Turkish Citizenship: Does Your Child Lose Eligibility if They Turn 18 During the Process?

This article is an anonymized composite based on recurring legal inquiries and administrative scenarios encountered by foreign investors. It does not represent a specific individual or a guarantee of a particular legal outcome, as every file is subject to the discretion of the Turkish authorities.

The personal case

In this scenario, a foreign investor initiated the Turkish citizenship by investment process after purchasing real estate meeting the statutory threshold. At the time the investor received their Certificate of Eligibility (Uygunluk Belgesi) and subsequently submitted the formal citizenship application to the Provincial Directorate of Census and Citizenship (NVİ), their dependent child was 17 years and 10 months old.

The application was complete, including the necessary apostilled birth certificates and parental consent forms. However, the Turkish citizenship process involves multiple stages, including comprehensive security clearance and archival research conducted by the General Directorate of Security and the National Intelligence Organization. During this period, which can span several months, the child celebrated their 18th birthday. The parent is now concerned that because the child was no longer a minor at the moment the final decree was signed by the Presidency, the child’s file will be separated and rejected, forcing them to apply independently—a route that would require the child to make their own investment or meet standard naturalization criteria.

Short answer

Under Article 20 of Law No. 5901, a child must be under 18 when the parent acquires Turkish citizenship. Under Article 64(6) of the Citizenship Regulation, the child's age is legally determined as of the official application date. In practice, however, if a child turns 18 while the application is still pending, the administration separates their file and usually rejects it. This rejection is unlawful. Because the rejection decision is issued directly against the child after they reach adulthood, the child—now an adult in their own right—must file an annulment lawsuit against the administration. These lawsuits consistently conclude in favor of the applicant, resulting in the cancellation of the rejection and the granting of citizenship to the child.

Fact/Document Map

The following table outlines the critical documents and milestones relevant to a dependent child's application when they are nearing the age of majority.

Rule-by-rule analysis

The Statutory Rule: Article 20 of Law No. 5901

Under Article 20 of the Turkish Citizenship Law (Law No. 5901), children of foreign nationals who acquire Turkish citizenship are eligible to acquire citizenship alongside the parent if they are under the age of 18 at the time of the parent's acquisition (Source). The statute aims to safeguard family unity by extending naturalization to dependent minors.

The Administrative Dilemma: Separation of Files

A procedural barrier arises when the processing time—particularly the archival and security investigations—extends beyond the child's 18th birthday. Because Article 20 refers strictly to the date the parent acquires citizenship, the administration interprets this provision literally. When a child reaches adulthood while the file is pending, the NVİ removes the child from the parent's file, creates a separate case, and subsequently issues a formal rejection on the grounds that the applicant is no longer a minor.

The Legal Safeguard and Standing to Sue (Ehliyet)

Although the administration routinely issues rejections in these circumstances, the decision contradicts established administrative law principles and Article 64(6) of the Regulation on the Implementation of the Turkish Citizenship Law (Source). Article 64(6) dictates that the official application date is the date the formal petition is recorded by the competent authority. Under administrative case law, an applicant who met all eligibility conditions at the time of filing cannot be penalized for administrative processing delays.

Procedurally, because the rejection notice is finalized after the child turns 18, the child now possesses full legal capacity (fiil ehliyeti) under Turkish law. Consequently, the parents cannot file the lawsuit on their behalf as legal guardians. The lawsuit must be filed directly by the child as the sole plaintiff (or through a lawyer retained via the child's own Power of Attorney). Administrative courts consistently annul these rejections, ruling that citizenship must be granted based on the filing date eligibility.

Practical checklist

• Verify the Exact Filing Window: Prioritize filing the formal NVİ application immediately upon receiving the Certificate of Eligibility if a child is 17 years old.
• Obtain Proper Consents for Filing: Secure a notarized and apostilled parental consent (Muvafakatname) before initial submission; its legal validity is locked to the filing date.
• Track NVİ File Status: Monitor the security clearance phase closely. If the child turns 18 during this period, anticipate the administrative separation and subsequent rejection of their file.
• Prepare the Child's Own Power of Attorney: Because the child is now an adult and the formal rejection is issued in their name, the parents cannot litigate for them. The child must issue their own Power of Attorney to the attorney handling the case.
• Act Within the 60-Day Litigation Window: Ensure the annulment lawsuit is initiated in the competent administrative court within 60 days from the date the rejection notice is officially served to the child.
• Ensure MERNIS Registration Post-Verdict: Following the favorable court judgment, follow up with the NVİ to verify the child's final registration in the Central Civil Registration System (MERNIS).

Common mistakes

1. Parents Attempting to File the Lawsuit: A major procedural trap is parents attempting to sue on behalf of the child as guardians. Since the child was an adult at the time the rejection was served, the child must act as the plaintiff in their own name, or the court will dismiss the action for lack of legal capacity/standing.
2. Confusing the Eligibility Date with the Filing Date: Assuming the real estate purchase date or Certificate of Eligibility date locks the applicant's age. Only the official registration date at the NVİ establishes the legal benchmark.
3. Accepting the Administrative Rejection as Final: Assuming that once the NVİ issues a rejection letter due to the child reaching 18, all legal remedies are exhausted. In reality, judicial appeals against these rejections are routine and consistently successful.
4. Omitting Parental Consent for Near-Adults at Initial Filing: Omitting the non-applying parent's consent because the child is only weeks away from 18. If the applicant is even one day under 18 at filing, parental consent remains mandatory.
5. Missing the 60-Day Appeal Window: Failing to file the annulment lawsuit within 60 days of official notification of the rejection.

How SimplyTR would assess the file

When assessing a file where a dependent child is nearing 18, SimplyTR treats the Application Date (Article 64/6) as the primary legal safeguard. Our team expedites every phase—from title deed registration to the Certificate of Eligibility—to lodge the official NVİ petition while the child is still 17.

If the child turns 18 during the administrative security checks, we prepare clients for the standard administrative outcome: the NVİ will separate the file and issue a formal rejection. Because the child is an adult by that point, we immediately arrange for the child to execute an independent Power of Attorney, ensuring legal standing is flawless. We then coordinate the annulment action in the administrative courts. Relying on settled administrative case law regarding vested application rights, we secure the judicial cancellation of the rejection, ensuring the applicant successfully obtains Turkish citizenship.

Official references used for this case file

• Türk Vatandaşlığı Kanunu (Law No. 5901) - Article 20
• Türk Vatandaşlığı Kanununun Uygulanmasına İlişkin Yönetmelik - Article 64(6)
• İdari Yargılama Usulü Kanunu (Law No. 2577) - Article 7 (Filing Deadlines) & Article 31 (Capacity to Sue)

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