Source Freshness Review — Restricted-Zone Status
Restricted-zone status is not a general description of a neighbourhood and cannot be established from a commercial property map. For a foreign acquisition, the conclusion must be connected to the exact parcel or independent unit used in the land-registry transaction and to the official source and enquiry process current at the decision date. Boundaries, legal classifications and enquiry procedures can change, and neighbouring properties can produce different results.
Use the competent official framework
TKGM Foreign Affairs publishes the Land Registry Law No. 2644, Law No. 2565 on Military Prohibited Zones and Security Zones, the related regulation, instructions and circulars. TKGM also maintains circulars concerning enquiries under Law No. 2565 and instructions for special security zones. These materials establish the legal framework. The status of a specific asset, however, should be evidenced through the official land-registry or authority enquiry applicable to that parcel, not inferred from a street address or sales brochure.
Do not collapse different zone categories
TKGM guidance explains that foreign acquisitions are subject to statutory restrictions that include military and security zones. The implementing regulation distinguishes categories with different consequences: some military areas prohibit foreign ownership, while particular special-security-zone situations can involve permission by the competent authority. Therefore a note saying restricted is not enough. The file should identify the category, legal basis, authority that decides the matter and the property-specific outcome.
Freshness test
Record the date of every enquiry and the official reference used. If the result was obtained long before the planned transfer, determine whether the current TKGM procedure permits continued reliance or whether a new enquiry is needed. A subdivision, merger, new parcel number, project-boundary change or replacement unit breaks the assumption that the previous result still covers the asset. A new circular, instruction or official change opening or closing an area to foreign acquisition also requires a renewed check.
Avoid non-authoritative substitutes
A municipal planning map, satellite map or brokers statement may help locate the property but does not establish the security-zone legal status. Likewise, the absence of a visible note on an old copy of title should not be treated as proof that every foreign-acquisition enquiry has been completed. The transaction file should preserve the actual enquiry or decision used by the competent process, the date, reference and parcel to which it applies.
Connect this result to the wider foreign-buyer file
Restricted-zone status is one component of asset eligibility, not the whole foreign-buyer review. Even after it is cleared, nationality, statutory area limits, identity, DAB, representation and current TKGM application documents remain separate controls. A citizenship transaction also has its own investment and TTB requirements. Passing the location control cannot be used as a shortcut to declare all other requirements satisfied.
Red flags
- The result identifies only a project name and no parcel.
- A broker gives a verbal assurance without an official reference.
- The enquiry concerns an old parcel after subdivision or consolidation.
- The contract address and land-registry data do not match.
- An old conclusion is used after TKGM publishes a later relevant instruction.
FAQ
Is a public map enough to prove that the property is outside a military zone?
No. The decision should be tied to the parcel and the official enquiry or record used by the competent authorities.
If another foreigner bought a neighbouring unit, does that clear this property?
No. Parcel, date, category and regulatory status can differ. The current asset needs its own evidence.
When should the check be repeated?
When the asset or parcel changes, project boundaries change, significant time passes, or a new official instruction or restriction appears.
Official sources
- TKGM — Foreign Affairs laws: https://www.tkgm.gov.tr/yabancii-db/kanun
- TKGM — Regulations: https://www.tkgm.gov.tr/yabancii-db/yonetmelik
- TKGM — Circulars: https://www.tkgm.gov.tr/yabancii-db/genelge
- TKGM — Military prohibited zones: https://www.tkgm.gov.tr/harita-db/askeri-yasak-bolgeler