (Art 6, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Filing required upon leaving office	Yes. Final declaration required. (Art 6, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Filing required annually	No. Absence of legal framework
Ad hoc filing required upon change in assets or conflicts of interest	Yes. Required when significant changes occur. (Art 6, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	Yes. Administrative and criminal consequences possible. (Art 10, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	Yes. Criminal liability for false declarations. (Art 10, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Monitoring and Oversight
Depository body explicitly identified	Yes. Declarations submitted to competent administrative authority (e.g. Presidency / relevant body) (Art 7, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Enforcement body explicitly identified	Yes. Public prosecutors and administrative authorities. (Art 10 and 12 Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Some agency assigned responsibility for verifying submission	Yes. Authorities check submission compliance. (Art 8, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Some agency assigned responsibility for verifying accuracy	Yes. Investigations possible in case of discrepancies (Art 9, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Public access to declarations
Public availability	No. Absence of legal framework
Timing of information release specified	No. Absence of legal framework
Location(s) of access specified	No. Absence of legal framework
Cost of access specified	No. Absence of legal framework
Civil servants
Disclosure items
Spouses and children included in disclosure	Yes. Asset declarations include spouse and dependent children. (Art 2 and 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Income and Assets
Real estate	Yes. Real estate must be declared. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Movable assets	Yes. Includes vehicles, valuables, etc. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Cash	No. Cash and deposits declared above certain thresholds. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Loans and Debts	Yes. Liabilities must be declared. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Income from outside employment/assets	Yes. Income sources included in declaration. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Incompatibilities
Gifts received as a public official	No. Absence of legal framework
Private firm ownership and/or stock holdings	Yes. Shares and financial interests must be declared. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Ownership of state-owned enterprises (SOEs)	No. Covered under general asset declaration (shares), not specifically distinguished. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Holding government contracts	No. Absence of legal framework
Board member, advisor, or company officer of private firm	No. Covered under general asset declaration (shares), not specifically distinguished. (Art 5, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Post-employment	No. Absence of legal framework
Simultaneously holding policy-making position and policy-executing position	No. Absence of legal framework
Participating in official decision-making processes that affect private interests	No. Absence of legal framework
Concurrent employment of family members in public sector	No. Absence of legal framework
Filing frequency
Filing required upon taking office	Yes. Mandatory upon entry into office. (Art 6, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Filing required upon leaving office	Yes. Final declaration required. (Art 6, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Filing required annually	No. Absence of legal framework
Ad hoc filing required upon change in assets or conflicts of interest	Yes. Required when significant changes occur. (Art 6, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	Yes. Administrative and criminal consequences possible. (Art 10, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	Yes. Criminal liability for false declarations. (Art 10, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Monitoring and Oversight
Depository body explicitly identified	Yes. Declarations submitted to competent administrative authority (e.g. Presidency / relevant body) (Art 7, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Enforcement body explicitly identified	Yes. Public prosecutors and administrative authorities. (Art 10 and 12 Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Some agency assigned responsibility for verifying submission	Yes. Authorities check submission compliance. (Art 8, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Some agency assigned responsibility for verifying accuracy	Yes. Investigations possible in case of discrepancies (Art 9, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Public access to declarations
Public availability	No. Absence of legal framework
Timing of information release specified	No. Absence of legal framework
Location(s) of access specified	No. Absence of legal framework
Cost of access specified	No. Absence of legal framework
Holding government contracts	No. Absence of legal framework
Board member, advisor, or company officer of private firm	No. Absence of legal framework
Post-employment	No. Absence of legal framework
Simultaneously holding policy-making position and policy-executing position	No. Absence of legal framework
Participating in official decision-making processes that affect private interests	No. Absence of legal framework
Concurrent employment of family members in public sector	No. Absence of legal framework
Filing frequency
Filing required upon taking office	Yes. Mandatory upon entry into office. (Art 6, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Filing required upon leaving office	Yes. Final declaration required. (Art 6, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Filing required annually	No. Absence of legal framework
Ad hoc filing required upon change in assets or conflicts of interest	Yes. Required when significant changes occur. (Art 6, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	Yes. Administrative and criminal consequences possible. (Art 10, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	Yes. Criminal liability for false declarations. (Art 10, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Monitoring and Oversight
Depository body explicitly identified	Yes. Declarations submitted to competent administrative authority (e.g. Presidency / relevant body) (Art 7, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Enforcement body explicitly identified	Yes. Public prosecutors and administrative authorities. (Art 10 and 12 Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Some agency assigned responsibility for verifying submission	Yes. Authorities check submission compliance. (Art 8, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Some agency assigned responsibility for verifying accuracy	Yes. Investigations possible in case of discrepancies (Art 9, Law No. 3628 on Declaration of Property, Bribery and Corruption (1990) (as amended))
Public access to declarations
Public availability	No. Absence of legal framework
Timing of information release specified	No. Absence of legal framework
Location(s) of access specified	No. Absence of legal framework
Cost of access specified	No. Absence of legal framework

Legislation

*Last update: 2017

Conflict of Interest

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Restrictions						18
Sanctions						25
Monitoring and Oversight						25
Alternative Metric	2012	2015	2016	2017	2020	2024	Trend
Head of State						0
Ministers						11
Members of Parliament						18
Civil servants						61

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Head of State
Restrictions
General restriction on conflict of interest	No. Absent from legal framework
Accepting gifts	No. Absent from legal framework
Private firm ownership and/or stock holdings	No. Absent from legal framework
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework
Holding government contracts	No. Absent from legal framework
Board member, advisor, or company officer of private firm	No. Absent from legal framework
Post-employment	No. Absent from legal framework
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework
Participating in official decision-making processes that affect private interests	No. Absent from legal framework
Assisting family or friends in obtaining employment in public sector	No. Absent from legal framework
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	No. The Constitution provides a special constitutional responsibility mechanism, but no explicit administrative sanctions in the law (Constitution of the Republic of Türkiye, Art. 105)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	No. Absent from legal framework
Enforcement body specified (sanctions, hearings)	No. Absent from legal framework
Ministers
Restrictions
General restriction on conflict of interest	No. Absent from legal framework
Accepting gifts	No. Absent from legal framework
Private firm ownership and/or stock holdings	No. No rule that prohibits ministers from owning private firms or holding shares. The legal framework does, however, require disclosure of assets including shares and similar movable property. (Law on Asset Declarations, Bribery and Combating Corruption No. 3628, Arts. 2, 5)
Ownership of state-owned enterprises (SOEs)	No. No rule that generally prohibits ministers from owning shares in state-owned enterprises. The legal framework instead contains asset-declaration duties. (Law on Asset Declarations, Bribery and Combating Corruption No. 3628, Arts. 2, 5)
Holding government contracts	No. No rule that prohibits ministers from holding government contracts while in office. Provisions for asset disclosure and criminal provisions, not a stand-alone contracts ban for ministers. (Law on Asset Declarations, Bribery and Combating Corruption No. 3628, Arts. 1, 2, 5)
Board member, advisor, or company officer of private firm	No. Absent from legal framework
Post-employment	No. Absent from legal framework
Simultaneously holding policy-making position and policy-executing position	No. The Constitution says that if ministers are appointed from among Members of Parliament, their parliamentary membership ends but there is no broader stand-alone rule saying ministers may not hold any other public duty in general terms. (Constitution of the Republic of Türkiye, Art. 106)
Participating in official decision-making processes that affect private interests	No. Absent from legal framework
Assisting family or friends in obtaining employment in public sector	No. Absent from legal framework
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework
Penal sanctions are stipulated for violations of COI regulations restricting behavior	Yes. The asset-declaration law provides imprisonment for failure to submit a declaration when required, false declarations, and unlawful acquisition of property. (Law on Asset Declarations, Bribery and Combating Corruption No. 3628, Arts. 10, 11, 13)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	No. Absent from legal framework
Enforcement body specified (sanctions, hearings)	No. Absent from legal framework
Members of Parliament
Restrictions
General restriction on conflict of interest	No. Absent from legal framework.The Public Ethics Law expressly excludes members of the Grand National Assembly of Turkey
Accepting gifts	No. Absent from legal framework.The Public Ethics Law expressly excludes members of the Grand National Assembly of Turkey (Law on the Establishment of the Council of Ethics for Public Service No. 5176, Art. 2)
Private firm ownership and/or stock holdings	No. No rule that generally prohibits Members of Parliament from owning private firms or holding shares. The legal framework does, however, require disclosure of assets including shares and similar movable property, and the Constitution sets only partial incompatibility rules. (Law on Asset Declarations, Bribery and Combating Corruption No. 3628, Arts. 2, 5; Constitution of the Republic of Türkiye, Art. 82)
Ownership of state-owned enterprises (SOEs)	Yes. The Constitution bars Members of Parliament from holding office in enterprises and corporations with direct or indirect state participation and from sitting on certain executive and supervisory boards (Constitution of the Republic of Türkiye, Art. 82)
Holding government contracts	No. The Constitution forbids Members of Parliament from accepting certain contracted engagements or acting as representatives or arbitrators for listed public or part-public bodies, but there is no ban on all government contracts. (Constitution of the Republic of Türkiye, Art. 82)
Board member, advisor, or company officer of private firm	No. The Constitution contains incompatibility rules for Members of Parliament, including bans on holding office in specified public and part-public bodies and some other duties. No rule expressly prohibits private-firm board, advisory, or officer roles (Constitution of the Republic of Türkiye, Art. 82)
Post-employment	No. Absent from legal framework
Simultaneously holding policy-making position and policy-executing position	Yes. The Constitution makes parliamentary membership incompatible with a wide set of public offices and certain other functions, and persistence in an incompatible position can lead to loss of membership. (Constitution of the Republic of Türkiye, Arts. 82, 84)
Participating in official decision-making processes that affect private interests	No. Absent from legal framework
Assisting family or friends in obtaining employment in public sector	No. Absent from legal framework
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	Yes. A non-criminal sanction exists for incompatibility breaches. If a deputy persists in holding a position or service incompatible with parliamentary membership, the Grand National Assembly may decide on loss of membership. (Constitution of the Republic of Türkiye, Art. 84(3))
Penal sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	No. Absent from legal framework. The Public Ethics Board does not cover members of the Grand National Assembly of Turkey.
Enforcement body specified (sanctions, hearings)	No. Absent from legal framework. The Public Ethics Board does not cover members of the Grand National Assembly of Turkey.
Civil servants
Restrictions
General restriction on conflict of interest	Yes. Civil servants are covered by the public-service ethics framework and must avoid conflicts of interest and notify their superiors when a conflict arises or appears likely to arise. (Law on the Establishment of the Council of Ethics for Public Service No. 5176, Arts. 1, 3, 4; Regulation on the Principles of Ethical Behavior of Public Officials and Application Procedures and Principles, Art. 13)
Accepting gifts	Yes. Civil servants may not request or accept gifts directly or indirectly, and may not accept gifts or borrow money from business owners for benefit. The ethics regulation also prohibits gifts or benefits that affect or may affect impartial performance. (Civil Servants Law No. 657, Art. 29; Law on the Establishment of the Council of Ethics for Public Service No. 5176, Art. 9; Regulation on the Principles of Ethical Behavior of Public Officials and Application Procedures and Principles, Art. 15)
Private firm ownership and/or stock holdings	No. Civil servants may not engage in trade or other gainful activities and may not hold certain business roles, but I did not identify a blanket ban on all ownership of private firms or all shareholding. The framework also contains asset-declaration duties. (Civil Servants Law No. 657, Art. 28; Law on Asset Declarations, Bribery and Combating Corruption No. 3628, Arts. 2, 5)
Ownership of state-owned enterprises (SOEs)	No. No rule that generally prohibits civil servants from owning shares in state-owned enterprises. The legal framework prohibits certain offices and gainful activities, not shareholding as such. (Civil Servants Law No. 657, Art. 28; Law on Asset Declarations, Bribery and Combating Corruption No. 3628, Arts. 2, 5)
Holding government contracts	No. No rule that generally prohibits civil servants from holding government contracts as such. The framework I identified is based on ethics, incompatibility, and asset disclosure rather than a stand-alone contracts ban. (Law on Asset Declarations, Bribery and Combating Corruption No. 3628, Arts. 1, 2, 5)
Board member, advisor, or company officer of private firm	No. Civil servants may not engage in trade and may not hold a range of commercial roles, but I did not identify a binding rule that expressly and generally prohibits every private-firm board, advisory, or officer role as such. The restriction is therefore only partial. (Civil Servants Law No. 657, Art. 28)
Post-employment	Yes. For two years after leaving office, former public officials may not undertake work or transactions before, against, or in relation to the office, department, administration, or institution where they served. (Law on Works That Those Who Have Left Public Service Cannot Perform No. 2531, Art. 2)
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework
Participating in official decision-making processes that affect private interests	Yes. Civil servants must avoid real or apparent conflicts of interest, take the steps needed to prevent them, and notify their superiors as soon as they become aware of such a situation. (Regulation on the Principles of Ethical Behavior of Public Officials and Application Procedures and Principles, Art. 13)
Assisting family or friends in obtaining employment in public sector	Yes. The ethics regulation expressly prohibits favoritism and nepotism. Civil servants may not use their duty or authority to benefit relatives or third persons, and may not engage in favoritism toward relatives, friends, or fellow townsmen. (Regulation on the Principles of Ethical Behavior of Public Officials and Application Procedures and Principles, Art. 14)
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	No. No administrative fine specifically attached to civil servants’ conflict-of-interest and ethics restrictions. The main consequences are disciplinary sanctions, while the asset-declaration law provides criminal penalties for declaration-related offences. (Civil Servants Law No. 657, Arts. 124, 125; Law on Asset Declarations, Bribery and Combating Corruption No. 3628, Arts. 10-13)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	Yes. Administrative or disciplinary sanctions are expressly provided. Civil servants may receive warning, reprimand, salary deduction, suspension of grade advancement, or dismissal from the civil service. (Civil Servants Law No. 657, Arts. 124, 125)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	No. No criminal offence consisting simply of breaching civil-service conflict-of-interest and ethics restrictions. The binding framework instead provides disciplinary sanctions and separate criminal penalties for declaration-related offences. (Civil Servants Law No. 657, Arts. 124, 125; Law on Asset Declarations, Bribery and Combating Corruption No. 3628, Arts. 10-13)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	Yes. The Council of Ethics for Public Service determines ethical principles, conducts examinations and investigations, and for lower-level officials the authorized disciplinary committees assess alleged breaches of ethical principles. (Law on the Establishment of the Council of Ethics for Public Service No. 5176, Arts. 3, 4)
Enforcement body specified (sanctions, hearings)	Yes. The Council of Ethics for Public Service examines higher-level cases, while authorized disciplinary committees handle other public officials; disciplinary sanctions are then imposed under the civil-service law. (Law on the Establishment of the Council of Ethics for Public Service No. 5176, Arts. 4, 5; Civil Servants Law No. 657, Arts. 124, 125)

Legislation

*Last update: 2017

Freedom of Information

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Scope and Coverage						82
Information access and release						75
Exceptions and Overrides						67
Sanctions for non-compliance						33
Monitoring and Oversight						17

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Scope and Coverage
Scope of disclosure
Existence of legal right to access	Yes. Everyone has the right to access information. Foreigners residing in Türkiye and foreign legal entities operating in Türkiye may benefit from the provisions of this Law, provided that the information they request is related to themselves or their field of activity, and within the framework of the principle of reciprocity. Türkiye reserves the right and obligations arising from international agreements to which it is a party. (Article 4 of Law no. 4982/2004 „Right to Information Act”)
"Information" or "Documents" is defined	Yes. c) Information: All data within the scope of this Law contained in the records held by institutions and organizations, d) Document: Written, printed or reproduced files, documents, books, magazines, brochures, studies, letters, programs, instructions, sketches, plans, films, photographs, tape and video cassettes, maps, and all kinds of information, news and data carriers recorded in electronic media, owned by institutions and organizations within the scope of this Law. (Article 3 of Law no. 4982/2004 „Right to Information Act”)
Proactive disclosure is specified	No. Absent from legal framework (Absent from legal framework)
Coverage of public and private sectors
Executive branch	Yes. a) Institutions and organizations: All authorities and agencies to which information requests are made, as defined in Article 2 of this Law and included within its scope. (Article 3 of Law no. 4982/2004 „Right to Information Act”)
Legislative branch	Yes. a) Institutions and organizations: All authorities and agencies to which information requests are made, as defined in Article 2 of this Law and included within its scope. (Article 3 of Law no. 4982/2004 „Right to Information Act”)
Judicial branch	Yes. a) Institutions and organizations: All authorities and agencies to which information requests are made, as defined in Article 2 of this Law and included within its scope. (Article 3 of Law no. 4982/2004 „Right to Information Act”)
Other public bodies	Yes. a) Institutions and organizations: All authorities and agencies to which information requests are made, as defined in Article 2 of this Law and included within its scope. (Article 3 of Law no. 4982/2004 „Right to Information Act”)
Private sector	No. Absent from legal framework (Absent from legal framework)
Access to specific documents (subject to reactive and/or proactive disclosure)
Draft legal instruments	Yes. c) Information: All data within the scope of this Law contained in the records held by institutions and organizations, d) Document: Written, printed or reproduced files, documents, books, magazines, brochures, studies, letters, programs, instructions, sketches, plans, films, photographs, tape and video cassettes, maps, and all kinds of information, news and data carriers recorded in electronic media, owned by institutions and organizations within the scope of this Law. (Article 3 of Law no. 4982/2004 „Right to Information Act”)
Enacted legal instruments	Yes. c) Information: All data within the scope of this Law contained in the records held by institutions and organizations, d) Document: Written, printed or reproduced files, documents, books, magazines, brochures, studies, letters, programs, instructions, sketches, plans, films, photographs, tape and video cassettes, maps, and all kinds of information, news and data carriers recorded in electronic media, owned by institutions and organizations within the scope of this Law. (Article 3 of Law no. 4982/2004 „Right to Information Act”)
Annual budgets	Yes. c) Information: All data within the scope of this Law contained in the records held by institutions and organizations, d) Document: Written, printed or reproduced files, documents, books, magazines, brochures, studies, letters, programs, instructions, sketches, plans, films, photographs, tape and video cassettes, maps, and all kinds of information, news and data carriers recorded in electronic media, owned by institutions and organizations within the scope of this Law. (Article 3 of Law no. 4982/2004 „Right to Information Act”)
Annual chart of accounts (actual expenditures)	Yes. c) Information: All data within the scope of this Law contained in the records held by institutions and organizations, d) Document: Written, printed or reproduced files, documents, books, magazines, brochures, studies, letters, programs, instructions, sketches, plans, films, photographs, tape and video cassettes, maps, and all kinds of information, news and data carriers recorded in electronic media, owned by institutions and organizations within the scope of this Law. (Article 3 of Law no. 4982/2004 „Right to Information Act”)
Annual reports of public entities and programs	Yes. c) Information: All data within the scope of this Law contained in the records held by institutions and organizations, d) Document: Written, printed or reproduced files, documents, books, magazines, brochures, studies, letters, programs, instructions, sketches, plans, films, photographs, tape and video cassettes, maps, and all kinds of information, news and data carriers recorded in electronic media, owned by institutions and organizations within the scope of this Law. (Article 3 of Law no. 4982/2004 „Right to Information Act”)
Information access and release
Procedural access
Universal access (agencies, citizens and non-citizens)	No. Everyone has the right to access information. Foreigners residing in Türkiye and foreign legal entities operating in Türkiye may benefit from the provisions of this Law, provided that the information they request is related to themselves or their field of activity, and within the framework of the principle of reciprocity. Türkiye reserves the right and obligations arising from international agreements to which it is a party. (Article 4 of Law no. 4982/2004 „Right to Information Act”)
Type of request is specified (written, electronic, oral)	Yes. Article 6 - Applications for information are submitted to the institution or organization holding the requested information or document, using a petition that includes the applicant's name and surname, signature, residential or business address, or, if the applicant is a legal entity, the title and address of the legal entity, the signature of the authorized person, and the authorization document. This application may also be made electronically or through other means of communication, provided that the applicant's identity and signature, or other information that can legally identify the source of the writing, can be determined. The application must clearly specify the information or documents requested. (Article 6 of Law no. 4982/2004 „Right to Information Act”)
Assistance to requesters must be provided by law (includes barriers due to language differences, illiteracy, complexity of requests, etc.)	No. Absent from legal framework (Absent from legal framework)
Cost of access is specified (free, request fees, photocopying costs, other administrative costs)	Yes. The institution or organization to which the application is made may charge the applicant a fee equal to the cost of accessing the information or documents provided, to be recorded as revenue in the budget. (Article 10 of Law no. 4982/2004 „Right to Information Act”)
Deadlines for release of information
20-day response deadline	Yes. Institutions and organizations shall provide access to the requested information or documents within fifteen working days of the application. However, if the requested information or document must be obtained from another unit within the institution or organization to which the application was submitted; if it is necessary to obtain the opinion of another institution or organization regarding the application; or if the content of the application concerns more than one institution or organization, access to the information or document shall be provided within thirty working days. (Article 11 of Law no. 4982/2004 „Right to Information Act”)
Agency granted right to extend response time	Yes. Institutions and organizations shall provide access to the requested information or documents within fifteen working days of the application. However, if the requested information or document must be obtained from another unit within the institution or organization to which the application was submitted; if it is necessary to obtain the opinion of another institution or organization regarding the application; or if the content of the application concerns more than one institution or organization, access to the information or document shall be provided within thirty working days. (Article 11 of Law no. 4982/2004 „Right to Information Act”)
Maximum total response time of no more than 40 days	Yes. Institutions and organizations shall provide access to the requested information or documents within fifteen working days of the application. However, if the requested information or document must be obtained from another unit within the institution or organization to which the application was submitted; if it is necessary to obtain the opinion of another institution or organization regarding the application; or if the content of the application concerns more than one institution or organization, access to the information or document shall be provided within thirty working days. (Article 11 of Law no. 4982/2004 „Right to Information Act”)
Exceptions and Overrides
Exemptions to disclosure
Existence of secrecy/states secrets law	No. Absent from legal framework (Absent from legal framework)
Existence of personal privacy/data law	Yes. Law No. 6698 on the Protection of Personal Data (Law No. 6698 on the Protection of Personal Data)
Specific exemptions to disclosure	Yes. Articles 15-28 of the Law describe the limitation in access to public information (Article 15-28 of Law no. 4982/2004 „Right to Information Act”)
Public Interest test: Specified exemptions to disclosure may be overridden in cases where disclosure of information benefits the public interest.
Appeals
Appeals allowed within public entities	No. Absent from legal framework (Absent from legal framework)
Independent, non-judicial appeals mechanism, e.g., information commissioner. Does not include Ombudsman unless appeals decisions are binding.	Yes. The applicant whose request for information (…) [1] is rejected may appeal to the Board within fifteen days of the notification of the decision before resorting to judicial remedies. The Board shall give its decision on this matter within thirty working days. Institutions and organizations are obliged to provide the Board with any information or documents it requests within fifteen working days. /// In order to review the decisions made regarding objections to information access requests, and to make decisions regarding the use of the right to access information for institutions and organizations, an Information Access Evaluation Board has been established. (Articles 13 and 14 of Law no. 4982/2004 „Right to Information Act”)
Judicial appeals mechanism	Yes. Article 13 - The applicant whose request for information (…) [1] is rejected may appeal to the Board within fifteen days of the notification of the decision before resorting to judicial remedies. The Board shall give its decision on this matter within thirty working days. Institutions and organizations are obliged to provide the Board with any information or documents it requests within fifteen working days. An appeal to the board suspends the applicant's time limit for filing an appeal with the administrative courts. (Articles 13 of Law no. 4982/2004 „Right to Information Act”)
Sanctions for non-compliance
Administrative sanctions are specified for violations of disclosure requirements	Yes. Penal provisions Article 29 - Officials and other public servants who are found to have acted negligently, carelessly, or intentionally in the application of this Law shall be subject to disciplinary penalties as stipulated in the legislation to which they are subject, without prejudice to the possibility of criminal prosecution under general provisions for the acts they have committed. Information and documents accessed through this Law may not be reproduced or used for commercial purposes. (Article 29 of Law no. 4982/2004 „Right to Information Act”)
Fines are specified for violations of disclosure requirements	No. Absent from legal framework (Absent from legal framework)
Criminal sanctions are specified for violations of disclosure requirements	No. Absent from legal framework (Absent from legal framework)
Monitoring and Oversight
Information officers must be appointed in public agencies	No. Absent from legal framework (Absent from legal framework)
Public body that is responsible for applying sanctions	No. Absent from legal framework (Absent from legal framework)
Public body that is responsible for public outreach (raising public awareness)	No. Absent from legal framework (Absent from legal framework)
Nodal agency for RTI (implementation support/compliance within public sector). Does not include Ombudsman.	No. Absent from legal framework (Absent from legal framework)
Ombudsman involvement in implementation is specified by law	No. Absent from legal framework (Absent from legal framework)
Reporting of data and/or implementation is required	Yes. Article 30 - Institutions and organizations shall submit the following data for the previous year: a) The number of information requests they receive, b) The number of applications that were answered positively, providing access to the information or documents. c) Statistical information showing the number of rejected applications and their distribution, d) The number of applications in which access to information or documents was granted after removing or separating confidential or secret information, e) The number of appeals filed after an application was rejected, and their outcomes. They prepare an explanatory report and send these reports to the Information Access Evaluation Board by the end of February each year. Affiliated, related, and associated public institutions and organizations submit their reports through the ministry to which they are affiliated, related, or associated. The Board sends the general report it prepares, along with the reports of the aforementioned institutions and organizations, to the Grand National Assembly of Turkey by the end of April each year. These reports are made public by the Presidency of the Grand National Assembly of Turkey within two months of the following day. (Article 30 of Law no. 4982/2004 „Right to Information Act”)

Legislation

*Last update: 2017

Public Procurement

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Scope						97
Information availability						94
Evaluation						62
Open competition						64
Institutional arrangements						36

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Scope
Threshold - lowest PP
What is the minimum contract value above which the public procurement law is applied? (Product type GOODS)	TRY 207,453. Law applies from 0 TRY; the first threshold (Art. 8) triggers differentiated notice periods (shorter/longer) and domestic preference rules; for goods, the domestic preference threshold (~EUR 500,000 equivalent) determines whether the contracting authority may restrict participation to domestic bidders only; above this: participation must be open to foreign bidders. (Law No. 4734, Arts. 8, 13, 63)
What is the minimum contract value above which the public procurement law is applied? (Product type WORKS)	TRY 207,453. For works, the Art. 8 threshold (approximately EUR 12 million equivalent, updated annually) determines: (a) whether the restricted procedure may be used (approximate cost above 50% = ~EUR 6 million of this threshold); (b) domestic preference eligibility (below threshold: only domestic bidders may be required; above: must be open to foreign bidders). (Law No. 4734, Arts. 8, 20, 63)
What is the minimum contract value above which the public procurement law is applied? (Product type SERVICES)	TRY 207,453. Same structure as goods; the domestic preference/international openness threshold for services is approximately EUR 500,000 equivalent; below this, the contracting authority may restrict participation to domestic bidders; above this, foreign bidders must be permitted. (Law No. 4734, Arts. 8, 13, 63)
Threshold - by PP type
What are the minimum application thresholds for the procurement type? (Entity: PUBLIC SECTOR)	TRY 207,453. All central government bodies, local authorities and institutions meeting the Art. 2 definition apply Law No. 4734 from 0 TRY; Art. 8 thresholds differentiate notice periods and procedure eligibility but not applicability of the law; threshold levels are denominated in TRY and updated annually. (Law No. 4734, Arts. 2, 8)
What are the minimum application thresholds for the procurement type? (Entity: UTILITIES)	TRY 207,453. The majority of utilities procurement in Turkey is conducted under Article 3 exemptions of Law No. 4734, with each sector (energy, water, transport) governed by ministry- or sector-specific regulations; this is identified as a major gap vs. EU Directive 2014/25/EU and is explicitly flagged by the EU Turkey 2024 Report; there is no equivalent of Directive 2014/25/EU in Turkish law. (Law No. 4734, Art. 3; EU Turkey Report 2024)
What are the minimum application thresholds for the procurement type? (Entity: DEFENCE)	TRY 207,453. Defence and security procurement is generally exempt where secrecy or special security measures apply, but the operative lower procedural monetary limit used in practice for this workbook is the 2024 direct procurement limit of TRY 207,453; (Law No. 4734, Art. 3(b); KIK 2024 monetary limits table)
Threshold - by product type
What are the minimum application thresholds for the procurement type? (Product type GOODS)	TRY 207,453. Below Art. 8 goods threshold: domestic-only restriction permitted; above: must be open to foreign bidders; direct procurement (Art. 21/f) applies below the annual KİK limit for urgently needed goods; all other procedures may be used without value restriction. (Law No. 4734, Arts. 8, 21, 63)
What are the minimum application thresholds for the procurement type? (Product type WORKS)	TRY 207,453. Below 50% of the Art. 8 threshold: only open procedure available; above 50%: restricted procedure also available; above the full Art. 8 threshold: must be open to foreign bidders; direct procurement (Art. 21/f) available below annual KİK limit. (Law No. 4734, Arts. 8, 20, 63)
What are the minimum application thresholds for the procurement type? (Product type SERVICES)	TRY 207,453. Same structure as goods; consultancy services follow the same thresholds; direct procurement (Art. 21/f) available below annual KİK limit. (Law No. 4734, Arts. 8, 21, 63)
Information availability
Publishing and record keeping
Is there a requirement that tender documents must published in full?	Yes. All tender documentation (administrative specifications, technical specifications, contract drafts) must be published on EKAP from the date of notice publication; documents are downloadable free of charge; clarifications and amendments to tender documents must also be published through EKAP at least 10 days before the tender date. (Law No. 4734, Arts. 13–14; EKAP system)
Are any of these documents published online at a central place?	Yes. EKAP (Electronic Public Procurement Platform): https://ekap.kik.gov.tr (mandatory for all PPL-covered procurement since 2011 for notices, 2016 for e-bidding); EKAP API v2: available for programmatic data access; Official Gazette (Resmî Gazete) for legislation; KİK website: https://www.kik.gov.tr; EKAP is the single mandatory publication platform for all Law No. 4734 procurement. (Law No. 4734, Art. 13; EKAP system)
Is it mandatory to keep all of these records? -Public notices of bidding opportunities, -Bidding documents and addenda, -Bid opening records, -Bid evaluation reports, -Formal appeals by bidders and outcomes, -Final signed contract documents and addenda and amendments, -Claims and dispute resolutions, -Final payments, -Disbursement data (as required by the country’s financial management system)	Yes. Contracting authorities must maintain complete procurement files; EKAP tracks all stages; Law No. 4735 requires comprehensive contract implementation documentation including progress payments, contract modifications and acceptance procedures; the Inspection and Acceptance Regulations (issued by KİK) guide the implementation of Law No. 4735. (Law No. 4734; Law No. 4735; Inspection and Acceptance Regulations)
Are contracts awarded within a framework agreement published (ie mini contracts)?	Yes. Framework agreement call-off contracts are processed through EKAP (Additional Article 2 of Law No. 4734); EKAP tracks mini-contract awards; however, OCDS is not implemented and bulk export of call-off data is not systematically available for public analysis. (Law No. 4734, Additional Art. 2; EKAP system)
Sub-contracting
Is it mandatory to publish information on subcontractors (ie names) in some cases?	Yes. Law No. 4734 and implementing regulations require declaration of subcontractors; subcontractor information is published through EKAP as part of contract documentation; EKAP tracks subcontractor details for PPL-covered contracts. (Law No. 4734; EKAP system)
If yes, what is the threshold for publication (i.e. the % of total contract value subcontracted)? For example, if the threshold is 75%, and you have subcontracted out only 40% of your contract, no disclosure is required. Consultant will insert 75% in the short answer column.	0%. All known subcontractors must be declared regardless of the proportion subcontracted; no percentage threshold triggers or exempts the disclosure obligation under Law No. 4734. (Law No. 4734)
Evaluation
Preferential treatment
Is there a ban on mentioning specific companies or brands in tender specification/call for tender?	Yes. Technical specifications may not refer to a specific manufacturer, origin, process, trademark, patent, type, or place of production in a way that favours or eliminates operators; such references must include "or equivalent"; aligned with EU practice. (Law No. 4734)
Is there a preferential treatment for small-to-medium enterprises (SMEs)?	No. No explicit preferential treatment for SMEs exists in Law No. 4734; principles of equal treatment and non-discrimination apply; lot division is permitted for unit-price tenders, facilitating SME access; the law prohibits artificial contract splitting to fall below thresholds. (Law No. 4734, Arts. 7, 19)
Is there a preferential treatment for local/national companies? (companies from other EU MS are considered foreign companies)	Yes. Article 63 of Law No. 4734 explicitly allows a domestic price advantage of up to 15% for goods and up to 15% for construction works in favour of domestic (Turkish) tenderers in tenders above the threshold; below the Art. 8 threshold, contracting authorities may restrict participation to domestic bidders only for goods and services; this is a legally enshrined domestic preference mechanism and is one of the major structural divergences from EU acquis identified by the EU Turkey 2024 Report. (Law No. 4734, Art. 63; EU Turkey Report 2024)
Is there a specific set of rules for green/sustainable procurement?	No. Law No. 4734 permits inclusion of environmental criteria in technical specifications and award criteria but does not mandate green procurement; Presidential Circular No. 2024/7 introduced restrictions on requiring non-subject equipment (vehicles, computers, etc.) in procurement documents – a minor efficiency improvement; no national GPP strategy adopted; this is identified as a gap by the EU Turkey 2024 Report. (Law No. 4734; Presidential Circular No. 2024/7; EU Turkey 2024 Report)
Bid evaluation
Are there restrictions on allowable grounds for tenderer exclusion?	Yes. Law No. 4734 (Art. 10) establishes mandatory and discretionary exclusion grounds: mandatory – criminal conviction for specified offences; bankruptcy/insolvency; fraudulent or false declarations; provision of false documents; non-payment of taxes or social security contributions; previous public contract penalties; debarment for corrupt practices; Turkey has a debarment/blacklist system (yasak kararı) under Arts. 58–60 of Law No. 4734: the PPA maintains a publicly accessible list of debarred economic operators; debarment periods are 1–2 years and may be applied to persons, companies and associated persons. (Law No. 4734, Arts. 10, 58–60; KİK Debarment Registry)
Are some bids automatically excluded? e.g., lowest/highest price; unusually low price, etc.	Yes. For services and construction tenders, secondary legislation allows contracting authorities to automatically exclude tenders below the "limit value" (statistical threshold calculated from submitted bids and approximate cost) without a clarification procedure, if this is stated in the procurement document; for goods tenders, there is no limit value methodology in secondary legislation, so abnormally low goods bids cannot be automatically excluded and must be assessed individually; this is a significant departure from EU Directive practice (which requires clarification before exclusion). (Law No. 4734, Arts. 38; Construction Works Tender Implementation Regulation; Service Procurement Regulation)
Is scoring criteria published?	Yes. Contracting authorities must publish award criteria and their relative weights in the procurement documents; the mandatory award criterion under Law No. 4734 is the most economically advantageous tender (MEAT) – defined as either lowest price alone or price combined with non-price factors (operation/maintenance cost, quality, technical value, productivity); however, in 2024, approximately 55% of PPL-covered procurement (EUR 27.33 billion) was via open procedures and 44% (EUR 21.7 billion) via negotiated procedure; lowest price dominates in practice; non-price criteria must have their monetary values or relative weights specified in documents. (Law No. 4734, Arts. 36–40; KİK 2024 Annual Statistics)
Are decisions always made by a committee?	Yes. Law No. 4734 requires each tender to be conducted by a Procurement Commission (ihale komisyonu) consisting of at least 5 persons: the head (an authorised officer), two members with relevant technical expertise, one financial/accounting officer, and one legal adviser; where technical expertise is required, external experts may be co-opted; the commission must have an odd number of members. (Law No. 4734, Art. 6)
Are there regulations on evaluation committee composition to prevent conflict of interest?	Yes. Article 11 of Law No. 4734 ("those who cannot participate in the tender") prohibits participation by: contracting officers and their spouses, relatives up to 3rd degree and marital relatives up to 2nd degree; persons assigned to prepare, execute or approve any procurement transaction; partners and companies of the above; consultancy service providers for the same work; violation results in exclusion and forfeiture of bid security; if discovered after award, the procurement procedure is cancelled and bid security forfeited. (Law No. 4734, Art. 11)
Is some part of evaluation committee mandatorily independent of contracting authority?	No. There is no legal requirement for procurement commission members to be independent of the contracting authority; commission members are officials of the contracting authority; external experts may be co-opted where technical expertise is required but are not mandatory. (Law No. 4734, Art. 6)
Are scoring results publicly available?	Yes. Award decisions and their reasoning are published through EKAP; all tenderers participating in a tender are notified of the finalised decision, including excluded tenderers and reasons for exclusion; EKAP publishes contract award notices; EKAP API v2 allows programmatic access to award data; however, EKAP does not implement OCDS and bulk data analysis capacity is limited; the KİK Annual Statistics report (2024 edition, EUR 68.9 billion total) provides aggregate market data; exempt procurement (EUR 12.28 billion, 2024) has no public award data. (Law No. 4734, Arts. 41, 47; EKAP system; KİK 2024 Annual Statistics)
Does the law specify under which conditions the tender can be cancelled?	Yes. Law No. 4734 (Art. 39) specifies conditions for cancellation: no tender was received; all tenders were found unacceptable; fundamental circumstances have changed; the tender is vitiated by an error; overriding public interest; cancellation requires a reasoned decision published through EKAP; contracting authorities may cancel at their discretion if the Art. 39 conditions are met; the contracting authority may decline to award even the most economically advantageous bid (Art. 47). (Law No. 4734, Arts. 39, 47)
Open competition
CFT publication
Does the law specify the location for publicizing open calls for tenders?	Yes. EKAP: https://ekap.kik.gov.tr (mandatory, single platform); Official Gazette (Resmî Gazete) for certain high-value or above-threshold procedures; contracting authority websites; national and local newspapers (for above-threshold procedures); EKAP is the mandatory primary channel for all Law No. 4734 procurement notices. (Law No. 4734, Art. 13; EKAP system)
Does the law specify the location for publicizing restricted calls for tenders?	Yes. EKAP: https://ekap.kik.gov.tr; restricted procedure notices must be published on EKAP; this procedure is used for works requiring specialist expertise/advanced technology or for works above 50% of the Art. 8 threshold. (Law No. 4734, Arts. 13, 20; EKAP system)
Does the law specify the location for publicizing negotiated calls for tenders?	Yes. Negotiated procedures with notice requirement (Arts. 21/a, 21/d, 21/e) are published on EKAP; negotiated procedures without notice (Arts. 21/b, 21/c, 21/f) – the most frequently used – are not pre-published on EKAP; in 2024, 44% of total PPL-covered procurement (EUR 21.7 billion) was conducted via negotiated procedures, raising major transparency concerns; only post-award reporting is required for no-notice negotiated procedures. (Law No. 4734, Art. 21; EKAP system; KİK 2024 Statistics)
Minimum # of bidders
What is the minimum number of bidders for restricted procedures?	5. For the restricted procedure, if fewer than 5 qualified tenderers can be invited to the second stage, or if fewer than 3 tenderers actually submit tenders, the procedure must be cancelled (Art. 20 of Law No. 4734). (Law No. 4734, Art. 20)
What is the minimum number of bidders for negotiated procedures?	3. For negotiated procedures without notice (Arts. 21/b, 21/c, 21/f), at least 3 tenderers must be invited to submit qualification documents and price offers; the contracting authority directly selects at least 3 companies; for negotiated procedures with notice (Arts. 21/a, 21/d, 21/e), no statutory minimum number of invitees is set (any qualified tenderer may participate). (Law No. 4734, Art. 21)
What is the minimum number of bidders for competitive dialogue procedures?	N/A. Law No. 4734 does not include a competitive dialogue procedure; the law uses three procedure types only: open, restricted, and negotiated; Turkey has not introduced the competitive dialogue, competitive negotiation or innovation partnership procedures available under EU Directive 2014/24/EU – a structural gap vs. EU acquis. (Law No. 4734, Arts. 19–21)
Bidding period length
What are the minimum number of days for open procedures?	10. Law No. 4734 sets differentiated minimum notice periods by value and procedure type: below the first threshold (Art. 8): minimum 10 days from notice to bid deadline (goods/services) or 15 days (works); above the first threshold but below the upper threshold: minimum 25 days (goods/services) or 40 days (works); above the upper threshold (international openness threshold): minimum 40 days (goods/services) or 52 days (works); notice periods are calculated from the publication date on EKAP. (Law No. 4734, Art. 13 (as implemented by regulations))
What are the minimum number of days for restricted procedures?	14. Two-stage restricted procedure: stage 1 (pre-qualification): minimum 14 days from pre-qualification notice to deadline; stage 2 (tender submission): minimum 25 days (below international openness threshold) or 40 days (above threshold) from invitation to tender. (Law No. 4734, Art. 20)
What are the minimum number of days for competitive negotiated procedures?	25. For negotiated procedures with notice (Art. 21/a, 21/d, 21/e): minimum 25 days from notice publication for submission of initial (non-price) tenders; the duration of negotiation rounds and the deadline for final price offers are set by the contracting authority; no minimum statutory timeframe for subsequent rounds. (Law No. 4734, Art. 21)
Institutional arrangements
Institutions and regulations
Does the law specify the main EXCEPTIONS preventing the application of the public procurement law for tenders/organisations?	Yes. Article 3 of Law No. 4734 exempts 25 categories of procurement from the law's scope (expanded from the original set): (1) defence, security and intelligence procurement; (2) energy sector procurement; (3) foreign affairs ministry procurement abroad; (4) procurement by state-owned enterprises (SOEs) conducting commercial activities; (5) Central Bank procurement; (6) privatisation administration; (7) Türkiye Wealth Fund; (8) certain housing development administration (TOKİ) procurement; (9) BOTAŞ (petroleum pipeline) procurement; (10) certain natural disaster response; plus additional categories for various state enterprises and special funds; procurement not governed by Law No. 4734 is not supervised by KİK and is not published on EKAP – it is governed by ministry- or entity-specific regulations; the EU Turkey 2024 Report explicitly states Turkey "must remove exceptions incompatible with EU acquis". (Law No. 4734, Art. 3; EU Turkey 2024 Report; KİK 2024 Statistics)
Does the law specify the main types of institutions that must apply the public procurement law?	Yes. Law No. 4734 (Art. 2) applies to: (a) public administrations under the general and special budgets (ministries, agencies, universities, local authorities); (b) special provincial administrations and municipalities and their related revolving fund organisations; (c) state economic enterprises (public corporations and state economic establishments); (d) social security institutions, funds and institutions established by law or Presidential Decree assigned with public duties; (e) institutions where more than 50% of capital is directly or indirectly owned by the above entities; notably excluded from Law No. 4734 (under Art. 3): Türkiye Wealth Fund, BOTAŞ, TOKİ, Central Bank, privatisation administration and 20 other categories of entities/activities – a major structural gap. (Law No. 4734, Arts. 2–3)
Does the law specify the main procedure types or procurement methods permitted?	Yes. Turkey's Law No. 4734 uses only 3 procedure types (open, restricted, negotiated), compared to the 7+ procedures available in EU Directive 2014/24/EU; competitive dialogue, innovation partnership, competitive negotiation, design contest (as a procurement procedure) and light-touch regime are not available in Turkish procurement law; this is identified as a structural gap vs. EU acquis; in 2024, the open procedure was used for 55% and negotiated procedure for 44% of PPL-covered procurement. (Law No. 4734, Arts. 19–21; KİK 2024 Statistics)
Is there a procurement arbitration court dedicated to public procurement cases?	Yes. The Public Procurement Authority (Kamu İhale Kurumu – KİK/PPA) (www.kik.gov.tr) performs a dual role: it is both the central regulatory body AND the first-instance review body for complaints (appeals/itirazen şikayet); this dual role is unique in the region and is a structural governance concern; the two-stage complaint process requires complainants to first file a complaint with the contracting authority (within 5 or 10 days of discovering unlawful action); if unsatisfied, they may appeal to KİK within 10 days; KİK must decide within 20 days (or 10 working days for specific negotiated procedure decisions); KİK decisions may be challenged before the Administrative Courts (Council of State / Danıştay for above-threshold issues); since 2020, complaint application fees apply. (Law No. 4734, Arts. 53–57; Regulation on Applications)
Is there a procurement regulatory body dedicated to public procurement?	Yes. The Public Procurement Authority (KİK/PPA) is both the regulatory body (issuing communiqués, regulations, standard documents, annual reports) and the review body (adjudicating complaints); it was established in 2002 alongside Law No. 4734; it issues the three implementing regulations (Construction Works, Services, Goods) and all secondary communiqués including the annual threshold update communiqué; KİK employs a professional staff of procurement experts and public procurement experts; the KİK website hosts EKAP, all regulations, standard documents and the debarment registry; the 2024 Annual Statistics report provides comprehensive market data. (Law No. 4734, Arts. 52–53; KİK Annual Statistics 2024)
Does the law specify procurement advisors' profession (i.e. degree to be obtained, official list of members of the professional association) and its role in the tendering process (e.g. right to draft tender documentations, conduct market research identifying bidders)?	No. Law No. 4734 does not establish a regulated profession of procurement adviser; procurement commission membership requires relevant expertise but no specific certification; KİK provides training programmes; no mandatory certification system exists – a gap compared to Montenegro's model. (Law No. 4734)
Is disclosure of final, beneficial owners required for placing a bid?	No. Law No. 4734 does not require beneficial ownership disclosure as a precondition for bidding; Turkey's AML framework includes a beneficial ownership register (MASAK); no linkage between the BO register and EKAP/procurement procedures has been introduced; this is identified as a gap in Turkey's EU accession context. (Law No. 4734; EU Turkey 2024 Report)
Complaints
Is there a fee for arbitration procedure?	Yes. Two-stage complaint process with fees: (1) Complaint to contracting authority: no fee; (2) Appeal to KİK (itirazen şikayet): fee payable to the State Treasury, updated annually by KİK communiqué; the fee is calculated as a percentage of the approximate cost or is a fixed amount per procurement category; if the appeal is upheld, the fee is refunded; fees are set at levels intended to deter frivolous complaints while preserving access; the Academic study on complaint appeal fees (2024) confirms that fees are stratified and updated annually. (Law No. 4734, Art. 56; KİK Annual Fee Communiqué)
Is there a ban on contract signature until arbitration court decision (first instance court)?	Yes. After the finalised tender decision is published, the contracting authority may not invite the winner to sign the contract for 10 days (this is the complaint window to the contracting authority); if a complaint is filed with the contracting authority, the standstill continues until the contracting authority decides (within 10 days); if then appealed to KİK, the contracting authority must not sign the contract until KİK decides; exception: for negotiated procedures without notice (Arts. 21/b, 21/c), no standstill applies and the contract may be signed immediately – a transparency gap. (Law No. 4734, Arts. 40, 46, 55–56)
What is the maximum number of days until arbitration court decision from filing a complaint in the case of awarded contracts?	20. KİK must issue its final decision within 20 calendar days of registration of all required documents, the procurement process dossier and the required fee; for appeals against contracts awarded under Arts. 21/b and 21/c and against cancellation decisions, the deadline is 10 working days; if KİK does not decide within the deadline, the administrative courts may be petitioned; KİK decisions are binding on contracting authorities, who must implement them immediately. (Law No. 4734, Art. 56)
Is there a requirement to publicly release arbitration court decisions ?	Yes. All KİK decisions are published on the KİK website (www.kik.gov.tr) and in the Official Gazette; KİK decisions are publicly accessible and searchable; contracting authorities are notified of KİK decisions through EKAP; KİK also publishes the publicly accessible Debarment Registry (yasak karar listesi) of operators barred from public procurement; KİK's annual statistics report includes aggregate data on complaint outcomes; administrative court decisions are published through the general judicial publication system. (Law No. 4734, Art. 57; KİK website)

Legislation

Construction Works Tenders Implementation Regulation (Turkish)	pdf
Inspection and Acceptance Regulation for Construction Works Subject to Tender (Turkish)	pdf
Public Procurement Law No. 4734 (Turkish)	pdf
Public Procurement Contracts Law No. 4735 (Turkish)	pdf
Presidential Circular No. 2024/7 on Savings Measures in the Public Sector (Turkish)	pdf
Regulation on Administrative Applications Against Procurement Proceedings (Turkish)	pdf
Service Procurement Tenders Implementation Regulation (Turkish)	pdf

*Last update: 2017

Anti Money Laundering

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Risk-based approach						0
Sanctions for natural persons						86
Sanctions for legal persons						25
Pecuniary sanctions for obliged entities						60
Beneficial ownership of legal persons and legal arrangements						5
Supervision of obliged entities						100
Financial Intelligence Units (FIUs)						83
Mutual legal assistance (MLA) and International Cooperation						50

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Country score
Risk-based approach
Each Member State shall be legally required to prepare a national risk assessment that outlines appropriate steps to identify, assess, understand and mitigate the risks of money laundering and terrorist financing affecting it.	No. Absent from legal framework (Absent from legal framework)
Member states shall be legally required to keep the national risk assessment up to date and review it at least every 4 years.	No. Absent from legal framework (Absent from legal framework)
Member states should legally designate an authority or mechanism to co-ordinate actions to assess risks.	No. Absent from legal framework (Absent from legal framework)
Sanctions for natural persons
The following conduct, when committed intentionally, is punishable as a criminal offence: the conversion or transfer of property, knowing that such property is derived from criminal activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person’s action;	Yes. ARTICLE 281-(1) Any person who takes away the assets acquired as a result of an offense which requires minimum one year or more punishment of imprisonment, or carries the same to a foreign country to be subject to various transactions in order to hide illegal source of these assets and to give the impression that they are acquired in the lawful manner, is punished with imprisonment from two years to five years, and also imposed punitive fine up to twenty thousand days. (2) In case of commission of this offense by a public officer while performing his duty or a person with profession, the punishment to be imposed is increased by one half. (3) In case of commission of this offense within the frame of activities of an organized criminal group, the punishment to be imposed is increased by one fold. (4) Legal entities involving in commission of this offense are subject to special security precautions. (5) No punishment is imposed for the offense defined in this section on a person who renders assistance or facilitates finding of assets acquired illegally as a result of offense by notifying the authorized bodies. (Article 281 of the Criminal Code of Turkey)
The following conduct, when committed intentionally, is punishable as a criminal offence: the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity;	Yes. ARTICLE 281-(1) Any person who takes away the assets acquired as a result of an offense which requires minimum one year or more punishment of imprisonment, or carries the same to a foreign country to be subject to various transactions in order to hide illegal source of these assets and to give the impression that they are acquired in the lawful manner, is punished with imprisonment from two years to five years, and also imposed punitive fine up to twenty thousand days. (2) In case of commission of this offense by a public officer while performing his duty or a person with profession, the punishment to be imposed is increased by one half. (3) In case of commission of this offense within the frame of activities of an organized criminal group, the punishment to be imposed is increased by one fold. (4) Legal entities involving in commission of this offense are subject to special security precautions. (5) No punishment is imposed for the offense defined in this section on a person who renders assistance or facilitates finding of assets acquired illegally as a result of offense by notifying the authorized bodies. (Article 281 of the Criminal Code of Turkey)
The following conduct, when committed intentionally, is punishable as a criminal offence: the acquisition, possession or use of property, knowing at the time of receipt, that such property was derived from criminal activity.	Yes. ARTICLE 281-(1) Any person who takes away the assets acquired as a result of an offense which requires minimum one year or more punishment of imprisonment, or carries the same to a foreign country to be subject to various transactions in order to hide illegal source of these assets and to give the impression that they are acquired in the lawful manner, is punished with imprisonment from two years to five years, and also imposed punitive fine up to twenty thousand days. (2) In case of commission of this offense by a public officer while performing his duty or a person with profession, the punishment to be imposed is increased by one half. (3) In case of commission of this offense within the frame of activities of an organized criminal group, the punishment to be imposed is increased by one fold. (4) Legal entities involving in commission of this offense are subject to special security precautions. (5) No punishment is imposed for the offense defined in this section on a person who renders assistance or facilitates finding of assets acquired illegally as a result of offense by notifying the authorized bodies. (Article 281 of the Criminal Code of Turkey)
Aiding and abetting, inciting and attempting a money laundering offence is punishable as a criminal offence.	(2) In case of attempt to commit crime, the offender is sentenced to imprisonment from thirteen years to twenty years instead of heavy life imprisonment according to the seriousness of the damage or danger; and imprisonment from nine years to fifteen years instead of life imprisonment. In other cases, the punishment is abated from one-fourth up to three-fourth. /// ARTICLE 38- (1) A person soliciting another person to commit offense is punished according to the degree of crime committed. (2) In case of solicitation to commit offense by using the power originating from lineage (antecedent/descendent) relation, the punishment of the soliciting person is increased from one-third to one half. The lineage relation is not sought for increase of punishment pursuant to the provisions of this subsection in case of solicitation of minors to commit offense. (3) Where the soliciting person is not known, the offender who plays role in identification of the soliciting person, or other accomplice is sentenced to imprisonment from twenty years to twenty-five years instead of heavy life imprisonment and to imprisonment from fifteen years to twenty years the offense requires life imprisonment. In other cases, one-third of the punishment can be abated. Encouragement of A person To Commit Offence ARTICLE 39- (1) A person encouraging another person to commit offense is sentenced to life imprisonment from fifteen years to twenty years if subject to heavy life imprisonment; and from ten years to fifteen years imprisonment if the offense requires life imprisonment. 2) A person is kept responsible under the following conditions from commission of offense as the party encouraging the offender; a) To solicit a person for commission of an offense or to support his decision to commit offense or to guarantee help after commission of offense. b) To give idea about how the offense shall be committed or to supply the necessary tools to be used during commission of offense. c) To render support before and during the commission of offense in order to simplify the intended act. (Articles 35, 38, 39 of the Criminal Code of Turkey)
Money laundering offences are punishable by a maximum term of imprisonment of at least four years.	Yes. ARTICLE 281-(1) Any person who takes away the assets acquired as a result of an offense which requires minimum one year or more punishment of imprisonment, or carries the same to a foreign country to be subject to various transactions in order to hide illegal source of these assets and to give the impression that they are acquired in the lawful manner, is punished with imprisonment from two years to five years, and also imposed punitive fine up to twenty thousand days. (2) In case of commission of this offense by a public officer while performing his duty or a person with profession, the punishment to be imposed is increased by one half. (3) In case of commission of this offense within the frame of activities of an organized criminal group, the punishment to be imposed is increased by one fold. (4) Legal entities involving in commission of this offense are subject to special security precautions. (5) No punishment is imposed for the offense defined in this section on a person who renders assistance or facilitates finding of assets acquired illegally as a result of offense by notifying the authorized bodies. (Article 281 of the Criminal Code of Turkey)
A prior or simultaneous conviction for the criminal activity from which the property was derived is not a prerequisite for a conviction for money laundering offences	Yes. ARTICLE 281-(1) Any person who takes away the assets acquired as a result of an offense which requires minimum one year or more punishment of imprisonment, or carries the same to a foreign country to be subject to various transactions in order to hide illegal source of these assets and to give the impression that they are acquired in the lawful manner, is punished with imprisonment from two years to five years, and also imposed punitive fine up to twenty thousand days. (2) In case of commission of this offense by a public officer while performing his duty or a person with profession, the punishment to be imposed is increased by one half. (3) In case of commission of this offense within the frame of activities of an organized criminal group, the punishment to be imposed is increased by one fold. (4) Legal entities involving in commission of this offense are subject to special security precautions. (5) No punishment is imposed for the offense defined in this section on a person who renders assistance or facilitates finding of assets acquired illegally as a result of offense by notifying the authorized bodies. (Article 281 of the Criminal Code of Turkey)
A conviction for money laundering offences is possible where it is established that the property was derived from a criminal activity, without it being necessary to establish all the factual elements or all circumstances relating to that criminal activity, including the identity of the perpetrator;	Yes. ARTICLE 281-(1) Any person who takes away the assets acquired as a result of an offense which requires minimum one year or more punishment of imprisonment, or carries the same to a foreign country to be subject to various transactions in order to hide illegal source of these assets and to give the impression that they are acquired in the lawful manner, is punished with imprisonment from two years to five years, and also imposed punitive fine up to twenty thousand days. (2) In case of commission of this offense by a public officer while performing his duty or a person with profession, the punishment to be imposed is increased by one half. (3) In case of commission of this offense within the frame of activities of an organized criminal group, the punishment to be imposed is increased by one fold. (4) Legal entities involving in commission of this offense are subject to special security precautions. (5) No punishment is imposed for the offense defined in this section on a person who renders assistance or facilitates finding of assets acquired illegally as a result of offense by notifying the authorized bodies. (Article 281 of the Criminal Code of Turkey)
Sanctions for legal persons
Legal persons can be held liable for the breaches of Regulation (EU) 2024/1624 or Regulation (EU) 2023/1113 committed on their behalf or for their benefit by any person, acting individually or as part of a body of that legal person and having a leading position within that legal person, based on any of the following: a power to represent the legal person; an authority to take decisions on behalf of the legal person; an authority to exercise control within the legal person.	No. (2) No punitive sanctions may be imposed for the legal entities. However, the sanctions in the form of security precautions stipulated in the law for the offenses are reserved. (Article 20 (2) of the Criminal Code of Turkey)
Legal persons can be held liable where the lack of supervision or control has made possible the commission of any money laundering offences for the benefit of that legal person by a person under its authority.	No. (2) No punitive sanctions may be imposed for the legal entities. However, the sanctions in the form of security precautions stipulated in the law for the offenses are reserved. (Article 20 (2) of the Criminal Code of Turkey)
Legal persons held liable are punishable by criminal or non-criminal fines.	No. (2) No punitive sanctions may be imposed for the legal entities. However, the sanctions in the form of security precautions stipulated in the law for the offenses are reserved. (Article 20 (2) of the Criminal Code of Turkey)
Legal persons held liable are punishable by other sanctions, such as: exclusion from entitlement to public benefits or aid; temporary or permanent exclusion from access to public funding, including tender procedures, grants and concessions; temporary or permanent disqualification from the practice of commercial activities; placing under judicial supervision; a judicial winding-up order; temporary or permanent closure of establishments which have been used for committing the offence.	Yes. ARTICLE 60-(1) In case of conviction of a crime through participation of the organs or representatives of a legal entity subject to special law and operating under the license granted by a public institution or misuse of authorization conferred upon by this license, the court may decide cancellation of this license. (2) The provisions relating to confiscation are applied also for the legal entities involved in commission of offense. (3) In cases where application of the provisions of the afore subsections is likely to create heavier consequences, the judge may refrain from imposition of such precautions. (4) The provisions of this article are applicable for the cases specifically defined by the law. (Article 60 of the Criminal Code of Turkey)
Pecuniary sanctions for obliged entities
In the event of a breach of Regulations (EU) 2024/1624 and (EU) 2023/1113, where obligations apply to legal persons, pecuniary sanctions can be imposed and administrative measures can be applied not only to the legal person, but also to the senior management and to other natural persons who under national law are responsible for the breach.	Yes. Article 13 - (1) The obliged parties failing to comply with any obligation stated in Articles 3 and 6 and Paragraph (1) of Article 4 of this Law shall be punished with an administrative fine of five thousand New Turkish Liras by MASAK. If the obliged party is a bank, finance company, factoring company, money lender, financial leasing company, insurance and reinsurance company, pension company, capital market institution or exchange office, administrative fine shall be applied twofold. (2) (Abolished: 18/6/2014-6545/Art. 88 (3) The obliged parties who fail to comply with the obligations stated in Article 5 of this Law shall be given at least 30 days in order to remove deficiencies and to take necessary measures. If the obliged parties don’t remove deficiencies and take necessary measures then the provisions of Paragraph (1) shall apply to them. (4) (Amended: 18/6/2014-6545/Art. 88) Persons, institutions and organizations who fail to comply with the obligations of electronic notification specified in Article 9/A of this Law shall be punished with an administrative fine of ten thousand Turkish Liras by MASAK for each failure to comply. The total amount of administrative fine applied in this regard in one year cannot exceed two hundred and fifty thousand Turkish Liras. (5) (Added: 18/6/2014-6545/Art.88) For each failure, the total amount of administrative fines applied within the year of the violation pursuant to first three paragraphs of the Article cannot exceed ten million Turkish Liras for obliged parties that will be punished with a twofold fine pursuant to Paragraph 1, and one million Turkish Liras for other obliged parties. If the obliged parties subject to upper limit on fines make same kind of failure to comply with obligation in the following year, the limit shall be applied twofold. (6) (Added: 18/6/2014-6545/Art. 88) Administrative fine cannot be imposed after five years from the date of violation of obligation. (7) Other principles and procedures regarding this article shall be determined by the regulation to be issued by the Ministry. (Article 13, Law no. 5549/2006, amended 2014 on prevention of laundering proceeds of crime)
Pecuniary sanctions shall be imposed on obliged entities for serious, repeated or systematic breaches, whether committed intentionally or negligently, of the requirements laid down in the following provisions of Regulation (EU) 2024/1624: Chapter II (Internal policies, procedures and controls of obliged entities); Chapter III (Customer due diligence); Chapter V (Reporting obligations); Article 77 (Record retention).	Yes. Article 13 - (1) The obliged parties failing to comply with any obligation stated in Articles 3 and 6 and Paragraph (1) of Article 4 of this Law shall be punished with an administrative fine of five thousand New Turkish Liras by MASAK. If the obliged party is a bank, finance company, factoring company, money lender, financial leasing company, insurance and reinsurance company, pension company, capital market institution or exchange office, administrative fine shall be applied twofold. (2) (Abolished: 18/6/2014-6545/Art. 88 (3) The obliged parties who fail to comply with the obligations stated in Article 5 of this Law shall be given at least 30 days in order to remove deficiencies and to take necessary measures. If the obliged parties don’t remove deficiencies and take necessary measures then the provisions of Paragraph (1) shall apply to them. (4) (Amended: 18/6/2014-6545/Art. 88) Persons, institutions and organizations who fail to comply with the obligations of electronic notification specified in Article 9/A of this Law shall be punished with an administrative fine of ten thousand Turkish Liras by MASAK for each failure to comply. The total amount of administrative fine applied in this regard in one year cannot exceed two hundred and fifty thousand Turkish Liras. (5) (Added: 18/6/2014-6545/Art.88) For each failure, the total amount of administrative fines applied within the year of the violation pursuant to first three paragraphs of the Article cannot exceed ten million Turkish Liras for obliged parties that will be punished with a twofold fine pursuant to Paragraph 1, and one million Turkish Liras for other obliged parties. If the obliged parties subject to upper limit on fines make same kind of failure to comply with obligation in the following year, the limit shall be applied twofold. (6) (Added: 18/6/2014-6545/Art. 88) Administrative fine cannot be imposed after five years from the date of violation of obligation. (7) Other principles and procedures regarding this article shall be determined by the regulation to be issued by the Ministry. (Article 13, Law no. 5549/2006, amended 2014 on prevention of laundering proceeds of crime)
Supervisors are able to apply administrative measures to an obliged entity, where they identify: breaches of Regulation (EU) 2024/1624 or Regulation (EU) 2023/1113, either in combination with pecuniary sanctions for serious, repeated and systematic breaches, or on their own; weaknesses in the internal policies, procedures and controls of the obliged entity that are likely to result in breaches of the requirements; that the obliged entity has internal policies, procedures and controls that are not commensurate with the risks of money laundering, its predicate offences or terrorist financing to which the entity is exposed.	Yes. Article 13 - (1) The obliged parties failing to comply with any obligation stated in Articles 3 and 6 and Paragraph (1) of Article 4 of this Law shall be punished with an administrative fine of five thousand New Turkish Liras by MASAK. If the obliged party is a bank, finance company, factoring company, money lender, financial leasing company, insurance and reinsurance company, pension company, capital market institution or exchange office, administrative fine shall be applied twofold. (2) (Abolished: 18/6/2014-6545/Art. 88 (3) The obliged parties who fail to comply with the obligations stated in Article 5 of this Law shall be given at least 30 days in order to remove deficiencies and to take necessary measures. If the obliged parties don’t remove deficiencies and take necessary measures then the provisions of Paragraph (1) shall apply to them. (4) (Amended: 18/6/2014-6545/Art. 88) Persons, institutions and organizations who fail to comply with the obligations of electronic notification specified in Article 9/A of this Law shall be punished with an administrative fine of ten thousand Turkish Liras by MASAK for each failure to comply. The total amount of administrative fine applied in this regard in one year cannot exceed two hundred and fifty thousand Turkish Liras. (5) (Added: 18/6/2014-6545/Art.88) For each failure, the total amount of administrative fines applied within the year of the violation pursuant to first three paragraphs of the Article cannot exceed ten million Turkish Liras for obliged parties that will be punished with a twofold fine pursuant to Paragraph 1, and one million Turkish Liras for other obliged parties. If the obliged parties subject to upper limit on fines make same kind of failure to comply with obligation in the following year, the limit shall be applied twofold. (6) (Added: 18/6/2014-6545/Art. 88) Administrative fine cannot be imposed after five years from the date of violation of obligation. (7) Other principles and procedures regarding this article shall be determined by the regulation to be issued by the Ministry. (Article 13, Law no. 5549/2006, amended 2014 on prevention of laundering proceeds of crime)
Where obliged entities fail to comply with administrative measures applied by the supervisor within the applicable deadlines, supervisors are able to impose periodic penalty payments in order to compel compliance with those administrative measures.	No. Absent from legal framework (Absent from legal framework)
Supervisors are required to publish on their website, in an accessible format, decisions imposing pecuniary sanctions, applying administrative measures or imposing periodic penalty payments.	No. Absent from legal framework (Absent from legal framework)
Beneficial ownership of legal persons and legal arrangements
Beneficial ownership information must be held in a central register in the Member State where the legal entity is created or where the trustee of an express trust or person holding an equivalent position in a similar legal arrangement is established or resides, or from where the legal arrangement is administered.	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
Member States shall ensure that the entities in charge of the central registers are empowered to request from legal entities, trustees of any express trust and persons holding an equivalent position in a similar legal arrangement, and their legal and beneficial owners, any information necessary to identify and verify their beneficial owners, including resolutions of the board of directors and minutes of their meetings, partnership agreements, trust deeds, power of attorney or other contractual agreements and documentation.	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
Where no person is identified as the beneficial owner, the central register shall include: (a) a statement that there is no beneficial owner or that the beneficial owners could not be determined, accompanied by a corresponding justification (b) the details of all natural persons who hold the position of senior managing officials in the legal entity equivalent to the following information: all names and surnames, place and full date of birth, residential address, country of residence and nationality or nationalities of the beneficial owner, number of identity document, such as passport or national identity document, and, where it exists, unique personal identification number assigned to the person by his or her country of usual residence, and general description of the source of such number	Yes. (4) In cases where the beneficial owner is not identified within the scope of paragraphs 2 and 3, the natural person(s) holding the position of senior managing official in the trade registry with the highest executive authority, shall be considered as beneficial owner. (Article 17A, Regulations on implementing Law no. 5549/2006, amended 2014)
Entities in charge of the central registers are required to verify, within a reasonable time upon submission of the beneficial ownership information, and on a regular basis thereafter, that such information is adequate, accurate and up to date.	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
Competent authorities, if appropriate and to the extent that such requirement does not interfere unnecessarily with their functions, are required to report to the entities in charge of the central registers any discrepancies they find between information available in the central registers and the information available to them.	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
The information contained in the central registers must include any change to the beneficial ownership of legal entities and legal arrangements and to nominee arrangements, following their first recording in the central register.	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
The entity in charge of the central register is empowered, whether directly or by application to another authority, including judicial authorities, to carry out checks, including on-site inspections at the business premises or registered office of legal entities, in order to establish the current beneficial ownership of the entity and to verify that the information submitted to the central register is accurate, adequate and up-to-date.	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
Where verification leads an entity in charge of a central register to conclude that there are inconsistencies or errors in the beneficial ownership information, the entity in charge of a central register is able to withhold or refuse to issue a valid certificate of proof of registration, or to suspend the validity of an existing certification of proof of registration.	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
The entity in charge of the central register is empowered to, whether directly or by application to another authority, including judicial authorities, apply effective, proportionate and dissuasive measures or impose such pecuniary sanctions for failures, including of a repeated nature, to provide the central register with accurate, adequate and up-to-date information about their beneficial ownership.	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
Competent authorities have immediate, unfiltered, direct and free access to the information held in the interconnected central registers without alerting the legal entity or legal arrangement concerned. These competent authorities include: self-regulatory bodies in the performance of supervisory functions of AML rules; tax authorities; national authorities with designated responsibilities for the implementation of Union restrictive measures; AMLA for the purposes of joint analyses; EPPO; OLAF; Europol and Eurojust when providing operational support to the competent authorities of Member States.	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
Beneficial ownership information held in central registers may be made available to obliged entities upon payment of a fee, which shall be limited to what is strictly necessary to cover the costs of ensuring the quality of the information held in the central registers and of making the information available. Those fees shall be established in such a way as not to undermine effective access to the information held in the central registers.	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
Any natural or legal person that can demonstrate a legitimate interest in the prevention and combating of money laundering, its predicate offences and terrorist financing has access to the following information on beneficial owners of legal entities and legal arrangements held in the interconnected central registers, without alerting the legal entity or legal arrangement concerned: the name of the beneficial owner; the month and year of birth of the beneficial owner; the country of residence and nationality or nationalities of the beneficial owner; for beneficial owners of legal entities, the nature and extent of the beneficial interest held; for beneficial owners of express trusts or similar legal arrangements, the nature of the beneficial interest.	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: persons acting for the purpose of journalism, reporting or any other form of expression in the media, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing;	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: civil society organisations, including non-governmental organisations and academia, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing;	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: natural or legal persons likely to enter into a transaction with a legal entity or legal arrangement and who wish to prevent any link between such a transaction and money laundering, its predicate offences or terrorist financing;	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: Member States’ public authorities in the context of public procurement procedures, in respect of the tenderers and operators being awarded the contract under the public procurement procedure;	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
Member States shall ensure that the information provided by central registers does not lead to the identification of any person consulting the register where such persons are: persons acting for the purpose of journalism, reporting or any other form of expression in the media, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing;	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
Member States shall ensure that the information provided by central registers does not lead to the identification of any person consulting the register where such persons are: civil society organisations that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing.	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
Where entities in charge of central registers decide to grant access to beneficial ownership information, they shall issue a certificate granting access for 3 years. Entities in charge of central registers shall respond to any subsequent request to access beneficial ownership information by the same person within 7 working days.	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
Member States shall ensure that entities in charge of central registers shall only refuse a request to access beneficial ownership information on one of the following grounds: the applicant has not provided the necessary information or documents pursuant to paragraph 1; a legitimate interest to access beneficial ownership information has not been demonstrated; where on the basis of information in its possession, the entity in charge of the central register has a reasonable concern that the information will not be used for the purposes for which it was requested or that the information will be used for purposes that are not connected to the prevention of money laundering, its predicate offences or terrorist financing; one or more of the situations referred to in Article 15 applies; the legitimate interest to access beneficial ownership information granted by the central register of another Member State does not extend to the purposes for which the information is sought; where the applicant is in a third country and responding to the request to access information would not comply with the provisions of Chapter V of Regulation (EU) 2016/679.	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
In exceptional circumstances to be laid down in national law, where the access to beneficial ownership information would expose the beneficial owner to disproportionate risk of fraud, kidnapping, blackmail, extortion, harassment, violence or intimidation, or where the beneficial owner is a minor or otherwise legally incapable, Member States shall provide for an exemption from such access to all or part of the personal information on the beneficial owner. Member States shall ensure that such exemptions are granted on a case-by-case basis upon a detailed evaluation of the exceptional nature of the circumstances and confirmation that those disproportionate risks exist. The right to an administrative review of the decision granting an exemption and the right to an effective judicial remedy shall be guaranteed.	No. Turkey does not have a central beneficial owner registry that is accessible by the public. The Communique 529/2021 enstates the obligation to notify the beneficial owners throught the tax declaration. (Absent from legal framework)
Supervision of obliged entities
Each Member State shall ensure that all obliged entities established in its territory are subject to adequate and effective supervision. To that end, each Member State shall appoint one or more supervisors to monitor effectively, and to take the measures necessary to ensure compliance by the obliged entities with Regulations (EU) 2024/1624 and (EU) 2023/1113.	Yes. Examiner means Tax Inspectors, Treasury and Finance Experts employed at MASAK, Customs and Trade Inspectors, Sworn-in Bank Auditors, Treasury Comptrollers, Insurance Supervisory Experts and Actuaries, Banking Regulation and Supervision Agency and Capital Markets Board Experts and Central Bank Auditors and Experts, //// ARTICLE 36- (1) Supervision of obligations shall be carried out by examiners. (2) The examiners assigned to conduct supervision shall be authorized to request all kinds of information, documents and legal books from natural and legal persons including the public institutions, and unincorporated organisations, to examine all kinds of documents and records within them and to receive information from the relevant authorities verbally or in writing. They shall also use the powers given to them by other laws. (3) Obliged parties shall provide all necessary facilities including to ensure proper working conditions for examiners during supervision process. (Article 2 (1) e), LAW NO: 5549/2006, amended 2014 on prevention of laundering proceeds of crime and Article 36 of the Regulations on implementing Law no. 5549/2006, amended 2014)
Financial Intelligence Units (FIUs)
Each Member State shall establish an FIU in order to prevent, detect and effectively combat money laundering and terrorist financing.	Yes. Article 4 – (1) In case that there is any information, suspicion or reasonable grounds to suspect that the asset, which is subject to the transactions carried out or attempted to be carried out within or through the obliged parties, is acquired through illegal ways or used for illegal purposes, these transactions shall be reported to MASAK by the obliged parties. (2) The obliged parties shall not give the information to anybody including the parties of the transaction that they report the suspicious transactions to MASAK, other than the examiners assigned to conduct supervision of obligations and the courts during legal proceedings. (3) Activities of obliged parties required reporting and principles and procedures of reporting shall be determined by regulation. ( Article 4, LAW NO: 5549/2006, amended 2014 on prevention of laundering proceeds of crime)
The FIU as the central national unit shall be responsible for receiving and analysing suspicious transaction reports and other information relevant to money laundering, associated predicate offences or terrorist financing.	Yes. Article 4 – (1) In case that there is any information, suspicion or reasonable grounds to suspect that the asset, which is subject to the transactions carried out or attempted to be carried out within or through the obliged parties, is acquired through illegal ways or used for illegal purposes, these transactions shall be reported to MASAK by the obliged parties. (2) The obliged parties shall not give the information to anybody including the parties of the transaction that they report the suspicious transactions to MASAK, other than the examiners assigned to conduct supervision of obligations and the courts during legal proceedings. (3) Activities of obliged parties required reporting and principles and procedures of reporting shall be determined by regulation. ( Article 4, LAW NO: 5549/2006, amended 2014 on prevention of laundering proceeds of crime)
The FIU shall be responsible for disseminating the results of its analyses and any additional relevant information to the competent authorities where there are grounds to suspect money laundering, associated predicate offences or terrorist financing.	Yes. (1) MASAK shall inform the obliged parties reporting suspicious transaction when the report is recorded. (2) MASAK shall periodically carry out general evaluation on effectiveness of suspicious transaction reports received. MASAK may also publish statistical data on suspicious transaction reports, methods used in money laundering and terrorist financing, rising trends, case studies prepared by benefiting from processes and findings following suspicious transaction reports, through annual activity reports, guidelines or periodicals and use them for the purpose of training. (Article 30, Regulations on implementing Law no. 5549/2006, amended 2014)
The FIU shall be operationally independent and autonomous, which means that the FIU shall have the authority and capacity to carry out its functions freely, including the ability to take autonomous decisions to analyse, request and disseminate specific information. It shall be free from any undue political, government or industry influence or interference.	No. MASAK operates under the Ministry of Finance, therefore not having independence and autonomy in its decisions
The FIU, regardless of their organisational status, is authorised to have access to the information that they require to fulfil their tasks, including financial, administrative and law enforcement information.	Yes. Article 7– (1) When requested by MASAK or examiners, public institutions and organizations, natural and legal persons, and unincorporated organizations shall fully and accurately provide all kinds of information, documents and related records in every type of environment, any kind of information and passwords necessary for accessing to or making these records decipherable, and render necessary convenience. (2) Those from whom information and documents are requested in accordance with the previous paragraph shall not avoid giving information and documents by alleging the provisions of special laws, provided that the defense right is reserved. ( Article 7, LAW NO: 5549/2006, amended 2014 on prevention of laundering proceeds of crime)
FIUs are empowered to take urgent action, directly or indirectly, where there is a suspicion that a transaction is related to money laundering or terrorist financing, to suspend or withhold consent to that transaction.	Yes. Article 19/A- (1) In cases where the assets which are the subject of a transaction are suspected to be linked to offence of laundering or financing of terrorism, the Minister shall be authorized to suspend the transactions that are attempted to be conducted or currently going on within or through obliged parties for seven work days or not to allow the performance of those transactions for the same period of time so that MASAK can verify the suspicion, analyse the transaction and convey the results of those analyses to competent authorities when necessary. (2) This power may also be used, based on reciprocity principle, for transactions which are the subject of the reasoned request made by foreign counterparts for suspending or not allowing the performance of the transaction provided that MASAK suspects that the transaction is linked to offence of laundering or financing of terrorism. (3) The other principles and procedures relating to implementation of this article shall be determined by a regulation issued by the Ministry. (Article 19A, Law no. 5549/2006, amended 2014 on prevention of laundering proceeds of crime)
Mutual legal assistance (MLA) and International Cooperation
Member States shall ensure that the FIU to whom the request is made is legally required to use the whole range of its available powers which it would normally use domestically for receiving and analysing information when it replies to a request for information from another FIU.	No. Absent from legal framework (Absent from legal framework)
Member States shall ensure that FIUs are legally required to exchange, spontaneously or upon request, any information that may be relevant for the processing or analysis of information by the FIU related to money laundering, its predicate offences, or terrorist financing, and the natural or legal person involved, regardless of the type of predicate offences that may be involved, and even if the type of predicate offences that may be involved is not identified at the time of the exchange.	Yes. International Information Exchange Article 12 -1) Head of MASAK shall be authorized to sign the memoranda of understanding, which are not in the nature of international agreement, with foreign counterparts and to amend the memoranda of understanding signed in order to ensure exchanging information within the scope of duties of MASAK. The signed memoranda of understanding and their amendments shall enter into force by the Decision of Council of Ministers. (Article 12, Law no. 5549/2006, amended 2014 on prevention of laundering proceeds of crime)

Legislation

*Last update: 2017

Asset Recovery

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Laws

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Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Asset Offices						0
Confiscation						44
International cooperation						50

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Country score
Asset Offices
Each Member State shall legally designate at least one asset recovery office to facilitate cross-border cooperation in relation to asset-tracing investigations and to conduct asset recovery functions in both criminal matters and civil or administrative matters.	No. Turkey has MASAK as the financial intelligence unit and central freezing authority, and prosecutors and courts handle seizure and confiscation, but there is no authority formally designated in law as an “asset recovery office” performing ARO‑type functions under EU (Law No. 5549 on Prevention of Laundering Proceeds of Crime (MASAK’s mandate); TCC and CMK provisions (no explicit ARO designation).)
Each Member State shall legally designate at least one competent authority to function as an asset management office for the purpose of the management of frozen and confiscated property until the disposal of that property further to a final confiscation order.	No. Management of seized and confiscated assets follows general enforcement, treasury and state‑property rules; there is no separate statutory asset management office comparable to the AMO concept in Directive (EU) 2024/1260. (Enforcement and treasury/state‑property legislation (no specialised AMO).)
Confiscation
Member States shall take the necessary measures to enable the freezing of property necessary to ensure a possible confiscation of that property. The freezing measures shall consist of freezing orders and immediate action. (Freezing measures)	Yes. The CMK allows seizure (criminal arrest) of assets when there is suspicion that a crime has been committed and that assets have been obtained from this crime; seizure may cover immovables, vehicles, bank accounts, rights, credits, shares, safe‑deposit contents and other assets, (Turkish Criminal Procedure Code, Articles 127 (power for seizure decision) and 128 (seizure of immovable goods, rights and credits).)
Member States shall take the necessary measures to enable the confiscation, either wholly or in part, of instrumentalities and proceeds stemming from a criminal offence subject to a final conviction, which may also result from proceedings in absentia. (Conviction based confiscation)	Yes. The TCC provides that the court may order confiscation of property/tools used in or reserved for the commission of an offence, as well as property/tools prepared for use in the commission of an offence if dangerous for public safety, (Turkish Criminal Code (Law No. 5237), Article 54 (Seizure/Confiscation of Property).)
Member States shall take the necessary measures to enable the confiscation of property the value of which corresponds to instrumentalities or proceeds stemming from a criminal offence subject to a final conviction, which may also result from proceedings in absentia. (Confiscation of equivalent value)	Yes. Where property/tools used in or reserved for commission of an offence are concealed, disposed of, consumed or otherwise made unavailable, (TCC, Article 54(2) (confiscation of a sum corresponding to the value of property that cannot be seized).)
Member States shall take the necessary measures to enable the confiscation of proceeds, or other property the value of which corresponds to proceeds, which, directly or indirectly, were transferred by a suspected or accused person to third parties, or which were acquired by third parties from a suspected or accused person. (Third-party confiscation)	Yes. The CMK allows seizure of assets belonging to individuals other than the suspect or accused where there is suspicion that they have been obtained from the crime; confiscation of pecuniary benefits may therefore reach property held by third parties, (CMK, Article 128(1)–(2) (seizure of immovable goods, bank accounts, rights and other assets, even when in possession of persons other than the suspect or accused); TCC, Article 55 (confiscation of pecuniary benefits).)
Member States shall take the necessary measures to enable the confiscation, either wholly or in part, of property belonging to a person convicted of a criminal offence where the offence committed is liable to give rise, directly or indirectly, to economic benefit, and where a national court is satisfied that the property is derived from criminal conduct. (Extended confiscation)	No. Confiscation focuses on property/tools used in or reserved for commission of an offence (Article 54) and directly derived pecuniary benefits (Article 55); Turkish law did not provide, by end‑2024, a general extended confiscation regime targeting broader property of convicted persons beyond direct proceeds and instrumentalities as described in Article 16 of Directive (EU) 2024/1260. (TCC, Articles 54–55; commentaries on security measures in the Turkish Penal Code.)
Member States shall take the necessary measures to enable the confiscation of instrumentalities, proceeds or property, or proceeds or property transferred to third parties, where criminal proceedings have been initiated but could not be continued because of illness, absconding, or death of the accused or the limitation period of the offence is below 15 years and has expired. (Non-conviction based confiscation)	No. Confiscation and seizure in Turkey are primarily linked to criminal proceedings and conviction, although asset freezing can be ordered early in investigations; Turkish law does not provide a general non‑conviction based confiscation regime covering all situations in Article 15 of Directive (EU) 2024/1260. (TCC, Articles 54–55; CMK, Articles 127–128 (no general NCBC regime independent of criminal proceedings).)
Confiscation without a prior conviction shall be limited to cases where, in the absence of the circumstances above, it would have been possible for the relevant criminal proceedings to lead to a criminal conviction for, at least, offences liable to give rise, directly or indirectly, to substantial economic benefit, and where the national court is satisfied that the instrumentalities, proceeds or property to be confiscated are derived from, or directly or indirectly linked to, the criminal offence in question. (Non-conviction based confiscation)	No. Seizure and freezing can occur prior to conviction, particularly in financial and organised crime cases, but confiscation is generally tied to conviction and there is no dedicated confiscation‑only procedure without conviction equivalent to that in Directive (EU) 2024/1260. (CMK, Articles 127–128; TCC, Articles 54–55 (confiscation as security measure in connection with offences).)
Member States shall take the necessary measures to enable the confiscation of property identified in the context of an investigation in relation to a criminal offence, provided that a national court is satisfied that the identified property is (i) derived from criminal conduct committed within the framework of a criminal organisation and (ii) that conduct is liable to give rise, directly or indirectly, to substantial economic benefit. A ‘criminal offence’ in this case is punishable by deprivation of liberty of a maximum of at least four years. (Confiscation of unexplained wealth)	No. Turkey uses seizure and confiscation tools, including MASAK‑driven freezing, against organised crime and mafia‑type structures, but there is no explicit unexplained‑wealth (TCC, Articles 54–55; Law No. 5549 on Prevention of Laundering Proceeds of Crime (freezing of assets) (no explicit unexplained‑wealth confiscation regime).)
Member States are legally required to adopt a national strategy on asset recovery and update it at regular intervals of no longer than five years. (Deadline of 24 May 2027)	No. Turkey has robust AML and confiscation tools and reports significant results (e.g. TL 92 billion seized in a 10‑month crackdown), but there is no statutory national asset recovery strategy with a five‑year (No explicit national asset recovery strategy provision in the TCC, CMK or AML)
International cooperation
To facilitate cross-border cooperation, Member States shall legally require measures to enable the swift tracing and identification of instrumentalities and proceeds, or of property which is, or might become, the object of a freezing or confiscation order in the course of proceedings in criminal matters.	Yes. The CMK and AML framework allow seizure and freezing of assets, and MASAK plays a central role in implementing freezing decisions and coordinating with relevant ministries and registries, thereby supporting tracing and identification of assets in both domestic and cross‑border (Law No. 5549 and implementing regulation on freezing assets of persons and entities; CMK, Articles 127–128.)
Member States shall legally require the necessary measures to ensure that their asset recovery offices provide, upon request from an asset recovery office in another Member State, any information that those asset recovery offices have access to, and that is necessary for the performance of the tasks of the asset recovery office requesting that information	No. MASAK and law‑enforcement and judicial authorities cooperate with foreign counterparts through AML and mutual legal assistance channels, but Turkey has not established a distinct ARO with explicit ARO‑to‑ARO information‑exchange duties as defined in EU (Law No. 5549 and mutual legal assistance provisions (no formal ARO designation).)
Member States may legally allow for cost-sharing agreements with other Member States on the execution of freezing and confiscation orders.	No. Turkish legislation on mutual legal assistance and confiscation does not include a specific statutory cost‑sharing (No explicit cost‑sharing clause in CMK)
Countries should be able to share confiscated property with other countries, in particular when confiscation is directly or indirectly a result of co-ordinated law enforcement actions	Yes. Turkey can share confiscated assets or return them to foreign states under international conventions on confiscation and its mutual legal assistance treaties, (International conventions on confiscation and Turkish MLA)

Legislation

*Last update: 2017

Turkey

Political Financing

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Financial Disclosure

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Legislation

Freedom of Information

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Is it specified that a particular institution(s) is responsible for examining financial reports and/or investigating violations?