Verifying a Turkish property valuation under the current rules
The first task in a valuation review is to make sure that an old rule is not being applied to a new transaction. The 2019 framework and later amendments once required valuation reports across a broad range of transactions involving foreigners. TKGM Circular 2024/4, published on 11 December 2024, changed the practical position. Transactions involving foreigners that do not include acquisition of Turkish citizenship no longer require the former property valuation report for that purpose. Transactions that do include citizenship use a Tutar Tespit Belgesi, or TTB, generated from a GEDAŞ valuation under the official system and transmitted through TADEBİS to TAKBİS or Web Tapu. The review must therefore start with the purpose and date of the transaction, not merely the fact that a party is foreign.
Separate a legal requirement from a voluntary market valuation
The removal of the former mandatory report for an ordinary foreign transaction does not prevent a buyer from commissioning an independent market valuation. A professional valuation can still be useful for negotiating price, understanding market evidence, lender requirements or internal investment analysis. The important distinction is that an optional commercial valuation is not the same thing as the TTB mechanism used in citizenship transactions and should not be described as a universal land-registry condition after the 2024 change. This distinction prevents both over-compliance and under-compliance: an ordinary buyer should not be charged for a procedure presented falsely as mandatory, while a citizenship buyer must not omit the specific official document that the current route requires.
What is the TTB in a citizenship transaction?
TKGM describes the TTB as the document that confirms the amount of real-estate investment acceptable for the citizenship route. It is derived from a valuation prepared by GEDAŞ under Circular 2024/2, created through TADEBİS and transmitted to TAKBİS or Web Tapu. Circular 2024/4 states that system transmission is the normal route and a physically presented TTB is not processed as a substitute. The valuation request underlying the TTB is made through the Web Tapu or TADEBİS citizenship-purpose valuation menu. A proper file should therefore preserve the system reference, file number and property linkage rather than rely only on a PDF forwarded by a seller.
Match the property identity before discussing value
A correctly issued report is still unusable if it relates to another unit. Match the province, district, neighbourhood, ada, parsel, independent-unit number, share and legal area with the transaction file. For a project under construction, the right or unit being valued must correspond to the right that will be sold or promised for sale. A difference in unit number, parcel, share or legal description should be resolved before accepting the value. Similar project names, approximate floor areas or a valuation for a comparable unit do not create identity. The valuation evidence must follow the actual asset.
Check date and validity under the correct regime
TKGM explains that valuation reports prepared before 9 December 2024 had a three-month validity period from the issue date and, when used in an application within that period, remained valid through completion under the stated rule. TTB documents prepared after 9 December 2024 have a six-month validity period. Circular 2024/4 also states that the interval between the TTB and the citizenship transaction application must not exceed six months; once that period is exceeded, the underlying valuation must be renewed. A file should therefore record the TTB date, application date and any replacement rather than carrying a simple valid label with no time basis.
Citizenship value is not proved by one number
For a citizenship transaction, a high valuation figure alone is insufficient. TKGM guidance explains that the relevant value tests operate across the declared sale price in the official deed or the price in the preliminary sale agreement, the total transfers or payments, and the investment amount confirmed by the TTB. For acquisitions after 19 September 2018, the guidance addresses the USD 400,000 threshold for the real-estate citizenship route. Acceptance of a TTB therefore does not replace review of the DAB, payment evidence and contract, and strong payment evidence does not replace the TTB where the citizenship process requires it.
Questions a buyer should ask
Start with: is this an ordinary purchase or a citizenship transaction? If it is for citizenship, was the valuation requested through the correct official route? What is the report or system file number? Is the TTB present in the system and tied to the exact property? What is its issue date and is it still within six months? Do the parcel and unit details match the deed or the preliminary sale agreement? Does the value confirmed through the TTB align with the declared and transferred amounts required by the citizenship rules? Was a correction or replacement issued later? If the transaction is not for citizenship, why is a valuation being presented as a mandatory registry requirement and what current rule supports that claim?
Closing-day review
For a citizenship case, recheck that the TTB used in the application is the same document tied to the final property set, remains within its validity period and has not been undermined by a change in unit, price or payment structure. If one property is added to or removed from a multi-property investment, do not assume the former valuation package still supports the new combination. In an ordinary non-citizenship sale, do not reintroduce the former general foreign-buyer valuation condition into the closing checklist merely because it was required under an older regime.
Recordkeeping
Keep the valuation request, system file number, GEDAŞ valuation reference, final TTB, issue date, property identifiers and every correction or replacement. In a citizenship transaction, connect that evidence to the contract, DAB and bank-payment records so the amount test can be reconstructed. If a document is superseded, preserve the earlier version in the audit file but mark it clearly as replaced and explain what changed. The goal is for a later reviewer to reproduce why the document was accepted on the decision date.
Red flags
- A claim that every foreign purchase in 2026 requires a valuation report based on an old circular.
- A seller-supplied PDF with no official system reference in a citizenship file.
- A mismatch in unit, ada or parsel between the valuation and transaction.
- A TTB older than six months when the citizenship application is made.
- Treating the valuation figure alone as sufficient while ignoring declared price and payments.
- A report for an entire project that cannot be tied to the actual right or unit.
- A correction exists but the file does not identify which version controls.
Frequently asked questions
Does every foreign buyer currently need a mandatory valuation report? Under TKGM Circular 2024/4, foreign transactions outside the citizenship route no longer require the former valuation report for that purpose; citizenship transactions use TTB.
What is the current validity period of a TTB? TKGM states six months for TTB documents prepared after 9 December 2024.
Can a paper TTB replace the system document? The circular provides for system transmission and states that a physically presented TTB is not processed as a substitute.