COMMISSION STAFF WORKING DOCUMENT Türkiye 2022 Report Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2022 Communication on EU Enlargement policy
Date: 2022-10-12
Institutions: Directorate-General for Neighbourhood and Enlargement Negotiations, European Commission
Subjects: Türkiye, accession criteria, accession negotiations, pre-accession strategy

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 12.10.2022  SWD(2022) 333 final  COMMISSION STAFF WORKING DOCUMENT Türkiye 2022 Report Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2022 Communication on EU Enlargement policy                   {COM(2022) 528 final} - {SWD(2022) 332 final} - {SWD(2022) 334 final} - {SWD(2022) 335 final} - {SWD(2022) 336 final} - {SWD(2022) 337 final} - {SWD(2022) 338 final}  
 
 
1. INTRODUCTION ................................................................................................................... 3 

1.1. 

CONTEXT ................................................................................................................. 3 

1.2. SUMMARY OF THE REPORT ............................................................................................. 4 

2. CLUSTER 1: THE FUNDAMENTALS OF THE ACCESSION PROCESS ............... 11 

2.1. FUNCTIONING OF DEMOCRATIC INSTITUTIONS AND PUBLIC ADMINISTRATION REFORM
 ................................................................................................................................ 11 

2.1.1. Democracy ...................................................................................................... 11 

2.1.2. Public Administration Reform ........................................................................ 20 

2.2.  

RULE OF LAW AND FUNDAMENTAL RIGHTS .......................................................... 23 

2.2.1.   Chapter 23: Judiciary and fundamental rights ............................................ 23 

2.2.2.  Chapter 24: Justice, freedom and security ............................................. 45 

2.3. ECONOMIC CRITERIA .................................................................................................... 59 

2.3.1. The existence of a functioning market economy ............................................ 60 

2.3.2. The capacity to cope with competitive pressure and market forces within the 

Union .......................................................................................................... 67 

2.4. PUBLIC PROCUREMENT, STATISTICS, FINANCIAL CONTROL ....................................... 70 

Chapter 5: Public procurement ................................................................................. 70 

Chapter 18: Statistics ................................................................................................ 72 

Chapter 32: Financial control ................................................................................... 74 

3. GOOD NEIGHBOURLY RELATIONS AND REGIONAL COOPERATION ........... 77 

4. 

ABILITY TO ASSUME THE OBLIGATIONS OF MEMBERSHIP ................. 81 

CLUSTER 2: INTERNAL MARKET ........................................................................................ 81 

Chapter 1: Free movement of goods ......................................................................... 81 

Chapter 2: Freedom of movement for workers ......................................................... 84 

Chapter 3: Right of establishment and freedom to provide services ........................ 84 

Chapter 4: Free movement of capital ........................................................................ 85 

Chapter 6: Company law .......................................................................................... 86 

Chapter 7: Intellectual property law ......................................................................... 87 

Chapter 8: Competition policy .................................................................................. 89 

Chapter 9: Financial services .................................................................................... 90 

Chapter 28: Consumer and health protection ........................................................... 92 

CLUSTER 3: COMPETITIVENESS AND INCLUSIVE GROWTH ................................................ 94 

 
 
 
Chapter 10: Digital transformation and media ......................................................... 94 

Chapter 16: Taxation ................................................................................................ 97 

Chapter 17: Economic and monetary policy ............................................................. 99 

Chapter 19: Social policy and employment ............................................................ 100 

Chapter 20: Enterprise and industrial policy .......................................................... 103 

Chapter 25: Science and research ........................................................................... 104 

Chapter 26: Education and culture .......................................................................... 105 

Chapter 29: Customs union ..................................................................................... 108 

CLUSTER 4: THE GREEN AGENDA AND SUSTAINABLE CONNECTIVITY ............................ 109 

Chapter 14: Transport Policy .................................................................................. 109 

Chapter 15: Energy ................................................................................................. 111 

Chapter 21: Trans-European networks ................................................................... 113 

Chapter 27: Environment and climate change ........................................................ 114 

CLUSTER 5: RESOURCES, AGRICULTURE AND COHESION ................................................ 117 

Chapter 11: Agriculture and rural development ..................................................... 117 

Chapter 12: Food safety, veterinary and phytosanitary policy ............................... 118 

Chapter 13: Fisheries .............................................................................................. 120 

Chapter 22: Regional policy and the coordination of structural instruments ......... 121 

Chapter 33: Financial and budgetary provisions .................................................... 122 

CLUSTER 6: EXTERNAL RELATIONS .................................................................................. 123 

Chapter 30: External relations ................................................................................ 123 

Chapter 31: Foreign, security and defence policy .................................................. 125 

ANNEX I – RELATIONS BETWEEN THE EU AND TÜRKIYE .................................. 130 

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1. INTRODUCTION 

1.1.  CONTEXT 
Türkiye1  remains  a  key  partner  for  the  European  Union  and  a  candidate  country.  Türkiye  has 
been  linked  to  the  EU  by  an  Association  Agreement  since  1964  and  a  Customs  Union  was 
established  in  1995.  The  European  Council  granted  Türkiye  the  status  of  candidate  country  in 
December 1999 and accession negotiations were opened in October 2005. Within the framework 
of  accession  negotiations,  16  chapters  have  been  opened  and  one  of  these  was  provisionally 
closed.  The  General  Affairs  Council  conclusions  of  December  2021  reiterated  the  Council’s 
position  of  June  2018  that  under  the  current  circumstances,  Türkiye’s  accession  negotiations 
have effectively come to a standstill, and no further chapters can be considered for opening or 
closing2. Over the reporting period, the Turkish government has not reversed the negative trend 
in  relation  to  reform,  despite  its  repeated  commitment  to  EU  accession.  The  EU’s  serious 
concerns  on  the  continued  deterioration  of  democracy,  the  rule  of  law,  fundamental  rights  and 
the  independence  of  the  judiciary  have  not  been  addressed.  There  was  further  backsliding  in 
many  areas.  Concerns  increased  over  economic  governance  and  the  good  functioning  of  the 
market economy. 

After some positive developments in 2021, relations with the EU deteriorated in the first half of 
2022,  due  to  repeated  violations  of  Greek  airspace  by  Turkish  fighter  jets  in  the  Aegean  and 
threatening Turkish statements regarding the sovereignty of Greek islands, and against Cyprus. 
In addition, Türkiye continued to carry out military exercises in the maritime zones of Cyprus, 
and  Turkish  warships  illegally  obstructed  survey  activities  in  the  Cypriot  Exclusive  Economic 
Zone  (EEZ).  Despite  international  condemnation,  Türkiye  continued  with  its  plan  to  open  the 
fenced-off  area  of  Varosha.  Tensions  in  the  Aegean  Sea  and  Eastern  Mediterranean  were  not 
conducive to good neighbourly relations and undermined regional stability and security. 

The EU, most recently at the European Council of June 2022, has repeatedly urged Türkiye to 
avoid making any kind of threat, creating any source of friction or carrying out any action that 
damages  good  neighbourly  relations  and  the  peaceful  settlement  of  disputes.  The  EU  has  re-
affirmed  that  it  has  a  strategic  interest  in  a  stable  and  secure  environment  in  the  Eastern 
Mediterranean  and  in  developing  a  cooperative  and  mutually  beneficial  relationship  with 
Türkiye. 

The  EU  and  Türkiye  continued  high-level  engagement  in  areas  of  common  interest  such  as 
climate, health or migration and security. This was in line with the EU’s offer to support a more 
positive  dynamic  in  EU-Türkiye  relations,  expressing  readiness  to  engage  with  Türkiye  in  a 
phased, proportionate and reversible manner in a number of areas of common interest, subject to 
the conditions set out by the European Council. On energy, Türkiye continues to be an important 
and reliable transit country for the EU. 

Türkiye continued its remarkable efforts to host one of the largest refugee populations worldwide 
with around 3.6 million Syrians under temporary protection and more than 330 000 non-Syrians, 
including those who hold or have applied for international protection status. The EU Facility for 

1 In line with the request of the Republic of Türkiye regarding the use of the country's new official name in English, 
this document uses the name “Türkiye” instead of “Turkey” in English. This administrative change is limited to the 
nomenclature  used  in  EU  documents,  does  not  have  a  retroactive  effect,  and  entails  no  legal  consequences.  This 
approach is without prejudice to the nomenclature used by Member States. 
2 The European Council conclusions of December 2006 remain in force. 

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Refugees  in  Turkey  supported  this  work,  with  over  EUR 4.7  billion  of  the  EUR 6  billion 
operational budget of the Facility already having been disbursed by June 2022. The Commission 
allocated an additional package of EUR 3.5 billion covering the 2020-2023 period to ensure the 
continuation  of  support  provided  to  date,  in  particular  in  key  areas  such  as  basic  needs, 
healthcare and education, and protection and socio-economic support. 

The  March  2016  EU-Turkey  Statement  continued  to  yield  results  and  remained  the  key 
framework governing cooperation on migration despite Türkiye’s calls to update the Statement. 
Although the resettlement of refugees in EU Member States resumed after a short break, due to 
the pandemic, Türkiye maintained the suspension of returns from the Greek islands that it put in 
place in March 2020. 

By June 2022, Türkiye had experienced over 15 million COVID-19 cases, with almost 100 000 
deaths.  The  country  saw  two  waves  of  the  pandemic  in  2021  and  a  sharp  increase  in  case 
numbers  was  observed  in  February  2022,  with  the  emergence  of  the  Omicron  variant.  The 
number of COVID-19 cases has been decreasing since then, but started to increase again towards 
the  end  of  the  reporting  period.  The  two-dose  vaccination  coverage  is  64%  of  the  total 
population.  In  August  2021,  the  Commission  adopted  an  equivalence  decision,  confirming 
Türkiye’s participation in the EU Digital Green Certificate scheme, which connects the country’s 
vaccination  certification  scheme to  the EU’s system. COVID-19 vaccination  certificates issued 
by  Türkiye  are  accepted  in  the  EU  under  the  same  conditions  as  the  EU  Digital  COVID 
Certificate.  At  the  same  time,  Türkiye  agreed  to  accept  the  EU  Digital  COVID  Certificate  for 
travel from the EU to Türkiye. 

1.2. SUMMARY OF THE REPORT3 

There  are serious deficiencies in  the functioning  of Türkiye’s  democratic institutions. During 
the reporting period, democratic backsliding continued. Structural deficiencies in the presidential 
system remained in place. Key recommendations from the Council of Europe and its bodies have 
yet  to  be addressed. Parliament  continued to  lack the necessary means to  hold  the government 
accountable.  The  constitutional  architecture  continued  to  centralise  powers  at  the  level  of  the 
Presidency without ensuring the sound and effective separation of powers between the executive, 
legislative and the judiciary. In the absence of an effective checks and balances mechanism, the 
democratic accountability of the executive branch continues to be limited to elections. 

Despite  the  lifting  of  the  state  of  emergency  in  July  2018,  some  legal  provisions  granting 
government officials extraordinary powers and retaining several of the restrictive elements of the 
state of emergency remained in place. The State of Emergency  Inquiry Commission has yet to 
complete the examination of its caseload in relation to the public employees who were dismissed 
by decree-laws during the period of emergency rule. In July 2021, Türkiye’s Parliament adopted 
a bill that extends the duration of some of the restrictive elements of the state of emergency for 
one more year. 

3 This report covers the period from June 2021 to June 2022. It is based on input from a variety of sources, including 
contributions from the government of Türkiye, the EU Member States, European Parliament reports and information 
from  various  international  and  non-governmental  organisations.  This  also  includes  the  results  of  comparative 
assessments and indices produced by other stakeholders, in particular in the area of rule of law. 
The report uses the following assessment scales to describe the state of play: early stage, some level of preparation, 
moderately prepared, good level of preparation and well advanced. To describe progress made during the reporting 
period, it uses the following scale: backsliding, no progress, limited progress, some progress, good progress and very 
good progress. Where appropriate, interim steps have also been used. 

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The judiciary continued to systematically target members of the opposition parties in Parliament, 
in relation to alleged terrorism-related offences. The legal framework for elections and political 
parties remains problematic. The electoral threshold was lowered from 10% to 7%. Türkiye has 
not  yet  addressed  the  remaining  recommendations  by  the  OSCE  Office  for  Democratic 
Institutions and Human Rights and the Venice Commission. 

Pressure on mayors from opposition parties by the ruling coalition government further weakened 
local  democracy.  Mayors  from  the  opposition  parties  faced  administrative  and  judicial 
investigations. Local democracy in the south-east remained severely hampered. In the south-east, 
the forcibly dismissed mayors continued to be replaced by government-appointed trustees. 

The situation in the south-east remained very worrying. In October 2021, Türkiye’s Parliament 
extended the military’s mandate to launch cross-border anti-terror operations in Syria and Iraq by 
two additional years. The Turkish government continued its domestic and cross-border security 
and military  operations in  Iraq and Syria. The security  situation remained precarious in  border 
areas  with  recurrent  terrorist  acts  committed  by  the  Kurdistan  Workers’  Party  (PKK),  which 
remains  on  the  EU  list  of  persons,  groups  and  entities  involved  in  acts  of  terrorism.  The  EU 
unambiguously condemned the PKK’s attacks and expressed solidarity with the families of the 
victims.  The  government  has  a  legitimate  right  and  a  responsibility  to  fight  terrorism,  but  it  is 
essential  that  it  does  so  in  accordance  with  the  rule  of  law,  human  rights  and  fundamental 
freedoms.  Anti-terror  measures  need  to  be  proportionate.  There  were  no  developments  on  the 
resumption of a credible political peace process to achieve a sustainable solution. 

Serious  backsliding  regarding  civil  society  issues  continued.  Civil  society  organisations  faced 
increased pressure and their space to operate freely continued to reduce, limiting their freedoms 
of expression, association and assembly. The implementation of the law on preventing financing 
of  proliferation  of  weapons  of  mass  destruction  added  further  restrictions  on  civil  society 
organisations. 

Civilian  oversight  of  the  security  forces  has  not  been  consolidated.  Military,  police  and 
intelligence  services’  accountability  remained  very  limited.  Parliamentary  oversight  of  the 
security institutions needs to be strengthened. In July, the Parliament extended the retirement age 
of  the  Chief  of  General  Staff  from  67  to  72  allowing  the  incumbent  Chief  of  General  Staff  to 
serve an additional year while the air and navy commanders have retired. 

Türkiye  has  some  level  of  preparation/is  moderately  prepared  in  the  field  of  public 
administration  reform.  No  progress  was  made  during  the  reporting  period.  The  country 
continues to lack a comprehensive reform agenda for public administration and public financial 
management  and  the  government  has  not  started  any  comprehensive  reform  of  public 
administration.  The  administration's  accountability  is  insufficient,  and  its  human  resources 
management  needs  to  be  improved.  Policy-making  lacks  evidence-based  methods  and 
participatory  mechanisms.  The  politicisation  of  the  administration  continued.  Women’s 
representation in civil service managerial posts remained low. 

Türkiye’s judicial system is at an early stage of preparation. The serious backsliding observed 
since  2016  continued  during  the  reporting  period.  Concerns  remained,  in  particular  over  the 
systemic  lack  of  independence  of  the  judiciary  and  undue  pressure  on  judges  and  prosecutors. 
Particular concerns relating to the judiciary’s adherence to international and European standards 
increased, in particular in relation to the refusal to implement rulings by the European Court of 
Human  Rights.  Implementation  of  the  2021  human  rights  action  plan  and  the  2019  judicial 

5 

 
 
reform strategy continued. However, both documents failed to address major shortcomings in the 
Turkish judiciary, lacking a plan for significant improvements to the overall functioning of the 
country’s judicial system. Only 515 judges or prosecutors dismissed following the coup attempt 
were reinstated, despite several being acquitted. The lack of objective, merit-based, standardised 
and pre-established criteria for recruiting and promoting judges and prosecutors remains a source 
of concern. 

Regarding the fight against corruption, Türkiye remained at an early stage of preparations and 
made no progress  in  the reporting period. The country has not  set  up anti-corruption bodies in 
line with its international obligations. The legal framework and institutional architecture need to 
be  improved  to  limit  political  and  undue  influence  in  the  prosecution  and  adjudication  of 
corruption cases. The accountability and transparency of public institutions need to be improved. 
The absence of an anti-corruption strategy and action plan indicated a lack of will to decisively 
fight corruption. Most of the Council of Europe’s Group of States against Corruption (GRECO) 
recommendations have not been implemented. Overall, corruption is widespread and remains an 
issue of concern. 

Türkiye has some level of preparation in the fight against organised crime, however there was 
limited  progress  overall.  The  completion  of  an  international  agreement  on  the  exchange  of 
personal data between Europol and the Turkish authorities responsible for fighting serious crime 
and terrorism is still pending, as Turkish data protection legislation is not yet in line with the EU 
acquis.  The  legal  framework  regulating  the  fight  against  money  laundering  and  terrorist 
financing  needs  to  be  improved  in  line  with  recommendations  by  the  Financial  Action  Task 
Force  (FATF)  and  those  by  the  Venice  Commission  on  the  law  on  preventing  financing  of 
proliferation of weapons of mass destruction. 

The  deterioration  of  human  and  fundamental  rights  continued.  Many  of  the  measures 
introduced during the state of emergency remain in force. The legal framework includes general 
guarantees  of  respect  for  human  and  fundamental  rights,  but  the  legislation  and  its 
implementation  need  to  be  brought  into  line  with  the  European  Convention  on  Human  Rights 
(ECHR) and the European Court of Human Rights (ECtHR) case-law. The Council of Europe’s 
Parliamentary  Assembly  continued  to  monitor  Türkiye’s  respect  for  human  rights,  democracy 
and the rule of law. Türkiye’s continued refusal to implement certain ECtHR rulings, notably in 
the cases of Selahattin Demirtaş and Osman Kavala, is a source of serious concern regarding the 
judiciary’s  adherence  to  international  and  European  standards  and  Türkiye’s  commitment  to 
promote the rule of law and respect for fundamental rights. The infringement procedure  started 
by  the  Council  of  Europe  against  Türkiye  in  February  2022,  for  non-implementation  of  the 
judgment in the Kavala case has marked yet another benchmark of Türkiye’s drifting away from 
the standards for human rights and fundamental freedoms that it has subscribed to as a member 
of the Council of Europe. In July, the Court ruled that Türkiye has failed to implement the 2019 
ECtHR judgment on the Kavala case.  

The  human  rights  action  plan  adopted  in  2021  continued  to  be  implemented,  but  this  does  not 
address critical issues and has not led to an improvement in the overall human rights situation. 

On  freedom  of  expression,  the  serious  backsliding  observed  in  recent  years  continued.  The 
implementation  of  criminal  laws  relating  to  national  security  and  anti-terrorism  continued  to 
contravene the ECHR and other international standards and to diverge from the case-law of the 
ECtHR.  Restrictive  measures  implemented  by  state  institutions  and  increasing  pressure  with 

6 

 
 
judicial and administrative means continued to undermine the exercise of freedom of expression. 
There continued to be criminal cases brought against and convictions of journalists, human rights 
defenders, lawyers, writers, opposition politicians, students, artists and social media users. 

There  was  further  backsliding  in  the  area  of  freedom  of  assembly  and  association.  There  were 
recurrent  bans,  disproportionate  use  of  force  and  interventions  in  peaceful  demonstrations; 
investigations,  court  cases  and  administrative  fines  against  demonstrators  on  charges  of 
terrorism-related activities or on violating the law on demonstrations and marches. 

The  rights  of  the  most  disadvantaged  groups  and  people  belonging  to  minorities  need  better 
protection. Roma people remained largely excluded from formal work and their living conditions 
deteriorated severely. Gender-based violence, discrimination, and hate speech against minorities 
(in particular against lesbian, gay, bisexual, transgender, intersex and queer (LGBTIQ) persons 
are still a matter of serious concern. 

On  migration  and  asylum  policy,  Türkiye  made  some  progress.  The  EU-Turkey  Statement 
remained  the  main  framework  for  cooperation  between  the  EU  and  Türkiye,  and  the  EU’s 
engagement  with  Türkiye  on  migration  intensified.  Some  progress  was  made  on  further 
strengthening capacity for surveillance and protection of the land border with Iran. The return of 
irregular  migrants  from  the  Greek  islands  under  the  EU-Turkey  Statement  continued  to  be 
suspended,  as  it  has  been  since  March  2020.  In  2021,  numbers  of  irregular  migrants  arriving 
increased on most routes in comparison to 2020. The increase could be partially due to the lifting 
of  measures  taken  by  countries  in  the  region  in  2020  to  contain  the  COVID-19  pandemic. 
Although  the  number  of  irregular  arrivals  in  Greece  has  decreased  compared  to  pre-COVID 
figures,  irregular  arrivals  to  Italy  and  to  the  government-controlled  areas  of  Cyprus  have 
increased substantially in the past year and new smuggling routes have been established. Türkiye 
has  still  not  implemented  the  provisions  relating  to  third-country  nationals  in  the  EU-Türkiye 
readmission agreement, which entered into force in October 2017. Overall, the number of illegal 
border crossings between Türkiye and Greece remained significantly lower than it was prior to 
the adoption of the EU-Turkey Statement.  

Türkiye  continued  to  make  significant  efforts  to  host  and  meet  the  needs  of  one  of  the  largest 
refugee communities in the world. Out of the full operational budget of EUR 6 billion under the 
Facility  for  Refugees,  over  EUR 4.7  billion  was  disbursed  by  June  2022.  Efficient  integration 
measures  are  needed  to  address  the  extended  presence  of  refugees  in  the  country.  Access  to 
public health for migrants  and refugees should be improved. No outstanding visa liberalisation 
benchmarks were fulfilled. Türkiye still needs to further align its legislation with the EU acquis 
on visa policy.   

Türkiye’s  unilateral  foreign  policy  continued  to  be  at  odds  with  the  EU  priorities  under  the 
common foreign and security policy (CFSP), notably due to its military action in Syria and Iraq 
and a lack of alignment with EU restrictive measures against Russia. Türkiye maintained a very 
low alignment rate with the EU stand on foreign and security policy of 7% (as of August 2022). 
Türkiye’s military support to Libya, including the deployment of foreign fighters on the ground, 
and its persistent criticism of and lack of cooperation with Operation IRINI are detrimental to the 
EU’s effective contribution to implementing the UN arms embargo, and have led to conflicting 
approaches on Libya. Türkiye remains a critically important actor in the Syrian crisis and shares 
with  the  EU  the  objective  of  a  stable  and  prosperous  Syria.  However,  its  troops  maintained  a 
significant  presence  in  the  region  and  in  other  parts  of  northern  Syria.  Türkiye’s  security 

7 

 
 
concerns  stemming  from  northern  Syria  should  be  addressed  through  political  and  diplomatic 
means, not by military action, and in full respect of international humanitarian law. 

The Russian war of aggression against Ukraine was recognised by Türkiye as a state of war and 
Türkiye  condemned  the  Russian  aggression.  Türkiye  enforced  the  Montreux  Convention, 
whereby  the  passage  of  warships  was  limited  to  those  returning  to  their  bases.  Turkish 
companies continued to  sell military ordnance to Ukraine. Türkiye has aimed to facilitate talks 
between  Ukraine  and  Russia  and  working  on  de-escalation  and  bringing  about  a  cease-fire.  It 
also undertook a diplomatic initiative to facilitate the export of Ukrainian grain; the deal agreed 
by Ukraine and Russia on 22 July in Istanbul, facilitated by the UN and Türkiye, would not have 
been possible without the constructive role of Türkiye, which is also involved in facilitating the 
implementation  of  the  deal.  Nevertheless,  Türkiye  refrained  from  aligning  with  EU  sanctions 
against Russia. Türkiye  has signed a Memorandum  of Understanding for developing economic 
and trade relations with Russia.  

The  improved  dynamic  in  EU-Türkiye  relations  observed  since  December  2020,  following  the 
de-escalation  in  the Eastern Mediterranean, prevailed for several  months before tensions  in  the 
Aegean  resumed  in  April  2022.  In  November  2021,  following  the  second  review  of  the 
framework  for  restrictive  measures,  the  Council  extended  the  regime  for  one  more  year  until 
12 November  2022.  Currently  two  individuals  are  subject  to  sanctions.  While  there  were  no 
unauthorised  drilling  activities  by  Türkiye  in  the  Eastern  Mediterranean  during  the  reporting 
period,  tensions  have  been  rising.  Turkish  warships  illegally  obstructed  survey  activity  in  the 
Cypriot Exclusive Economic Zone. Türkiye’s military exercises in the maritime zones of Cyprus 
continued. Despite the international community, and the EU in particular, condemning Türkiye’s 
unilateral  steps,  Türkiye  continued  with  its  actions  to  further  reopen  the  fenced-off  town  of 
Varosha in Cyprus. 

Türkiye  needs  to  commit  itself  unequivocally  to  good  neighbourly  relations,  international 
agreements  and  to  the  peaceful  settlement  of  disputes  in  accordance  with  the  United  Nations 
Charter, having recourse, if necessary, to the International Court of Justice. 

The  June  2022  European  Council  expressed  deep  concern  about  recent  repeated  actions  and 
statements by Türkiye. It recalled its previous conclusions and the statement of March 2021 and 
reiterated  that  Türkiye  must  respect  the  sovereignty  and  territorial  integrity  of  all  EU  Member 
States.  It  emphasised  that  the  European  Council  expects  Türkiye  to  fully  respect  international 
law,  de-escalate  tensions  in  the  interest  of  regional  stability  in  the  Eastern  Mediterranean, 
promote good neighbourly relations in a sustainable way and fully respect international law. The 
European  Council  has  repeatedly  recalled  the  EU’s  strategic  interest  in  a  stable  and  secure 
environment in the Eastern Mediterranean and in the development of a cooperative and mutually 
beneficial  relationship  with  Türkiye.  The  European  Council  also  reaffirmed  its  readiness  to 
engage with  Türkiye in  a phased, proportionate  and reversible manner in a number of areas of 
common interest, subject to Türkiye meeting the established conditionalities set out in previous 
European Council conclusions, and provided that the de-escalation in the Eastern Mediterranean 
is sustained. 

Regarding the economic criteria, the Turkish economy is well advanced, but made no progress 
over  the  reporting  period.  Serious  concerns  persist  over  the  continued  proper  functioning  of 
Türkiye’s  market  economy  as  there  has  been  backsliding  on  important  elements,  such  as  the 
conduct  of  monetary  policy  and  the  institutional  and  regulatory  environment.  The  economy 

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recovered strongly from the COVID-19-crisis, growing by 11.4 % in 2021, and more than 7 % in 
the  first  half  of  2022  despite  the  fallout  of  Russia’s  invasion  of  Ukraine.  The  country's  overly 
loose monetary policy and lack of policy credibility have weakened the lira and have driven the 
official  inflation  to  a  two-decade  high  of  more  than  80%.  Higher  prices  for  imported 
commodities widened external imbalances, which remain a major vulnerability in a situation of 
increased  uncertainty  and  low  level  of  international  reserves.  Budget  execution  outperformed 
plans  but  government  debt  increased,  and  fiscal  policy  has  come  increasingly  under  pressure, 
burdened by unsuccessful attempts to curb rising inflation and underpin the domestic currency. 

The  institutional  and  regulatory  environment  remains  fragile,  particularly  as  regards  the 
predictability, transparency, and implementation of regulations. Some important steps were taken 
to improve the resolution of commercial disputes. Despite a gradual decline, the informal sector 
still accounts for a significant share of economic activity. State intervention in the price-setting 
mechanisms persists. The provision of State aid lacks proper implementation rules, enforcement 
and  transparency.  The  banking  sector  remained  largely  stable  and  capital  adequacy  above  the 
regulatory  requirements.  Non-performing  loans  decreased,  and  profitability  improved,  but 
dollarisation  and  financial  stability  risks  increased.  The  labour  market  recovered  from  the 
pandemic but deep-seated structural challenges, such as a very significant gender gap, a high rate 
of youth unemployment, and wide regional disparities remain. 

Türkiye  has  a  good  level  of  preparation  and  has  made  limited  progress  during  the  reporting 
period in developing its capacity to cope with the competitive pressure and market forces in the 
EU. Despite some progress in improving vocational training, the mismatch persists between the 
education system and labour market needs. Expenditure on research and development continued 
to  increase  very  slowly  and  remained  well  below  the  government’s  target.  Investment  activity 
slowed  in  the  second  half  of  2021.  Progress  continued  with  regard  to  diversifying  energy 
supplies and increasing the share of energy generated from renewable sources. The extension of 
local  content  requirement  practices  raises  concerns.  Türkiye  removed  some  of  the  additional 
custom  duties  it  had  introduced  in  defiance  of  the  commitments  under  the  EU-Turkey  Custom 
Union; however, extensive deviations from its obligations under the EU-Turkey Customs Union 
hinder bilateral trade. 

Türkiye is  moderately prepared in  the area of  public procurement  but  made no progress over 
the  reporting  period  and  large  gaps  remained  in  its  alignment  with  the  EU  acquis.  Türkiye 
continued  its  discriminatory  domestic  price  advantage  and  offset  practices  favouring  local 
content.  Türkiye  is  moderately  prepared  in  the  area  of  statistics  and  made  limited  progress 
during the reporting period. Frequent managerial changes within the Turkish Statistical Institute 
over the last few years, including during the reporting period, have significantly undermined the 
institution’s  credibility.  The  reliability  of  key  economic  data  has  been  repeatedly  called  into 
question. Türkiye has a good level of preparation on financial control, though no progress was 
made during the reporting period. The Public Internal Financial Control policy paper has not yet 
been  updated  and  the  anti-fraud  coordination  service  (AFCOS)  network  has  not  yet  been  re-
established. 

Regarding its ability to assume the obligations of membership, Türkiye’s alignment with the 
EU acquis continued to be very limited and pursued on a rather ad hoc basis. 

The internal market cluster is key to the good functioning of the EU-Turkey Customs Union 
and to integrating Türkiye into the EU’s single market. Preparations in the areas of freedom of 

9 

 
 
movement for workers and right of establishment and freedom to provide services are at an early 
stage,  as  many  professions  are  closed  to  EU  nationals.  Türkiye  has  achieved  a  good  level  of 
preparation  for  the  free  movement  of  goods.  Technical  barriers  to  trade  remained  in  place. 
Türkiye is moderately prepared on free movement of capital, as limitations continue on foreign 
ownership and on capital movement. Türkiye needs to continue to address outstanding issues in 
its framework regulating the fight against money laundering and terrorist financing. 

Türkiye  is  well  advanced  in  the  area  of  company  law  and  needs  to  make  further  progress  in 
aligning with the EU acquis. Türkiye has a good level of preparation in the area of intellectual 
property  law  but  needs  to  improve  enforcement.  Türkiye  has  some  level  of  preparation  in  the 
area  of  competition  policy.  Serious  concerns  persist  in  relation  to  the  legislative  framework, 
enforcement  capacity  and  transparency  in  the  field  of  State  aid.  Türkiye  has  a  good  level  of 
preparation  in  the  area  of  financial  services  and  made  some  progress,  including  with  the 
development  of  new  alternative  financing  instruments.  There  is  a  good  level  of  preparation  in 
terms  of  legislative  alignment  of  consumer  and  health  protection,  with  some  progress  made, 
notably on aligning with the EU acquis and in strengthening inter-sectoral cooperation. 

Within  the  cluster  on  competitiveness  and  inclusive  growth,  Türkiye  has  some  level  of 
preparation in the area of digital transformation and media, though it has continued to backslide. 
Türkiye’s preparations in the area of science and research are well advanced and Türkiye made 
good  progress  during  the  reporting  period,  notably  with  the  conclusion  of  the  association 
agreement  for  Horizon  Europe  for  the  2021-2027  period.  Türkiye  is  moderately  prepared  on 
education and culture and made some progress,  in  particular on vocational  education, national 
qualifications systems and in terms of Türkiye’s participation in the EU programmes. 

On  the  economy-related  chapters,  backsliding  continued  on  economic  and  monetary  policy, 
reflecting inefficient policy on ensuring price stability and anchoring inflation expectations. The 
central bank remains under significant political pressure and its functional independence needs 
to  be  restored.  Türkiye  made  limited  progress  on  enterprise  and  industrial  policy,  and  major 
challenges  in  relation  to  measures  incompatible  with  EU  industrial  policy  principles  remain 
unaddressed. No progress was made during the reporting period in the area of social policy and 
employment,  with  concerns  remaining  over  trade  union  rights,  the  lack  of  genuine  social 
dialogue and persistent levels of informal economic activity. 

While  Türkiye  is  moderately  prepared  on  taxation,  it  made  no  progress  during  the  reporting 
period and there remains a need for a clear strategy, avoiding frequent changes in tax rates and 
enabling tax information exchange with all EU Member States. Türkiye maintains a good level 
of  preparation  for  the  customs  union  but  made  limited  progress,  notably  by  removing  some 
additional  duties  applied  on  imports  of  products  originating  in  third  countries.  However, 
Türkiye’s  deviations  from  its  obligations  under  the  EU-Turkey  Customs  Union  continue, 
contributing to a high number of trade irritants.  

Regarding  the  cluster  on  the  Green  Agenda  and  sustainable  connectivity,  Türkiye  is 
moderately  prepared  in  transport  policy.  It  made  limited  progress  during  the  reporting  period, 
mainly  linked  to  the  adoption  of  a  plan  to  significantly  increase  the  use  of  railway  transport. 
Türkiye is moderately prepared in the area of energy and made limited progress overall. Progress 
continued  on  renewable  energy  deployment,  on  reforms  in  the  natural  gas  sector  and  in 
legislative  alignment  on  nuclear  safety.  Türkiye  is  well  advanced  on  trans-European  networks 
and  made  some  progress,  mainly  on  energy  networks,  thanks  to  the  smooth  operation  of  the 

10 

 
 
trans-Anatolian  pipeline.  The  construction  of  the  Halkali-Kapikule  railway  line  connecting  the 
Bulgarian  border  to  Istanbul  continued.  Türkiye  has  some  level  of  preparation  in  the  area  of 
environment  and  climate  change,  but  made  no  progress  overall  during  the  reporting  period. 
Türkiye  faces  critical  environmental  and  climate  challenges,  both  in  relation  to  mitigation  and 
adaptation. More ambitious and better coordinated environment and climate policies need to be 
drawn up and implemented. Türkiye still needs to increase and implement its contribution to the 
Paris  Agreement  on  climate  change  and  complete  its  alignment  with  the  acquis  on  climate 
action. 

On the cluster covering resources, agriculture and  cohesion, Türkiye reached some level of 
preparation in the area of agriculture and rural development. Backsliding continued during the 
reporting period, as its agricultural policy keeps  moving away from the main principles of the 
EU  common  agricultural  policy  and  Türkiye  continued  to  restrict  imports  of  agricultural 
products from the EU. Türkiye is a major exporter of food products to the EU and made limited 
progress  during  the  reporting  period  in  the  area  of  food  safety,  veterinary  and  phytosanitary 
policy.  Full  implementation  of  the  EU  acquis  in  this  area  requires  significant  further  work.  
Türkiye  is  moderately  prepared  in  the  area  of  fisheries  and  continued  to  make  good  progress, 
notably as regards the implementation of the new fisheries law, resources and fleet management, 
and inspection and control. Türkiye is moderately prepared in the area of regional policy and the 
coordination of structural instruments and continued to make some progress on accelerating the 
absorption  of  IPA  II funds. Türkiye has some level  of preparation in  the area of financial  and 
budgetary provisions, but made no progress during the reporting period. 

In  the  external  relations  cluster,  Türkiye  is  moderately  prepared  in  the  area  of  external 
relations and made limited progress in the reporting period, notably due to continued deviation 
from the Common Customs Tariff. Divergence from the EU Generalised Scheme of Preferences 
persisted,  in  violation  of  the  EU-Turkey  Customs  Union.  Türkiye’s  official  development 
assistance was largely directed towards humanitarian support for the Syria-related activities on 
Türkiye’s own territory.  Türkiye has some level  of preparation in  the area of foreign, security 
and  defence  policy.  Overall,  Türkiye’s  foreign  policy  continued  to  be  at  odds  with  the  EU 
priorities under the common foreign and security policy (CFSP). Türkiye’s non-alignment with 
EU  restrictive  measures  against  Russia  is  of  particular  concern  due  to  the  free  circulation  of 
products, including dual use goods, within the EU-Turkey Customs Union. This creates a risk of 
undermining EU restrictive measures. For the Customs Union to continue functioning the parties 
must fully respect existing rules and avoid undermining mutual trust. 

Overall, in many areas, significant further work is needed on legislative alignment with the EU 
acquis. In all areas, implementation and enforcement needs substantial improvement. Ensuring 
the  independence  of  regulatory  authorities  and  developing  administrative  capacity  are  key  for 
Türkiye to achieve further progress. 

2. CLUSTER 1: THE FUNDAMENTALS OF THE ACCESSION PROCESS 

2.1. FUNCTIONING OF DEMOCRATIC INSTITUTIONS AND PUBLIC ADMINISTRATION REFORM 

2.1.1. Democracy 

The functioning of Türkiye’s democratic institutions continued to be severely hampered. During 
the  reporting  period,  democratic  backsliding  and  deep  political  polarisation  continued.  The 
presidential  system’s  structural  defects  remained  in  place.  Despite  the  lifting  of  the  state  of 

11 

 
 
emergency  in  July  2018,  several  legal  provisions  granting  government  officials  extraordinary 
powers  and  retaining  several  of  the  restrictive  elements  of  the  state  of  emergency  remained  in 
place. In addition, the emergency decree-laws were used to reform other legislations. The State 
of Emergency Inquiry Commission has yet to complete its investigation into the cases of public 
employees  who  were  dismissed  by  decree-laws  during  the  period  of  emergency  rule.  In  July 
2021, Türkiye's Parliament adopted a bill that extends the duration of some restrictive elements 
of the state of emergency for one more year.  

Elections 

During  the  reporting  period,  no  elections  took  place.  In  April  2022,  the  Turkish  Parliament 
adopted a joint AKP (Justice and Development  Party) and MHP (Nationalist Movement Party) 
proposal overhauling the rules for parliamentary elections. The law notably reduced the electoral 
threshold  from  10  %  to  7  %  and  changed  the  formula  to  calculate  the  distribution  of 
parliamentary seats. The law also changed the procedures for selecting the chair and members of 
the  provincial  election  boards,  who,  inter  alia,  oversee  the  vote  count  and  appeals  after  the 
elections. They will be elected on a random basis, which may endanger election security.  

Several  amendments  to  electoral  legislation  were  adopted  in  March  2022.  The  Venice 
Commission  of  the  Council  of  Europe  and  the  OSCE  Office  for  Democratic  Institutions  and 
Human Rights (ODIHR) issued a joint opinion in June. It criticised the hasty adoption of these 
amendments and the absence of an inclusive consultation process with the opposition parties and 
civil society. The joint opinion noted the reduction of the election threshold from 10 % to 7 % of 
the  valid  votes  cast  throughout  Türkiye  in  general  elections  as  a  positive  development,  but 
underlined  that  the  threshold,  which  still  remains  high,  impedes  political  representation.  The 
opinion also noted that some provisions of the new election law hinder smaller political parties’ 
political  representation  in  Parliament.  The  new  legislation  envisaged  selecting  the  chairs  and 
members of the provincial and district election boards through a lottery instead of based on their 
experience.  The  Venice  Commission  argued  that  this  random  selection  of  judges,  who  will 
preside the district and provincial electoral boards, endangers election security.  

Türkiye  needs  to  address  the  remaining  recommendations,  such  as  guaranteeing  democratic 
media  plurality,  and  ensuring  the  fair  treatment  of  all  political  parties  and  candidates.  The 
changes to the electoral law regarding the calculation for allocating parliamentary seats and the 
composition  of  the  provincial  and  district  election  boards  are  a  matter  of  concern.  Any  further 
amendments  Türkiye  makes  to  its  electoral  framework,  including  its  legislation  on  political 
parties, should be made after thorough consultation, in line with international standards.  

In  the  southeast,  the  48  mayors  who  were  forcibly  replaced  by  government-appointed  trustees 
after the local elections in 2019 have not been reinstated. This is a source of serious concern, as it 
undermines local democracy and denies voters their chosen representation. No action was taken 
to address the Venice Commission’s June 2020 opinion, which questioned the decisions to deny 
mayoral mandates to the Peoples' Democratic Party (HDP) candidates who received the highest 
number of votes in the March 2019 municipal elections in six municipalities, and to give these 
mandates to second-placed AKP candidates. As underlined by the Venice Commission, while the 
removal of elected officials may be exceptionally justified by the need to prevent officials from 
abusing  their  office  to  favour  terrorist  activities,  replacing  elected  officials  by  candidates  who 
lost the election, without holding new elections, cannot be justified.  

Parliament 

12 

 
 
The  presidential  system  has  largely  weakened  Parliament’s  legislative  and  oversight  functions. 
The  President  has  been  granted  extensive  legislative  powers  and  can  make  decisions  across  a 
wide range of policy areas, which limits the Parliament’s legislative role. Policy discussions that 
resulted in bipartisan agreement were uncommon during the reporting period. Parliament lacked 
the  tools  needed  to  hold  the  government  accountable.  Targeting  of  the  political  opposition 
continued. The closure case of Türkiye’s second largest opposition party (HDP) is ongoing and 
in the course of the last year, an increasing number of opposition parliamentary immunities were 
lifted.  

Parliament’s  legislative  role  has  been  hampered  by  the  presidential  system,  due  to  the 
widespread use of Presidential decrees and decisions. Between January and December 2021, out 
of the 732 proposed bills, Parliament adopted 87  pieces of legislation. As of April 2022, there 
have been 98 presidential  decrees issued on a  wide range of policy issues, including on socio-
economic issues, which traditionally are not covered by presidential decrees.  

Inter-party  electoral  alliances  remained  in  place  in  Parliament.  Parliament’s  legislative  and 
agenda-setting duties were largely influenced by the parliamentary majority of the ruling AKP-
led  alliance,  and  opposition  parties  were  de  facto  unable  to  influence  parliamentary  debates. 
Within Parliament, key public policy inter-party debates that resulted in cross-party compromises 
were rare. 

Parliamentary  oversight  of  the  executive  remained  very  weak.  Parliament  does  not  have  the 
means  needed  to  hold  the  government  accountable.  Members  of  Parliament  can  only  submit 
written  questions  to  the  Vice  President  and  ministers  and  are  not  allowed  by  law  to  formally 
question  the  President.  Presidential  decrees  were  not  subject  to  parliamentary  scrutiny. 
Parliamentary oversight of public spending needs to be significantly improved. 

The judiciary continued to systematically target members of the opposition parties in Parliament, 
particularly the People's Democratic Party (HDP), for alleged terrorism-related offenses, which 
undermined  political  pluralism.  The  parliamentary  immunity  system  did  not  provide  adequate 
legal  protection  to  allow  the  opposition  parliamentarians  to  express  their  opinions  within  the 
boundaries of freedom of speech. Currently, some 5 000 HDP members and officials remain in 
prison.  

The Justice Ministry’s request to remove the parliamentary immunity of 20 opposition Members 
of Parliament from six different parties is pending. An HDP politician regained his status as an 
MP in July 2021 after the Constitutional Court ruled that his rights had been violated. However, 
the immunity of another HDP parliamentarian was removed by Parliament in March 2022. Four 
additional  opposition  deputies  have  had  their  parliamentary  immunity  removed  and  have  been 
detained  on  terrorism-related  accusations  during  the  current  parliamentary  term.  Two  former 
HDP co-chairs, and several former HDP legislators are still in prison despite a European Court of 
Human Rights ruling in their favour. 

The  closure  case  against  the  HDP  on  terrorism  charges  is  pending  before  the  Constitutional 
Court. The prosecution has demanded that 451 HDP members be banned from politics and that 
the party’s bank account be frozen. In April, the HDP submitted its defence to the Constitutional 
Court in the ongoing closure case, arguing that the case was politically motivated, as it seeks to 
exclude the HDP from Türkiye’s political landscape. 

13 

 
 
The legal framework for elections and political parties remains problematic despite the recent 
lowering of the electoral threshold from 10 % to 7 %. Türkiye has yet to address the remaining 
recommendations  of  the  OSCE  Office  for  Democratic  Institutions  and  Human  Rights  and  the 
Venice Commission. In Parliament, women continued to be underrepresented (17.32 %).  

Governance 

The presidential system continues to be characterised by a lack of checks and balances, as well 
as  the  politicisation  of  the  public  administration.  Most  regulatory  authorities  remain  directly 
linked to the Presidency. The recommendations by the Council of Europe’s Venice Commission 
on the presidential regime still need to be addressed. The government’s pressure on mayors from 
opposition parties continued to weaken local democracy. 

The presidential system continues to lack the necessary checks and balances to prevent the undue 
concentration  of  power  in  one  office  and  to  protect  the  independence  of  the  judiciary,  as 
highlighted in the Venice Convention’s 2017 opinion and the European Commission’s previous 
country reports. The presidential system continues to have a harmful impact on the functioning 
of the executive and legislative arms of government, as well as on public administration. Due to 
a  lack  of  effective  checks  and  balances,  and  Parliament’s  inability  to  effectively  oversee  the 
office of the President, the latter’s political accountability is restricted to elections. 

The use of traditional instruments of oversight of the executive by Parliament, such as a vote 
of confidence and the ability to ask the executive oral questions, is still not possible and has not 
been since the entry into force of the presidential system in 2018;  only written questions to the 
Vice President and ministers are permitted. The administration, courts, and security sector are all 
heavily politicised. The Presidency has direct control over the vast majority of key institutions. 
The civil service has become politicised, particularly at the highest levels of management. 

The  legal  framework  has  enabled  undue  political  influence  over  regulatory  authorities.  The 
President  has  the  power  to  appoint  the  heads  of  the  vast  majority  of  the  regulatory  agencies, 
which  are  still  directly  linked  to  the  Presidency.  During  the  reporting  period,  two  deputy 
governors and one monetary policy board member of the central bank were dismissed.  

The  Ombudsman  remained  silent  on  politically  critical  issues  concerning  fundamental  rights. 
The Ombudsman still lacks ex officio powers to initiate investigations and to intervene in cases 
with legal remedies. 

Local government 

The  government’s  pressure  on  opposition  mayors  and  opposition  politicians  remained  strong. 
Administrative  and  judicial  probes  continued  against  mayors  from  the  opposition  parties.  The 
CHP  Istanbul  Chair,  whose  conviction  was  upheld  by  the  Court  of  Cassation,  was  given  a 
political  ban.  The  Court  of  Cassation’s  Public  Prosecutor  cancelled  her  political  party 
membership. The trial  continued against the  Istanbul  Metropolitan Mayor on the allegations of 
insulting the members of the Supreme Election Council in 2019. An administrative investigation 
was also launched against the mayor for allegedly hiring terrorists in his office. 

Local  democracy  in  the  south-east  remained  severely  hampered.  Since  the  local  elections  in 
2019,  48  HDP  mayors  have  been  dismissed  from  office  due  to  terrorism-related  charges. 
Furthermore,  due  to  alleged  ties  to  the  Gülen  movement,  one  CHP  mayor  was  replaced. 
Governors  remained  in  the  positions  of  the  deposed  mayors  as  trustees.  Municipal  assemblies 

14 

 
 
have been halted in the majority of cases by the new trustees. Hundreds of municipal lawmakers 
and elected officials have been detained on terrorism-related allegations. Such actions deny the 
public  their  right  to  be  ruled  by  their  chosen  representatives.  According  to  the  Venice 
Commission, the voters’ choice must be restored by either reinstating suspended mayors, elected 
municipal assemblies appointing acting mayors, or holding new elections. 

The  legal  framework  regulating  the  Ministry  of  Interior’s  tutelary  powers  over  elected  local 
office holders was not revised in line with Türkiye’s commitments under the European Charter 
of Local Self-Government. 

The municipal law envisages local administrations' engagement with the public and civil society. 
Citizens’  assemblies,  which  aim  to  bring  together  professional  and  civil  society  organisations 
and  other  local  stakeholders,  continued  to  be  inactive  in  most  provinces.  Some  municipalities 
increased their level of transparency and accountability through innovative solutions, such as the 
live broadcasting of municipal tenders.  

Women's  representation  at  the  local  level  remained  low.  Only  two  out  of  30  (6.6  %)  urban 
mayors and 42 out of 1 389 (3 %) mayors are women. 

Civil Society 

Serious  backsliding  regarding  the  civil  society  environment  continued.  Civil  society  faced 
continuous pressure and their space to operate freely continued to reduce, limiting their freedom 
of  expression,  association  and  assembly.  A  prominent  human  rights  defender,  Osman  Kavala, 
was  sentenced  to  life  imprisonment  without  parole  (‘aggravated  life  imprisonment’)  and  seven 
co-defendants  were  sentenced  to  18  years  of  imprisonment.  This  judgement  is  contrary  to  a 
ruling  by  the  ECtHR.  Human  rights  organisations,  which  were  closed  under  the  state  of 
emergency, were not offered any legal remedy in relation to confiscations.  

The  implementation  of  the  law  on  preventing  financing  of  proliferation  of  weapons  of  mass 
destruction added further restrictions and pressure on civil society organisations, including with 
regard to restrictions on the activities of human rights defenders and civil society. 

Despite all these negative developments, civil society continued to be vocal and involved in civic 
life,  and  reported  on  developments  as  much  as  possible.  Systematic  and  inclusive  mechanisms 
for  the  effective  consultation  of  independent  civil  society  organisations  on  new  legislation  and 
policies need to be put in place. 

A powerful and diverse civil society, which is a crucial part of a democratic system, should not 
be targeted and restricted in its functioning by the government and state institutions. Civil society 
organisations  in  Türkiye  continued  to  make  crucial  contributions  on  key  issues  of  the  country, 
notably in the areas of education, women’s rights, rights for LGBTIQ persons, rights of persons 
belonging  to  minorities,  freedom  of  religion  and  belief,  anti-discrimination,  and  awareness-
raising regarding ethnic and social tolerance, monitoring hate crimes and support for refugees.  

Human  rights  organisations  faced  increased  judicial  and  administrative  pressures,  including 
arrests  and  detention  of  activists  and  human  rights  defenders.  Frequent  judicial  investigations 
and court cases resulting in heavy sentences, led to an increasingly hostile environment for civil 
society.  The  overly  broad  definition  of  terrorism  and  its  interpretation  by  the  judiciary  has  a 
worrying deterrent effect on civil society.  

15 

 
 
In  April  2022,  Osman  Kavala,  a  prominent  human  rights  defender,  was  sentenced  to  life  in 
prison  without  parole,  under  charges  of  attempting  to  overthrow  the  government  (a  charge  of 
which  he  had  been  previously  acquitted).  Seven  other  co-defendants,  prominent  human  rights 
defenders,  were  sentenced  to  18  years  in  prison  under  the  same  charges.  The  judgement  has 
provoked  strong  reactions  by  the  international  community  and  many  EU  Member  States.  In 
February  2022,  the  Committee  of  Ministers  of  the  Council  of  Europe  decided  to  launch  an 
infringement procedure against Türkiye for its refusal to implement the ECtHR’s 2019 judgment 
and  to  immediately  release  Osman  Kavala.  The  launching  of  the  infringement  procedure. 
Türkiye’s  refusal  to  implement  the  Court’s  ruling  in  the  Kavala  case  has  raised  doubts  about 
Türkiye’s commitment to its obligations as member of the Council of Europe. In the context of 
the infringement procedure, the ECtHR ruled in July 2022 that Türkiye has indeed failed to fulfil 
its  obligations  under  Article  46  §  1  of  the  Convention  to  comply  with  the  Chamber  judgment 
delivered by the Court in the case of Kavala v. Türkiye on 10 December 2019. Another landmark 
case  against  human  rights  defenders,  the  Büyükada  case,  is  still  pending  before  the  Court  of 
Cassation. 

The  portrayal,  in  some  media  outlets  close  to  the  government,  of  human  rights  defenders  as 
criminals,  notably  for  accepting  funds  from  international  donors,  including  the  EU,  remains  a 
matter  of  serious  concern.  Defamatory  rhetoric  during  court  proceedings  by  high-level  public 
officials, including the President and ministers, casts serious doubt on the respect of the principle 
of the presumption of innocence and the right to a fair trial.  

The  pressure  faced  by  female  politicians  and  women’s  organisations  characterised  by  frequent 
detentions,  investigations,  and  arrests  created  a  serious  hurdle  for  the  exercise  of  freedom  of 
association, freedom of expression, assembly and for participation in political life. A closure case 
was  launched  against  the  ‘We  Will  Stop  Femicides  Platform’,  and  the  executives  of  the  Rosa 
Women’s Association based in Diyarbakır faced regular detentions, arrests, and were subjected 
to repetitive audits, including by the Financial Crimes Investigation Board (MASAK). A closure 
case  has  been  launched  against  the  Tarlabaşı  Community  Centre  in  Istanbul,  following 
administrative  audits  and  fines  and  an  intense  smear  campaign  against  the  centre,  for  alleging 
that they promote LGBTIQ and PKK propaganda to children. 

Stigmatisation,  hate  speech  and  discriminatory  discourse  targeting  LGBTIQ  civil  society 
organisations  and  persons  remained  very  strong.  International  non-governmental  organisations, 
including  those  providing  humanitarian  aid  to  refugees,  continued  to  face  difficulties  in  their 
work in Türkiye. No effective domestic remedy was provided for the confiscation of assets from 
civil society organisations closed by emergency decrees. 

The legal framework regulating the work of civil society organisations lacks clarity and carries 
the risk of arbitrariness during implementation. Despite a 2021 Council of State judgement, it is 
compulsory for all associations to register their members in the Ministry of Interior’s information 
system of the. This legal obligation is not in line with the OSCE/Council of Europe guidelines on 
freedom of association.  

The  2020  law  on  preventing  financing  of  proliferation  of  weapons  of  mass  destruction,  which 
requires  risk  analysis,  was  used  repeatedly  by  the  authorities  to  profile  and  target  independent 
human  rights  organisations.  This  created  a  climate  of  fear  and  intimidation  and  reinforced  a 
chilling effect on NGOs that inhibit them from carrying out their legitimate activities. The July 
2021  Venice  Commission  and  the  February  2021  UN  Special  Rapporteurs’  recommendations 

16 

 
 
concluded  that  the  government  should  reconsider  certain  aspects  of  the  legislation  to  ensure 
compliance with Türkiye’s human rights obligations. The law should not be used to hinder civil 
society’s  freedom  of  association  and  assembly,  including  their  fundraising  activities.  As  the 
Venice Commission underlined, while fully recognising Türkiye’s difficult security situation, the 
measures introduced should not go beyond what is necessary and should be proportional.  

The  law  on  collection  of  aid  continues  to  impose  burdensome  requirements  for  permits  that 
discourage fundraising activities by civil society  organisations. These include prior notification 
for each fundraising activity and lengthy authorisation processes. Public funds are not distributed 
in a transparent way and the distribution process does not allow for the full involvement of civil 
society organisations and other stakeholders at every stage. The existing tax system impedes the 
functioning and development of foundations and associations. The status of ‘public benefit’ for 
associations and ‘tax exemption’ for foundations is vaguely defined and granted by the President. 
The  space  for  foreign  donors,  who  provide  financial  support  to  civil  society  in  Türkiye  under 
current Turkish legislation is increasingly shrinking. Both donors and the civil society are often 
faced  with  slander  and  the  risk  of  having  their  activities  funded  by  international  donors  being 
criminalised.  

There  is  still  neither  a  comprehensive  government  strategy  nor  any  mechanisms  in  place  for 
cooperation with civil society or for improving the legal framework. There is no legal framework 
or transparent and consistent practice for public consultations with the independent civil society 
organisations  who  are  largely  excluded  from  the  consultations  that  are  part  of  policy-making 
processes  and  monitoring.  It  is  crucial  that  a  full  participatory  approach  is  ensured  as  it  is  a 
constitutive element of a functioning democracy. Overall, the legal, financial and administrative 
environment needs to be more conducive to developing civil society in Türkiye. 

Civilian oversight of the security forces 

The  presidential  system  grants  broad  powers  to  the  executive  branch  over  the  security  forces. 
However, civilian oversight of the security forces has not been consolidated. The accountability 
of  the  military,  the  police  and  the  intelligence  services  remained  very  limited.  Parliamentary 
oversight  of  the  security  institutions  needs  to  be  strengthened.  The  legal  framework  for 
overseeing military expenditure was not improved. 

The culture of impunity remained prevalent. Security personnel continued to enjoy overreaching 
judicial  and  administrative  protection  in  cases  of  alleged  human  right  violations  and 
disproportionate use of force. Legal privileges continued in relation to the prosecution of military 
personnel  and  top  echelons  of  command.  The  investigation  of  alleged  military  offences 
committed  by  military  personnel  requires  prior  authorisation  from  either  military  or  civilian 
superiors.  

Situation in the east and south-east 

The situation in the south-east remained very worrying. In October 2021, Türkiye’s Parliament 
extended the military’s mandate to launch cross-border anti-terror operations in Syria and Iraq by 
two additional years. The Turkish government continued its domestic and cross-border security 
and military  operations  in  Iraq and Syria. The security  situation remained precarious in  border 
areas with recurrent terrorist acts led by the Kurdistan Workers’ Party (PKK), which remains on 
the EU list of persons, groups and entities involved in acts of terrorism. The EU unambiguously 
condemned the PKK’s attacks and expressed solidarity with the families of the victims.  

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While  the  government  has  a  legitimate  right  to  fight  terrorism,  it  is  essential  that  it  does  so in 
accordance with the rule of law, human rights and fundamental freedoms. Anti-terror measures 
need to be proportionate. There were no developments on the resumption of a credible political 
peace process to achieve a sustainable solution. 

PKK  leader  Öcalan  was  not  allowed  to  receive  visits  from  his  family  nor  his  lawyers.  In 
December  2021,  the  Council  of  Europe  Committee  of  Ministers  issued  a  resolution  on  the 
‘Gurban’  group  of  cases,  including  PKK  leader  Öcalan,  in  which  it  noted  that  Türkiye  has  to 
adopt  general  measures,  and  invited  the  authorities  to  submit  information  on  the  progress 
achieved in adopting them by the end of September 2022. In February 2022, the Constitutional 
Court rejected the application by Öcalan’s lawyers who asked to meet their client, being held in 
İmralı Prison. This decision was appealed before the ECtHR.  

The  curfew  in  six  districts  of  Diyarbakir’s  Sur  municipality  was  lifted.  However,  provincial 
governorates declared recurrent military security zones in several rural settlements. Human rights 
organisations  and  opposition  parties  continued  to  report  serious  violations  of  human  rights  by 
security  forces,  including  alleged  instances  of  torture,  ill-treatment,  arbitrary  arrests  and 
procedural rights violations in prisons and in police and gendarmerie establishments.  

There  was  no  progress  in  investigations  into  the  deaths  of  civilians  during  security  operations 
under curfews in 2015-2016 in towns of the Southeast such as Cizre. According to independent 
sources,  67  children  in  Kurdish-majority  provinces  lost  their  lives  due  to  armoured  vehicle 
crashes and remnants of war in Türkiye in the last 10 years. There are concerns about impunity 
in these cases. 

Eastern and south-eastern provincial governors declared frequent  blanket  bans on all meetings, 
demonstrations and events in their provinces, The longest of these has been in force in Van since 
2016.  The  broad  interpretation  of  the  fight  against  terrorism,  judicial  and  administrative 
difficulties imposed on the rights of journalists, political opponents, bar associations and human 
rights defenders working on the Kurdish issue raised repeated concerns. Associations, Kurdish-
language media outlets, and cultural rights institutions mostly remained closed. Legal procedures 
were  launched  against  20  Kurdish  journalists,  whereas  16  were  arrested  in  Diyarbakir  in  June 
2022. The 2021 Constitutional Court judgement annulling a provision of the emergency decree 
regarding  the  closure  in  2016  of  media  outlets  on  the  grounds  of  ‘posing  a  threat  to  national 
security’  and  also  reverting  a  provision  that  paved  the  way  for  the  seizure  of  the  properties  of 
those that were shut down, was not implemented.  

There were a number of hate crimes committed against Kurdish students and other members of 
the  public.  The  court  case  in  relation  to  the  killing  of  HDP  staff  member  in  Izmir,  continued. 
There  were  also  several  hate  attacks  against  HDP  buildings.  Fifteen  bar  associations  in  south-
eastern and eastern provinces condemned the escalating violence against Kurds across Türkiye in 
July  2021  and  asked  for  an  end  to  the  language  of  violence  and  discrimination.  The  Kurdish 
Newroz  celebrations  took  place  despite  a  heavy  police  presence  and  numerous  detentions, 
including HDP executives and members.  

The  HDP  closure  case  continued  before  the  Constitutional  Court.  The  trial  known  as  ‘Kobane 
case’  against  108  members  and  executives  of  the  HDP  (of  whom  20  remain  in  prison)  also 
continued.  There  were  hundreds  of  new  detentions  and  arrests  of  elected  representatives  and 
mayors, municipal council members and municipal executives on terrorism-related charges in the 
east  and  south-east  of  Türkiye.  Requests  by  the  prosecution  to  Parliament  to  remove  the 

18 

 
 
immunity of almost all HDP lawmakers are pending. Former HDP co-chair Selahattin Demirtaş 
remained  in  prison  despite  two  final  ECtHR  judgements  ruling  for  his  immediate  release.  The 
Constitutional Court’s ruling of June 2020 on the violation of Mr. Demirtaş’ right to liberty and 
security  was  also  not  implemented.  In  April  2022,  a  new  indictment  against  Mr  Demirtaş  was 
launched  over  some  of  his  social  media  messages  posted  nine  years  ago.  Campaigns  for  the 
release of a former HDP MP and co-chair, who is reportedly unable to sustain herself in prison, 
yielded no results.  

As of April 2022, out of the 65 municipalities won by the HDP in the 2019 local elections, 48 
elected mayors have been replaced by state-appointed trustees and another six elected municipal 
mayors have been replaced by AK Party mayors, as these were dismissed from their roles by law 
decrees. Since the first trustee appointment in June 2019, 83 co-mayors have been detained, and 
39  mayors  have  been  arrested.  Currently  eight  HDP  co-mayors  remain  in  prison.  In  February 
2022,  the  ECtHR  issued  a  judgement  on  the  40  former  HDP  MPs  (including  former  co-Chair 
Demirtaş)  finding  that  removing  their  parliamentary  immunity  was  against  the  Turkish 
Constitution and that their freedom of expression had been violated. The March 2022 monitoring 
report  and  recommendations  on  Türkiye  of  the  Congress  of  Local  and  Regional  Authorities  of 
the Council of Europe need to be implemented.   

Court  cases  are  ongoing  regarding  government-funded  construction  projects  on  cultural, 
historical,  and  religious  heritage  sites  which  were  damaged  in  2015  and  2016.  Two  churches 
were restored using state funding. There were renewed tensions around several projects, which 
are  considered  to  have  a  negative  environmental  impact  and  to  disrupt  cultural  and  religious 
places, such as the mining project in Tunceli Mountains, which is part of a national park and a 
sacred site for Alevis.  The serious risk of such damages had been raised for  years by residents 
and activists. 

There  continued  to  be  no  comprehensive,  consistent  approach  in  place  in  relation  to  missing 
persons, to the exhumation of mass graves or to the independent investigation of all alleged cases 
of extrajudicial killing by security and law enforcement officers. Most of the investigations into 
cases of enforced disappearance from the 1990s have reached the 20-year statute of limitations. 
Out  of  more  than  1  400  cases  of  missing  persons  since  then,  only  16  court  cases  have  been 
launched.  14  of  these  ended  in  acquittals  of  the alleged  perpetrators,  two  are  ongoing  and  two 
other  cases  are  before  the  Court  of  Cassation.  Concerns  remained  about  the  continued 
justification  of  extraterritorial  abductions  and  forced  returns  under  the  pretext  of  combating 
terrorism and protecting national security.   

Refugees and internally displaced persons 

Türkiye  continues  to  host  one  of  the  largest  refugee  populations  in  the  world.  According  to 
official  data,  as  of  May  2022,  Türkiye  hosted  3  737  369  Syrian  refugees  with  temporary 
protection status, some 108 000 Syrians with legal residency and 193 000 Syrians with Turkish 
citizenship. The number of Syrian refugees who voluntarily returned to Syria from Türkiye stood 
at  470  000,  according  to  the  Turkish  government.  According  to  the  United  Nations  High 
Commissioner  for  Refugees,  besides  the  Syrian  refugees,  Türkiye  hosted  330  000  asylum-
seekers  and  refugees  from  other  countries  including  Iraq,  Afghanistan,  Iran  and  Somalia  in 
December 2021. 

In  2021,  Türkiye  granted  international  protection  (refugee  status,  conditional  refugee  status  or 
subsidiary  protection)  to  13  227  applicants,  an  increase  from  8  753  in  2021.  The  authorities 

19 

 
 
rejected 11 908 applications compared to 10 674 in 2020. The backlog of international protection 
applications  remains  high.  In  February  2022,  Türkiye  officially  closed  registration  of 
international  and  temporary  protection  applications  in  several  provinces,  based  on  a  newly 
introduced  ‘25  per  cent  rule’,  which  caps  the  proportion  of  foreigners  residing  in  a  given 
province.  Human  rights  organisations  and  lawyers  reported  challenges  in  their  access  to 
registration  in  many  other  provinces,  beyond  those  that  are  closed  to  registration.  Barriers  to 
registration hinder access to all essential services and compound the vulnerability of applicants 
as they increase the risk of detention and deportation. Unaccompanied children continue to face 
protection  risks  in  asylum  and  migration  procedures.  A  multi-disciplinary  age  determination 
procedure,  which  takes  psycho-social  aspects  into  consideration  is  necessary  to  improve 
compliance  with  European  standards.  In  December  2021,  1  314  181  foreign  nationals  holding 
residence permits were present in Türkiye, including humanitarian residence permit holders.  

The  return  of  irregular  migrants  from  the  Greek  islands,  unilaterally  suspended  by  Türkiye  on 
public health grounds in March 2020, has not resumed. The EU has repeatedly called on Türkiye 
to resume return operations in line with the commitments made under the EU-Turkey Statement. 
Resettlements of vulnerable Syrians refugees from Türkiye to EU Member States have continued 
in the reporting period. 

Recurrent  allegations  of  human  rights  violations  in  the  field  of  migration  and  asylum, 
particularly  in  removal  centres  remain  a  concern.  Over  the  last  year,  media  and  civil  society 
continued  to  report  on  policies  and  practices  in  breach  of  human  rights  standards  and  Turkish 
legislation. NGOs have noted reports of detainees being coerced to sign voluntary return forms 
in  removal  centres  and  an  increase  in  hate  crimes  and  incidents  motivated  by  anti-refugee 
sentiments,  and  are  a  cause  for  concern.  Türkiye  needs  to  further  align  its  practice  in  removal 
centres  with  European  standards,  in  particular  with  regard  to  protection  of  human  rights, 
including  access  to  legal  counselling  and  interpreters,  and  protection  of  vulnerable  groups,  in 
particular  children  staying  with  their  families  (see  Chapter  24).  Public  discontent  with  the 
presence of Syrian refugees has become an election issue and a matter of constant debate. The 
pandemic had a disproportionately negative effect on vulnerable groups including refugees and 
internally displaced persons, who were already living in dire economic conditions.  

Türkiye has made sustained significant efforts to provide support for refugees and ensure wider 
access  to  healthcare  and  schooling,  with  approximately  742  000  children  enrolled  in  formal 
education by December 2021, which is about 82 000 higher than for the previous academic year. 
However, more than 400 000 school-aged refugee children were still out of school and did not 
have  any  access  to  education  opportunities.  Syrian  refugees  continued  to  benefit  from  free-of-
charge healthcare provided in 181 migrant health centres funded by the EU through its Facility 
for Refugees in  Turkey  and in Turkish hospitals. The EU supported the employment of over 4 
000  healthcare  workers  to  ensure  access  of  refugees  and  people  under  subsidiary  protection  to 
healthcare  services.  22.8  million  primary  health  care  consultations  were  conducted  in  EU- 
supported  primary  level  healthcare  facilities.  Many  cities  continued  to  improve  municipal 
services and infrastructure to respond to the population increase due to the influx of refugees.  

There was no progress on the situation of internally displaced persons resulting from the violence 
in the south-east in the 1990s and in more recent years.  

2.1.2. Public Administration Reform 

Türkiye  has  some  level  of  preparation/is  moderately  prepared  in  the  field  of  public 

20 

 
 
administration  reform.  No  progress  was  made  during  the  reporting  period.  The  country  still 
lacks  a  comprehensive  reform  agenda  for  public  administration  and  public  financial 
management. The political will to reform is still lacking. The administration’s accountability is 
insufficient  and  human  resources  management  needs  to  be  improved.  Policy-making  lacks 
evidence-based methods and participatory mechanisms. The politicisation of the administration 
continued. Women’s representation  in  civil  service in  the managerial  posts remained low.  Last 
year’s recommendations were not implemented and remain valid. 

In the coming year, Türkiye should in particular: 

  prepare  and  adopt  an  interinstitutional  public  administration  reform  plan  in  line  with  EU 

principles and values, and with the necessary political ownership and support; 

  ensure  that  the  Inquiry  Commission  on  the  State  of  Emergency  Measures  provides  for  an 
effective  remedy,  which  safeguards  the  right  of  every  individual  to  a  fair  administrative 
process; 

  introduce  merit-based  appointments  and  promotions  for  the  senior  managerial  positions  of 

the civil service. 

Strategic framework for public administration reform 

Türkiye  still  lacks  an  overarching  strategy  for  public  administration  reform.  The  absence  of 
political  support  and  ownership  for  reforming  the  public  administration  continues.  Several 
planning  and  sectoral  policy  documents  on  various  aspects  of  public  administration  exist. 
However,  they  reflect  a  fragmented  policy  framework  in  the  absence  of  an  overall  strategy 
document. Most of these sectoral policy documents do not specify the expected costs of reform 
measures,  so  financial  sustainability  of  public  sector  reforms  is  not  granted.  They  also  lack  a 
structured  follow  up  mechanism  (see  Chapter  32  -  Financial  control).  An  administrative  unit 
legally entitled to coordinate, design, and monitor public administration reforms needs to be set 
up. Such a unit would need to coordinate with the Ministry of Treasury and Finance, to ensure 
coherence of fiscal planning and to efficiently address issues with managerial accountability. 

Policy development and coordination 

The  centralisation  of  policy-making  under  the  presidential  system  continued.  The  presidential 
administration continued to play a leading role in policy-making, and the role of ministries was 
further diminished.  Inter-agency  policy development and  coordination  were limited, due to the 
dominant  role  of  the  Presidency.  Most  regulatory  authorities  are  also  linked  by  law  to  the 
Presidency. 

The  link  between  policy-making  and  financial  planning  remains  weak.  There  is  no  legal 
requirement  to  conduct  public  consultations  for  policy-making.  Evidence-based  policy-making 
instruments, such as regulatory impact assessments, are not used by the executive and legislative 
branches. Therefore, the country lacks an inclusive and evidence-based policy-making process.  

Türkiye’s state institutions do not carry out systematic  ex post monitoring and public reporting 
on  the  implementation  of  key  government  programmes.  Therefore,  the  public  scrutiny  of  the 
government’s work has remained very limited.  

Public financial management 

21 

 
 
Türkiye continued to  lack an overarching  public financial management reform programme. 
The  annual  budget  is  prepared  as  part  of  the  medium-term  budgetary  framework.  Public 
procurement legislation is not in line with the EU acquis. The very large number of exemptions 
inserted  into  the  Law  on  public  procurement  disrupts  the  transparency  and  accountability  of 
public expenditures (See also Chapter 5). In the absence of adequate ex post monitoring, major 
public investment programmes lack transparency.  

As regards external audit, the Turkish Court of Accounts’ (TCA)  ex post controls continued to 
constitute  the  basis  for  parliamentary  oversight  of  the  budget.  The  TCA  reports  also  provided 
substantial  information  about  the  budgetary  expenditures  for  the  public.  The  TCA’s  audit 
findings of misuse of public resources were also reported in the media. However, there remained 
shortcomings in the coverage and in parliamentary and judicial follow up on the TCA’s audits. 
Some  institutions  are  exempt  from  the  Court’s  remit  and,  therefore  from  the  associated 
parliamentary  scrutiny.  Parliamentary  and  judicial  follow-up  on  audit  reports  need  to  be 
improved. 

The  limited  parliamentary  oversight  of  the  budget  resulted  in  reduced  budget  transparency. 
The  Turkish  State  Wealth  Fund  (TWF)  lacks  accountability  and  transparency.  The  TWF  audit 
report for 2021 has not  yet  been made public. The new law,  adopted in  May 2022, introduced 
significant  amendments  to  the  TWF’s  legislative  framework,  extending  the  already  numerous 
exemptions and exceptions to cover companies, funds and their subsidiaries of which the TWF 
has become the controlling shareholder. This is a source of concern. An overview of the TWF’s 
investments  and  borrowings  is  not  included  in  the  budget.  Annual  budgetary  figures  are 
aggregated,  making  budget  reports  difficult  to  analyse.  Public  engagement  with  the  budgetary 
process is virtually absent. 

Public service and human resources management  

The functions and the human resources management of the civil service remain substantially 
governed by the Civil Servants’ Act of 1965. The need for new legislation on the public service 
remain,  but  a  non-systematic  approach  continued  to  prevail.  Türkiye  is  still missing  an  overall 
civil service strategy and overall monitoring report on the implementation of civil service policy. 

The  civil  service  legal  framework  does  not  guarantee  neutrality,  continuity  or  merit-based 
recruitment and promotion procedures. Numerous incidents indicated a growing politicisation 
of the civil service. During the reporting period, two deputy governors and one monetary policy 
board  member  of  the  central  bank  were  dismissed.  The  first  phase  of  external  recruitment  for 
entry-level  positions  is  based  on  merit,  whereas  the  oral  interview  phase  remains  poorly 
regulated  and  thus  open  to  political  patronage.  The  recruitment  procedure  for  the  most  senior 
civil service posts lacks objective criteria, leaving appointments open to  nepotism and political 
interference. 

Accountability of the administration 

The  presidential  system  has  introduced  strictly  centralised  lines  of  accountability  to  the 
Presidency.  Given  that  internal  control  and  audit  systems  do  not  function  effectively,  the 
accountability  of  central  government  agencies  remains  weak  and  at  risk  of  political  patronage. 
The functional division of roles and responsibilities between different governmental institutions 
needs to be clarified to improve efficiency, transparency and accountability. 

22 

 
 
State  institutions  are  formally  required  to  submit  annual  accountability  reports  on  the  use  of 
resources to achieve their designated targets. However, a systematic mechanism for follow-up by 
the executive is not in place. (See Chapter 32 - Financial control). 

Citizens’  right  to  good  administration  is  formally  ensured,  through  internal  and  external 
oversight  arrangements.  However,  the  implementation  of  the  internal  and  external  control 
mechanisms is not effective. The role of oversight institutions such as the Ombudsman remained 
limited in the absence of ex officio powers (see Governance). Internal controls did not result in 
systematic prosecution of alleged wrongdoings within the civil service.  

The  right  to  access  public  information  is  regulated  by  the  Law  on  the  Right  to  Information. 
However, there is no effective follow up mechanism overseeing the implementation of the law. 
The law allows for broad exemptions on grounds of protecting state secrets, commercial secrets 
and personal data, thus limiting actual public accessibility to state information.  

Strong concerns remain on the quality of the work of the Inquiry Commission on the State of 
Emergency Measures. As of 31 December 2021, the commission closed 120 703 cases out of 
126 783 applications in four years. There are 6 080 applications pending. Strong concerns remain 
as to whether cases are examined individually, whether the rights of defence of those dismissed 
are respected and whether the assessment procedure is in line with international standards. Since 
there were no hearings, there was a general lack of procedural rights for applicants and decisions 
were taken on the basis of the written files relating to the original dismissal, all of which call into 
question the extent to which the Inquiry Commission is an effective judicial remedy. 

Service delivery to citizens and businesses 

There is still no specific law on general administrative procedures in Türkiye. The simplification 
of administrative procedures  needs  to  be developed, to  reduce the burden of bureaucracy.  In 
the absence of such law, citizens and businesses continue to be faced with legal uncertainty. 

There is no central policy or co-ordination mechanism for improving the overall quality of public 
services.  Most  of  the  institutions  have  developed  service  delivery  standards  within  their  own 
legal remit. However, no institution is responsible for overall promotion or measurement of the 
quality of public services.  

2.2.   RULE OF LAW AND FUNDAMENTAL RIGHTS 

2.2.1.   Chapter 23: Judiciary and fundamental rights 

The rule of law and respect for human rights are amongst the EU’s founding values. Respect for 
fundamental  rights  in  law  and  in  practice,  the  effectiveness  of  the  judicial  system  (its 
independence, high  quality and efficiency) and the effectiveness  of  the fight  against  corruption 
are of paramount importance. 

Türkiye  is  at  an  early  stage  of  applying  the  EU  acquis  and  European  standards  in  this  area. 
Serious backsliding continued during the reporting period. Major issues  identified in  previous 
reports, in particular the systemic lack of independence of the judiciary and the urgent need to 
improve  the  human  rights  situation,  remained  unaddressed.  The  2019  judicial  reform  strategy 
(JRS) and the March 2021 human rights action plan (HRAP), while tackling some of the areas 
where reforms are needed, do not include concrete steps to remedy the most acute problems in 
this area. 

23 

 
 
Undue pressure by the authorities on judges and prosecutors continued to have a negative effect 
on  the  independence  and  the  quality  of  the  judiciary.  Concerns  related  to  the  judiciary’s 
adherence  to  the  international  and  European  standards  increased,  in  particular  as  regards  the 
refusal to implement rulings by the European Court of Human Rights.  

Corruption remained widespread and continued to be an issue of concern. There was no progress 
in addressing the many gaps in the Turkish anti-corruption framework, which is a sign of a lack 
of will to decisively fight corruption. 

The  human  rights  situation  continued  to  deteriorate.  Broad  restrictions  on  the  activities  of 
journalists, writers, lawyers, academics, human rights defenders and critical voices continued to 
have  a  negative  effect  on  the  exercise  of  their  freedoms.  The  damage  caused  by  the  state  of 
emergency on fundamental rights and related legislation adopted was not remedied. There were 
some positive but limited efforts by the Human Rights and Equality Institution. 

Despite  some  legal  changes,  violence  against  women  and  gender  discrimination  remained 
matters  of  grave  concern,  in  the  aftermath  of  Türkiye’s  withdrawal  from  the  Istanbul 
Convention.  Sentences  for  gender-based  violence  remained  low  and  incapable  of  providing  an 
effective deterrent, and the culture of impunity remained unaddressed. In July 2022, the Council 
of  State  ruled  that  the  Presidential  decree,  allowing  Türkiye’s  withdrawal  from  the  Istanbul 
Convention, was lawful and rejected the cases asking for its reversal. In its ruling, the Council of 
State concluded that the President has the authority to withdraw from international conventions. 
The decision was appealed. 

Functioning of the judiciary 

Türkiye  is  at  an  early  stage  in  this  area.  There  was  serious  backsliding  during  the  reporting 
period and structural deficiencies in the judicial system were not addressed. Undue pressure by 
the  authorities  on  judges  and  prosecutors  continued  to  have  a  negative  effect  on  the 
independence  and the quality of the judiciary. Concerns  related to  the judiciary’s  adherence to 
the  international  and  European  standards  increased,  in  particular  as  regards  the  refusal  to 
implement  the  rulings  of  the  European  Court  of  Human  Rights.    The  judiciary  continued  to 
launch actions against opposition politicians. 

Implementation  of  the  2021  HRAP  and  the  2019  JRS  continued.  However,  both  documents 
failed  to  address  the  major  shortcomings  of  the  Turkish  judiciary,  lacking  significant 
improvements in the overall functioning of the country’s judicial system. The lack of objective, 
merit-based,  uniform  and  pre-established  criteria  for  recruiting  and  promoting  judges  and 
prosecutors  remains  a  source  of  concern.  Following  the  criticism  of  the  Venice  Commission 
regarding  the  institution  of  criminal  judges  of  peace,  the  appeal  system  was  changed  in  July 
2021, enabling their decisions to be appealed to a higher court.  

The  recommendations  of  last  year  were  not  addressed.  In  the  coming  year,  Türkiye  should  in 
particular: 

  create  a  political  and  legal  environment  that  allows  the  judiciary  to  carry  out  its  duties 
independently  and 
judicial 
responsibilities, with the executive and legislature fully respecting the separation of powers; 
and ensure that lower courts respect judgments by the Constitutional Court, whose decisions 
should abide by the ECtHR jurisprudence; 

respecting  European  standards;  strengthen 

impartially, 

24 

 
 
  amend  the  structure  and  process  of  selecting  the  members  of  the  Council  of  Judges  and 
Prosecutors  (HSK)  so  that  the  role  and  influence  of  the  executive  is  limited,  and  introduce 
safeguards  against  any  interference  by  the  HSK  or  high-level  officials  in  judicial 
proceedings; 

  provide effective guarantees against transfers of judges without their consent; 

  in  accordance  with  the  guaranteed  judicial  independence  under  the  Constitution,  limit  any 
suspension of judges from office to cases where there are well-founded suspicions of serious 
misbehaviour  and  take  measures  to  remedy  the  damage  caused  by  the  dismissals  that  took 
place in breach of procedural rights; 

  revise the system of disciplinary proceedings so that it is based on objective criteria without 

undue influence from the executive; 

  in  relation  to  the  administrative  and  judicial  measure  taken  against  individuals,  ensure  that 
any allegation of wrongdoing or crime is subject to due process, based on concrete evidence, 
following fully transparent procedures under the authority of an independent judiciary; 

  ensure that all judicial proceedings respect fundamental rights, including procedural rights, in 
particular  the  presumption  of  innocence,  individual  criminal  responsibility,  legal  certainty, 
the  right  to  defence,  the  right  to  a  fair  trial,  equality  of  arms  and  the  right  to  an  effective 
appeal. 

Strategic documents 

Implementation of the 2021 human rights action plan and the 2019-2023 judicial reform strategy 
continued. So far, six judicial reform packages (JRP) have been adopted, in addition to several 
pieces  of  legislation  on  fundamental  rights.  The  6th  JRP  introduced  inter  alia  the  posts  of 
assistant  judge  and  assistant  prosecutor  and  changed  some  regulations  on  the  Council  of  State 
and  the  Court  of  Cassation.  However,  it  failed  to  address  key  shortcomings  in  the  judicial 
system. The government’s implementation report for the JRP issued in December 2021 indicated 
that 171 out of 256 activities (67 %) have been completed. However, there is no evidence-based 
assessment of the results of the implementation of the package. These legislative changes address 
a  limited  number  of  issues  and  fail  short  of  tackling  the  main  long-standing  structural 
shortcomings.  

Management bodies 

Concerns remain around the structure of the Council of Judges and Prosecutors (HSK), its lack 
of independence from the executive, and the appointment process of its members. In accordance 
with  the  Constitution,  out  of  the  thirteen  members  of  the  HSK,  eleven  are  elected.  Out  of  the 
eleven  elected  members,  four  are  appointed  by  the  President  and  seven  are  appointed  by 
Parliament  by  qualified  majority.  None  is  elected  by  their  peers.  The  remaining  two  seats  are 
attributed ex officio to the Minister of Justice and the Deputy Minister, who are also appointed by 
the President. In the absence of a transparent selection process, the resignation of one member of 
the HSK and appointment of his replacement raised several public questions regarding political 
influence and patronage networks in the judiciary. Due to its lack of independence, the HSK has 
been suspended from participating in the European Network of Councils for the Judiciary since 
December 2016. 

25 

 
 
The budget allocated to the Council of Judges and Prosecutors increased to TRY 72 764 805 in 
2022, compared to TRY 30 209 000 for 2021.  

Independence and impartiality 

Judicial independence is set out in the Constitution and in relevant legislation; however, serious 
concerns  remained  about  political  influence  upon  the  judicial  system,  particularly  from  the 
executive  branch.  The  shortcomings  identified  in  the  Venice  Commission’s  December  2016, 
relating  to  the  minimal  standards  for  dismissals  of  judges  and  legal  safeguards  regarding  the 
transfer  of  judges  and  prosecutors  remained  unaddressed.  Appeals  against  such  transfers  are 
possible but usually unsuccessful.  

The  human  rights  action  plan  provides  for  some  actions  to  improve  the  independence  of  the 
judiciary,  including  the  prevention  of  frequent  transfer  of  judges,  geographical  guarantees  for 
judges  and  prosecutors,  a  review  of  the  disciplinary  and  promotion  system  for  judges  and 
prosecutors  and  an  improved  inspection  system  based  on  objective  criteria.  However,  most  of 
these  activities  have  not  yet  been  implemented.  Overall,  3  985  judges  and  public  prosecutors 
have been dismissed for alleged links to the Gülen movement since the 2016 attempted coup and 
only 515 have been returned to their positions. 17 more judges and prosecutors were dismissed 
over the reporting period.  

Judicial independence was further undermined by public comments by representatives from the 
executive  and  legislative  branched,  including  the  President,  over  ongoing  judicial  cases.  Some 
government officials also made public statements showing disregard for the rule of law and for 
human rights. Representatives of the executive and the legislature continued to publicly criticise 
and openly reject ECtHR and Constitutional Court case-law.  

Pre-trial  detention  was  frequently  imposed,  while  European  standards  consider  it  a  measure  of 
last resort, which should be applied for the shortest amount of time. The Law on Permanent State 
of  Emergency,  which  allowed  detention  for  up  to  12  days  in  cases  of  collective  crimes,  was 
abolished  in  July  2022.  Accordingly,  detention  periods  cannot  exceed  4  days.  The  ECtHR 
concluded that in  several  cases, including in  the  judgments relating to  Selahattin  Demirtaș and 
Osman  Kavala,  the  judicial  authorities’  decision  to  extend  the  detention  was  not  sufficiently 
justified.  In  November  2021,  the  ECtHR  issued  a  ruling  on  the  pre-trial  detention  of  426 
applicants  on  suspicion  of  membership  in  the  Gülen  movement,  and  ruled  that  their  pre-trial 
detention had been unlawful. Physical presence at trials should be ensured whenever possible in 
order to safeguard the right to defence. Elections to the bar associations were completed, after a 
hiatus  due  to  the  COVID-19  pandemic.  The  Council  of  Judges  and  Prosecutors  published  a 
social media usage guide. 

Accountability 

The  obligation  for  judges  and  prosecutors  to  declare  their  assets  every  five  years  is  still 
applicable.  It  remains  important  to  have  a  credible  and  functioning  verification  system  and  to 
ensure  that  there  is  appropriate  follow-up  for  late  or  incorrect  declarations  of  assets.  No 
information is available as to sanctions imposed   if this procedure is not followed. 

Professionalism and competence 

Judges and prosecutors continued to be selected and recruited through a non-transparent process. 
Ministry  of  Justice  supervision  over  the  selection  boards  for  new  judges  and  prosecutors 
continued.  The  Council  of  Judges  and  Prosecutors  (HSK)  itself  has  no  role  in  the  selection 

26 

 
 
boards, as the Minister of Justice leads the process. The HSK also manages the annual appraisal 
of  judges  and  prosecutors.  The  legal  exam  introduced  in  October  2019  for  candidate  judges, 
lawyers or public notaries has yet to take place. There was limited progress on setting objective, 
merit-based,  standardised  and  pre-established  criteria  for  recruiting  and  promoting  judges  and 
prosecutors. As regards the promotion systems, the HSK adopted in September 2021 a number of 
criteria which still need to be implemented.  

Quality of justice 

Pre-service training for candidate judges and prosecutors and in-service training continued to be 
delivered  by  the  Justice  Academy,  whose  lack  of  independence  remained  a  matter  of  concern. 
Despite  the  Academy’s  independence  being  enshrined  in  law,  its  management  is  left  to  its 
president,  who  is  appointed  by  the  President  of  the  Republic.  The  Academy’s  lack  of 
independence affects its capacity to provide training programmes that meet the requirements of 
openness, competence and impartiality. Since 2017, the European Judicial Training Network has 
suspended the Academy’s observer status. 

As of July 2022 Türkiye had 15 263 full-time judges (18.1 per 100,000 inhabitants) and 7 442 
full-time  prosecutors  (8.9  per  100,000  inhabitants)  in  2021.  According  to  the  European 
Commission  for  the  Efficiency  of  Justice  (CEPEJ),  the  European  averages  are  21  judges/12 
prosecutors  per  100,000  inhabitants.  Out  of  22  705  judges  and  prosecutors,  8  233  are  women. 
The budget for the judiciary increased to TRY 24 billion in 2021 compared with almost TRY 20 
billion in 2020. 

Concerns remain regarding the quality of judicial decisions and indictments, due to the lack of 
legal  reasoning  and  factual  evidence.  Civil  society  trial  monitoring  reports  reveal  that  in  some 
politically  sensitive  cases,  defence  rights  were  violated  as  judges  interrupted  defendants’ 
statements,  or  handed  down  a  decision  without  listening  to  the  defendant’s  statement. 
Particularly  in  terrorism-related  cases,  the  practice  of  providing  evidence  extracted  coercively, 
from secret witnesses who cannot be cross-examined properly, or from a single witness without 
supporting evidence should  be addressed. The system of  confidentiality  of decisions  should be 
revised, as  it is  still used in  many cases to  limit the lawyers’  access  to  their clients’ files, thus 
violating  the  right  of  defence.  Frequent  transfers  of  judges  and  prosecutors  continued  to 
negatively affect the quality of justice along with posting newly recruited and less experienced 
judges and prosecutors to criminal courts. 

Efficiency 

While the judicial reform strategy aims to increase the quality and quantity of human resources, 
this objective has not yet been achieved. The backlog of cases has not reduced. Large parts of the 
judiciary  continued  to  be  under  severe  pressure  to  handle  cases  in  a  timely  manner.  Criminal 
cases especially, are often postponed for months and in cases where the defendants are arrested 
pending trial, this delay further violates the defendant’s rights. Regarding the backlog of cases in 
the  high  courts,  at  the  end  of  2021,  296  907  criminal  and  76  455  administrative  cases  for  the 
Court  of  Cassation  were  transferred  to  2022,  compared  to  263  160  and  90  612  respectively  in 
2020. 128 961 cases for the Council of State were transferred from 2021 compared to 134 284 in 
2020.  As  regards  the  regional  courts  of  appeals,  in  2021,  a  total  of  745  416  cases  were 
transferred  from  2020;  the  courts  received  1  986  864  new  cases  and  settled  1  032  900  cases. 
Individual applications to the Constitutional  Court continued to increase. Since the process  for 
individual  applications  was  introduced  in  September  2012,  there  have  been  a  total  of  392  758 

27 

 
 
individual applications as of 31 December 2021 and 311 097 of these have been concluded. In 
2021, 66 121 applications were lodged and 45 321 were concluded.  

Fight against corruption 

Türkiye is at an early stage in the fight against corruption. There was no progress during the 
reporting period and last year’s recommendations were not addressed. The country has not set up 
anti-corruption bodies in  line with  the United Nations Convention against Corruption to  which 
Türkiye is party. The legal framework and institutional architecture need to be improved to limit 
undue  political  influence  in  the  prosecution  and  adjudication  of  corruption  cases.  The 
accountability  and  transparency  of  public  institutions  need  to  be  improved.  The  absence  of  an 
anti-corruption  strategy  and  action  plan  indicated  a  lack  of  will  to  decisively  fight  corruption. 
Most  of  the  Council  of  Europe’s  Group  of  States  against  Corruption  (GRECO)  outstanding 
recommendations have not been implemented. Overall, corruption is widespread, and remains an 
issue of concern. The sectors most vulnerable to corruption require targeted risk assessments and 
dedicated actions. 

In the coming year, Türkiye should in particular:  

  implement its international obligations effectively in relation to the fight against corruption, 
including  the  United  Nations  Convention  against  Corruption  and  the  Council  of  Europe 
Conventions; 

  ensure effective follow-up to the recommendations issued by GRECO, including by adopting 

the necessary legislation; 

  establish a track  record  of successful investigations of, prosecution of,  and convictions for, 

corruption including at high-level; 

  adopt  an  anti-corruption  strategy,  reflecting  a  clear  political  will  and  vision  to  address 

corruption effectively, underpinned by a credible and realistic action plan. 

Track record 

Türkiye  has  a  poor  track  record  of  investigations,  prosecutions  and  convictions  in  corruption 
cases,  particularly  in  relation  to  high-level  corruption  cases  implicating  politician  and  public 
officials.  Sentences  for  corruption  need  to  be  more  dissuasive.  Cooperation  between  audit  and 
inspection  units  and  prosecution  offices  is  insufficient.  The  increasing  use  and  wide  scope  of 
exemptions  in  procurement  procedures  undermined  the  integrity  of  public  procurement.  The 
government  continued  to  award  several  large  public-private  partnership  contracts  for  big 
infrastructure projects to a small number of companies. Political financing, local administrations, 
land administration, zoning and construction remained particularly prone to corruption.  

Institutional framework 

Prevention measures 

The country continued to lack a permanent, functionally independent anti-corruption body. The 
level of coordination between various preventive bodies remained largely inadequate. The State 
Supervisory  Council,  responsible  for  coordinating  preventive  anti-corruption  measures,  lacks 
independence. The anti-corruption legal framework is still weak in the private sector. There are 
no regular awareness-raising campaigns on transparency and the fight against corruption. 

28 

 
 
Law enforcement 

No  specialised  prosecution  services  have  been  established  to  lead  corruption  investigations. 
Similarly, there are no specialised courts exclusively adjudicating on anti-corruption cases. The 
legal  framework  allows  the  government  to  retain  undue  political  influence  over  the  judicial 
police,  which  had  an  impact  on  independent  and  effective  investigations.  Inter-agency 
cooperation and information sharing between law enforcement and the financial intelligence unit 
need to be further developed.  

Legal framework 

Türkiye  is  party  to  all  international  anti-corruption  conventions,  including  the  United  Nations 
Convention against Corruption. However, the country fails to fully align with the provisions of 
these conventions. Previous anti-corruption strategies and action plans have not been effectively 
followed  up.  The  outstanding  legislative  amendments  envisaged  in  previous  national  anti-
corruption strategies were not  adopted. These included amendments  to the  Law on the  general 
administrative  procedure,  the  Law  on  public  procurement,  the  Code  of  Ethics  for  Members  of 
Parliament and the  Law  on whistle-blower protection. The legal  framework for  whistle-blower 
protection and public procurement still needs to be aligned with the new relevant EU acquis.  

During  the  reporting  period  no  tangible  progress  was  made  to  implement  GRECO’s 
recommendations.  Under the previous Third Evaluation  Round on the transparency of political 
financing,  Türkiye  implemented  only  one  out  of  nine  recommendations  over  a  period  of  10 
years.  As  regards  the  ethics  and  integrity  of  Members  of  Parliament,  judges  and  prosecutors, 
covered  by  the  current  Fourth  Evaluation  Round,  the  latest  interim  report  from  June  2022 
indicates  that  only  three  out  of  22  recommendations  have  been  fully  implemented,  nine  have 
been  partially  implemented  and  ten  recommendations  remain  not  implemented,  demonstrating 
that no real progress has been made since the publication of the previous interim report in March 
2021.  

Shortcomings  remain  unaddressed  in  the  corruption-related  provisions  of  the  Criminal  Code, 
which  do  not  meet  the  standards  of  the  Council  of  Europe  Criminal  Law  Convention  on 
Corruption. The definition of active bribery provided in the Criminal Code is still not in line with 
international standards. The shortcomings particularly relate to the provisions on bribery in the 
private sector.  

Public procurement legislation is not in line with the EU acquis. The vast number of exemptions 
inserted into the law on public procurement continued to be a matter of serious concern. Legal 
privileges for public officials, such as the requirement for prior authorisation from their hierarchy 
before  an  investigation  can  be  initiated  against  them  for  alleged  wrongdoing,  continued  to 
provide  legal  protection  for  public  officials  in  anti-corruption  criminal  and  administrative 
investigations.  The  legal  framework  on  preventing,  prosecuting  and  issuing  penalties  for 
conflicts of interest as well as on declaring, verifying and disclosing assets remained inadequate.  

Financial control of political parties remained ineffective.  Türkiye has no legislation governing 
lobbying. 

Strategic framework 

The 2010-2014 and the 2016-2019 anti-corruption strategies and action plans did not deliver on 
most  of  their  objectives  and  a  new  anti-corruption  strategy  has  not  yet  been  drawn  up. 
Outstanding  measures  initially  envisaged  in  the  anti-corruption  action  plans  were  not  followed 

29 

 
 
up.  Türkiye  needs  to  put  in  place  mechanisms  to  coordinate,  implement  and  monitor  all  anti-
corruption actions among relevant preventive institutions and law enforcement agencies. 

Fundamental rights 

The  deterioration  of  human  rights  continued,  and  no  progress  was  made  on  last  year’s 
recommendations.  Many  of  the  measures  introduced  during  the  state  of  emergency  remain  in 
force and continue to  have a profound and devastating impact  on people in  Türkiye. The legal 
framework  includes  general  guarantees  of  respect  for  human  and  fundamental  rights,  but  the 
legislation and its implementation need to be brought into line with the European Convention on 
Human Rights (ECHR) and the European Court of Human Rights (ECtHR) case-law.  

The  Council  of  Europe’s  Parliamentary  Assembly  continued  to  monitor  Türkiye’s  respect  for 
human rights, democracy and the rule of law. Türkiye’s continued refusal to implement certain 
ECtHR rulings, notably in the cases of Selahattin Demirtaş and Osman Kavala, further increased 
concerns  regarding  the  judiciary’s  adherence  to  international  and  European  standards.  This 
concern increased following the handing down of heavy penalties on the defendants in the Gezi 
case.  

The  human  rights  action  plan  adopted  in  2021,  which  committed  to  undertake  reforms  in  a 
number of areas, continued to be implemented but it does not address critical issues and has not 
led to an improvement in the overall human rights situation. Many journalists, writers, lawyers, 
academics, human rights defenders and critical voices faced convictions or trials on account of 
alleged support for terrorism. 

In  addition  to  addressing  the  shortcomings  set  out  in  this  section,  which  have  still  not  been 
addressed, in the coming year Türkiye should in particular: 

  align  its  criminal  and  anti-terror  legislation  and  their  implementation  with  European 

standards, the ECHR, ECtHR case-law and Venice Commission recommendations; 

  ensure that any allegations of offences are subject to due process, based on concrete evidence 
and  fully  transparent  procedures  carried  out  under  the  authority  of  an  independent  and 
impartial judiciary, and fully respecting the right to a fair trial and relevant procedural rights, 
in particular the presumption of innocence, individual criminal responsibility, legal certainty, 
the  right  to  defence,  equality  of  arms  and  the  right  to  an  effective  appeal;  ensure  the 
effectiveness of the Inquiry Commission on the State of Emergency Measures as a domestic 
remedy; 

  improve the legislative framework and its implementation, to effectively tackle all forms of 
violence  against  women,  including  domestic  violence,  psychological  and  physical  abuse, 
sexual  harassment,  rape,  crimes  committed  in  the  name  of  ‘honour’,  stalking,  and  forced 
marriage. 

  Implement as a matter of priority the ECtHR judgement in the case of Kavala v. Türkiye. 

Türkiye is a party to most international human rights instruments; however, the deterioration 
of the human rights situation in practice continued. On the day Türkiye formally withdrew from 
the  Council  of  Europe  Convention  on  preventing  and  combating  violence  against  women  and 
domestic  violence  (the  ‘Istanbul  Convention’),  the  President  unveiled  a  new  action  plan  to 
improve the legal, administrative and political means of combating violence against women. In 

30 

 
 
April  2022,  the  Council  of  State  accepted  around  200  applications  filed  by  women’s 
organisations, lawyers and bar associations to undo the government’s decision to withdraw from 
the Istanbul Convention. The prosecutor of the Council of State considered that the withdrawal 
from  the  Istanbul  Convention  was  unlawful.  In  July,  the  Council  of  State  ruled  that  the 
Presidential  decree,  allowing  Türkiye’s  withdrawal  from  the  Istanbul  Convention,  was  lawful 
and  rejected  the  cases  asking  for  its  reversal,  stating  that  the  President  has  the  authority  to 
withdraw  from  international  conventions.  Türkiye  has  not  yet  signed  the  International 
Convention  for  the  Protection  of  all  Persons  from  Enforced  Disappearance  and  the  Optional 
Protocol  to  the  International  Covenant  on  Economic,  Social  and  Cultural  Rights.  The 
Parliamentary Assembly of the Council of Europe continued its full monitoring procedure. 

In  the  reporting  period,  the  European  Court  of  Human  Rights  (ECtHR)  delivered  621 
judgments  and  found  violations  of  the  European  Convention  on  Human  Rights  (ECHR)  in  70 
cases  relating  mainly  to  freedom  of  expression,  the  right  to  liberty  and  security,  protection  of 
property, the right to fair trial, the right to free elections, respect for private and family life and 
the right to life. During the reporting period, 9 856 new applications were allocated to a decision 
body of the ECtHR. In June 2022, the total number of Turkish applications pending before the 
Court was 17 006. There are currently 188 cases against Türkiye under enhanced supervision by 
the Committee of Ministers. In the case of Kavala v. Türkiye, in March 2021 the Committee of 
Ministers of the Council of Europe recalled the ECtHR’s findings that the applicant’s arrest and 
pre-trial detention took place in the absence of evidence to support a reasonable suspicion he had 
committed  an  offence  (violation  of  Article  5  §  1  of  the  Convention)  and  pursued  an  ulterior 
purpose, namely to silence him and dissuade other human rights defenders (violation of Article 
18 taken in conjunction with Article 5 § 1); and that the one year and nearly five months taken 
by  the  Constitutional  Court  to  review  his  complaint  was  insufficiently  ‘speedy’,  given  that  his 
personal liberty was at stake (violation of Article 5 § 4). The Committee of Ministers reiterated 
their call for the applicant’s immediate release. Finally, the Committee of Ministers decided to 
examine  the  applicant’s  situation  at  each  regular  and  human  rights  meeting  of  the  Committee 
until such time that he is released, which means on a weekly basis.  

Türkiye  needs  to  contribute  to  the  work  of  the  Committee  of  Missing  Persons  (CMP).  Since 
2006,  Türkiye  has  provided  access  to  some  military  areas  for  the  CMP’s  bi-communal 
excavation  teams.  CMP  is  in  the  process  of  finalising  the  excavations  of  the  remaining  13 
military areas.  

In March 2022, the Committee of Ministers of the Council of Europe reviewed the 4th interstate 
case Cyprus v. Turkey (judgment in 2001) as well as Varnava and others v. Turkey (judgment in 
2009). The Committee of Ministers underlined once again that it remains urgent for the Turkish 
authorities  to  maintain  and  advance  their  proactive  approach  to  providing  the  CMP  with  all 
necessary assistance. 

At  its  September  2021  meeting,  the  Committee  of  Ministers  adopted  an  interim  resolution  in 
relation  to  the 2014 just satisfaction judgment of  the Grand Chamber of the ECtHR, related to 
the  4th  interstate  case  where  the  Court  awarded  the  sum  of  EUR  90  million  in  respect  of  non-
pecuniary damage suffered by the relatives of the missing persons and the enclaved population of 
the Karpas peninsula. This interim resolution strongly urged the Turkish authorities to abide by 
their  unconditional  obligation  and  pay  the  debt  without  further  delay.  In  March  2022,  the 
Committee  of  Ministers  deplored  the  absence  of  a  response  to  the  interim  resolution  and 
reiterated its call on Türkiye to pay the sums awarded without further delay.  

31 

 
 
In  March  2022  the  Committee  of  Ministers  of  the  Council  of  Europe  adopted  an  interim 
resolution in relation also to the case Varnava and Others against Turkey. This deplored the fact 
that to date the Turkish authorities have not complied with their unconditional obligation to pay 
the amounts awarded by the Court. The Committee firmly reiterated its insistence on Türkiye’s 
unconditional  obligation  to  pay  the  just  satisfaction  awarded  by  the  Court  in  2009,  expressing 
profound  concern  that  prolonged  delays  in  fulfilling  these  obligations  not  only  deprive  the 
individual victims  of receiving  compensation for the damages suffered by  them, but  are also  a 
flagrant disrespect of Türkiye’s international obligations, both as a High Contracting Party to the 
Convention and as a Member State of the Council of Europe.  

As of April 2022, 7 111 applications had been lodged with the Immovable Property Commission 
(IPC)  in  the  northern  part  of  Cyprus.  Of  those,  1  324  have  been  concluded  through  amicable 
settlements  and  34  through  formal  hearings.  Altogether,  the  IPC  has  so  far  paid  out  the 
equivalent of EUR 392 million in compensation to applicants.   

On the promotion and enforcement of human rights, the implementation of the March 2021 
human  rights  action  plan  continued.  There  is  no  evidence-based  assessment  of  the 
implementation of the human rights action plan and the annual monitoring report which was due 
in March 2022 is not  yet available to the public. The human rights action plan did not include 
measures to address critical issues underpinning the worrying human rights situation in Türkiye 
and the lack of independence of the judiciary.  

The Human Rights and Equality Institution of Türkiye (HREI) and the Ombudsman are the main 
human rights institutions. The Ombudsman only processes complaints against the actions of the 
public administration and has no ex-officio powers while the HREI only accepts cases which fall 
outside the Ombudsman’s remit. No revisions were made to improve the operational, structural 
or  financial  independence  of  either  institution  and  the  system  for  appointing  their  members 
stayed  the  same.  The  HREI  has  applied  for  accreditation  to  the  Global  Alliance  for  National 
Human  Rights  Institutions  despite  no  progress  made  to  comply  with  the  Paris  principles  on 
which the accreditation is based.  

The  effectiveness  of  both  institutions  remains  very  limited.  In  2021,  the  HREI  received  1  185 
applications (compared to 1 363 in 2020), visited 56 institutions including prisons and adopted 
23  reports  prepared  within  the  scope  of  visits.  However,  in  general,  the  HREI  refrains  from 
visiting  the  prisons  where  most  torture  and  ill  treatment  allegations  are  reported.  The  new 
chairperson of the HREI has brought some dynamism to the institution in tackling human rights 
issues and in engaging in constructive dialogue with the civil society. However, the HREI is not 
effectively carrying out its mandate due to legislative and structural restrictions, including by not 
accepting applications filed by civil society organisations and by being cautious in tackling cases 
of  torture  and  ill  treatment.  A  total  of  4  464  individual  and  1  697  collective  applications  were 
filed with Parliament’s Human Rights Inquiry Committee in 2021 out of which 2 669 were not 
admitted. 

Human  rights  defenders  faced  heavy  pressure  through  judicial  investigations,  court  cases, 
threats,  surveillance,  prolonged  arbitrary  detentions  and  ill-treatment,  which  had  an  overall 
chilling effect on the independent civil society. Smear campaigns and targeting by some media 
outlets  close  to  the  government  and  aggressive  rhetoric  by  elected  and  appointed  officials 
towards human rights defenders led to further shrinking of the space for critical views. Lawyers 
providing  legal  assistance  to  human  rights  defenders  and  civil  and  political  activists  were 

32 

 
 
hindered in performing their work and themselves faced detentions, arrests and prosecution. 

In February 2022, the Committee of Ministers of the Council of Europe referred the Kavala case 
back to the European Court of Human Rights to determine whether Türkiye has failed to fulfil its 
obligation  to  implement  the  Court’s  2019  judgment  in  this  case,  in  line  with  proceedings 
provided  for  under  Article  46.4  of  the  European  Convention  on  Human  Rights.  The  Turkish 
authorities  continued  to  refuse  Osman  Kavala’s  release,  despite  the  Council  of  Europe 
Committee  of  Ministers’  regular  interim  resolutions.  In  July  2022  the  Grand  Chamber  of  the 
European Court of Human Rights confirmed that Türkiye has failed to fulfil its obligations under 
Article 46.1 of the Convention to comply with the Chamber judgment delivered by the Court in 
the  case  of  Kavala  on  10  December  2019.  The  Court  reconfirmed  that  Mr.  Kavala’s  detention 
had  been  politically  motivated  and  an  attempt  to  silence  him  and  dissuade  other  human  rights 
defenders. His April sentencing to aggravated life imprisonment is inconsistent with respect for 
human rights, fundamental freedoms, and the rule of law. 

After  the  Minister  of  Interior’s  harsh  criticism  of  the  Human  Rights  Association  (HRA), 
following its press statement on the deaths of 13 Turkish citizens in northern Iraq’s Gara region 
in  2021, three new cases were launched against the Human Rights  Association  chairperson.  In 
the first case in April 2022, the co-chair of the HRA was acquitted of charges of ‘membership in 
an  illegal  armed  organisation’  due  to  lack  of  evidence.  The  other  two  cases  are  pending.  The 
court  case  regarding  the  killing  of  lawyer  and  chairperson  of  the  Diyarbakir  Bar  Association 
Tahir Elçi in 2015, continued. Several female human rights defenders and activists were detained 
and faced fines while protesting against the withdrawal from the Istanbul Convention.  

Concerning the  right to  life, there are still serious shortcomings as  regards the steps to  ensure 
credible  and  effective  investigations  into  reported  killings  by  the  security  services.  The 
legislation  adopted  in  June  2016  which  grants  judicial  privileges  to  the  security  services  and 
increases  the  risk  of  impunity  is  still  in  force.  The  authorities  need  to  take  urgent  measures  to 
align  this  legislation  with  ECtHR  case-law  and  standards.  Overall,  impunity  remains  a  major 
concern.  In  many  cases,  the  authorities  denied  permission  to  prosecute  public  servants.  No 
adequate investigations have been carried out in relation to the alleged cases of abductions and 
enforced disappearances by security or intelligence services in several provinces reported since 
the attempted coup. According to independent data, in 2021 the right to life of at least 2 964 (3 
291  in  2020)  people  was  violated.  Credible  investigations  into  some  of  the  deaths  that  were 
reported  in  the  media  are  still  lacking.  A  case  is  still  pending  before  the  Constitutional  Court 
relating  to  the  death  of  a  villager  in  Van  province,  taken  away  by  a  military  helicopter  and 
allegedly tortured after being detained in November 2020. The reported killings by the security 
authorities in the south-east, especially in relation to the events in 2015, remain effectively not 
investigated  and  sanctioned.  The  Council  of  State  annulled  the  Ministry  of  Interior  circular  of 
April 2021, preventing citizens from recording videos of police officers during demonstrations, 
which  had  raised  further  concerns  over  the  weakening  of  law  enforcement  officers’ 
accountability and the prevention of evidence collection.  

Credible  and  grave  allegations  of  torture  and  ill-treatment  increased.  According  to  available 
reports,  torture  and  ill-treatment  occurred  in  detention  centres,  prisons,  in  informal  places  of 
detention, transportation vehicles and on the streets, mostly during demonstrations. The Human 
Rights  and  Equality  Institution  of  Türkiye  (HREI),  whose  role  is  to  act  as  the  National 
Preventive Mechanism (NPM), does not meet the key requirements under the Optional Protocol 
to  the  UN  Convention  against  Torture  and  other  Cruel,  Inhuman  or  Degrading  Treatment  or 

33 

 
 
Punishment (OPCAT) and is not yet effectively processing cases referred to it. Prison monitoring 
boards need to be made more effective. The authorities have not authorised the publication of the 
2016  and  2021  reports  by  the  Council  of  Europe’s  Committee  for  the  Prevention  of  Torture 
(CPT).  There continued to be a lack of effective investigations into allegations of torture and ill 
treatment.  Complaints,  reports  and  any  indications  of  torture  or  ill-treatment  need  to  be 
investigated swiftly, effectively and impartially;  perpetrators must be prosecuted and convicted 
in line with Türkiye’s international obligations, in particular with the ECHR and the OPCAT.  

The  overcrowding  of  the  prison  system  is  a  serious  concern.  As  of  August  2022,  the  prison 
population exceeded 320 000 and is the largest in Europe. Türkiye continues to be the Council of 
Europe Member State with the highest overcrowding rate. Although the human rights action plan 
contained  some  measures  to  improve  living  conditions  in  prisons,  allegations  of  human  rights 
violations including arbitrary restrictions on the rights of detainees, denial of access to medical 
care, mistreatment, limitation on open visits and solitary confinement continued to be reported. 
Investigations  into  allegations  of  suicides,  strip  search  and  discriminatory  behaviour  by  prison 
guards,  remained  limited.  Hunger  strikes  in  some  prisons  continued  to  demand  the  end  to 
violations of detainees’ rights. There are reports that LGBTIQ persons are discriminated against 
by prison  authorities. There are concerns related to the independence of the Forensic Medicine 
Institute as it operates under the Ministry of Justice and often ignores medical reports. Decisions 
requiring access to medical care for sick inmates are often delayed or  denied, causing death in 
prison or soon after release. The HREI, which should act as the national preventive mechanism, 
and  the  prison  monitoring  boards  do  not  provide  an  effective  driving  force  to  improve  the 
situation. The work of these boards is not transparent and it is not supervised by relevant NGOs 
and bar associations. 

On  the  protection  of  personal  data,  Türkiye  still  needs  to  align  the  2016  data  protection  law 
with  the  EU  acquis.  To  that  end,  a  ‘scientific  commission’  was  set  up  in  June  2021.  The  data 
protection reform is expected to improve Türkiye’s potential cooperation with Eurojust, Europol 
and, more generally, cooperation with the EU in a number of policy areas. The legislation needs 
to be improved notably with regard to the exceptions for law enforcement and the independence 
of the Personal Data Protection Authority. The 2018 Protocol amending the Convention for the 
Protection  of  Individuals  with  regard  to  Automatic  Processing  of  Personal  Data  (Council  of 
Europe, CETS No 223) has yet to be signed and ratified.  

On freedom of thought, conscience and religion, freedom of worship continued to be generally 
respected. The lack of legal personality of non-Muslim and Alevi communities remains a serious 
issue, notably in relation to the lack of legal status of patriarchates, chief rabbinate, synagogues 
and  churches.  The  Venice  Commission’s  recommendations  on  the  legal  status  of  non-Muslim 
religious communities and the right of the Greek Orthodox Ecumenical Patriarchate in Istanbul 
to  use  the  title  ‘Ecumenical’  have  yet  to  be  implemented.  The  new  Community  Foundations 
Election  Regulation,  which  has  been  being  prepared  since  2013,  was  published  in  June  2022, 
increasing the state’s control over minority foundations at every stage of the elections. Decisions 
in cases related to property of religious communities still need to be implemented. 

The lack of legal  provisions on conscientious objection to  army service remains a problem  for 
Jehovah’s Witnesses and other citizens, as refusing to serve in the military results in conviction 
for desertion. There are several unimplemented ECtHR judgements and decision by the UN that 
found violations of the rights of Jehovah’s Witnesses. In September 2021, the Council of State 
recognised in September 2021 the Kingdom Hall of Jehovah’s Witnesses in Mersin following the 

34 

 
 
2016  ECtHR  judgement,  which  should  set  a  precedent  for  the  other  pending  Halls.  School 
textbooks need to be revised in order to remove all discriminatory elements against all religions 
and faith groups. 

Two instances of damage caused to Hagia Sophia, which was converted into a mosque in 2020, 
were reported in April and May 2022, indicating a lack of proper care of the historic monument. 
The  UNESCO  World  Heritage  Committee  has  expressed  grave  concern  about  the  potential 
impact of the status change on the outstanding universal value of Hagia Sophia and has called on 
Türkiye to engage in international cooperation and dialogue before any further major changes are 
implemented  at  the  property.  No  steps  were  taken  to  open  the  Halki  (Heybeliada)  Greek 
Orthodox Seminary, which has been closed since 1971. 

In  December  2021,  the  Council  of  Europe  Committee  of  Ministers  urged  Türkiye  to  take 
measures  with  regard  to  the  longstanding  issues  faced  by  Alevis.  In  April  2022,  the 
Constitutional  Court  decided  that  the  Turkish  Constitution  and  freedom  of  religion  and 
conscience were violated in the application of an Alevi father, whose request for his child to be 
exempted  from  religious  class  was  rejected.  Alevis  faced  hate  crimes,  and  the  subsequent 
investigations remained largely inconclusive. Multiple attacks took place against Alevi worship 
places (Cem Houses) and Alevi religious leaders in July and August in Ankara and Istanbul. The 
government  condemned  the  attacks  and  committed  to  fully  investigate  the  incidents.  A 
comprehensive  legal  framework  in  line  with  European  standards  needs  to  be  put  in  place,  and 
appropriate  attention  must  be  paid  to  implementing  the  ECtHR  judgments  on  compulsory 
religion and ethics classes and Alevi worship places. 

Hate  speech  and  hate  crimes  against  Christians,  Protestants  and  Jews  continued  to  be  reported 
(see  below  -  Minorities).  Protestants  continued  to  face  problems  with  the  recognition  of  their 
places  of  worship.  Vandalism  to  and  destruction  of  minority  worship  places  and  cemeteries 
continued. Hate speech and insults against atheists and deists continued. 

Reports  of  maltreatment  and  sexual  abuse  in  dormitories  and  Quran  courses  controlled  by  the 
religious  sects  and  the  Religious  Affairs  Presidency  (Diyanet)  continued.  The  increased  work, 
powers and influence of the Diyanet continued in all spheres of public life. The Diyanet Law was 
amended in March 2022 to establish a new academy that possesses broad powers.  

Freedom of expression 

Türkiye continues to be at an early stage in this area and the serious backsliding observed over 
the past  years continued. The implementation of criminal laws relating to national security and 
anti-terrorism  continued  to  contravene  the  ECHR  and  other  international  standards  and  to 
diverge  from  the  ECtHR  case-law.  The  dissemination  of  opposition  voices  and  freedom  of 
expression were negatively affected by the increasing pressure and restrictive measures. Criminal 
cases  and  convictions  of  journalists,  human  rights  defenders,  lawyers,  writers,  opposition 
politicians, students, artists, and social media users continued.  

The recommendations from the last five annual reports of the Commission were not addressed. 
In the coming year, Türkiye should in particular:  

  release journalists, human rights defenders, lawyers, writers and academics being held in pre-

trial detention;  

  ensure that the criminal cases against them are concluded in accordance with the criteria set 

35 

 
 
by the ECHR and the ECtHR;  

  ensure  a  safe,  pluralist  and  enabling  environment  for  the  media  to  carry  out  their  work 
independently and without fear of reprisals and dismissals. This includes ending the practice, 
exercised  by  both  state  and  non-state  agents,  of  intimidating,  interfering  with  and  putting 
pressure on the media;  

  revise  criminal  legislation,  in  particular  the  anti-terror  law,  the  Criminal  Code,  the  data 
protection law, the internet law and the Radio and Television Supreme Council (RTÜK) law 
to  ensure  these  comply  with  European  standards  and  are  implemented  in  a  manner  which 
does not curtail freedom of expression;  

  ensure that criminal law provisions on defamation and on other similar offences are not used 

as a means of putting pressure on critical voices. 

Intimidation of journalists 

Increased  restrictions  imposed  on  the  activities  of  journalists,  writers,  lawyers,  academics, 
human  rights  defenders,  opposition  politicians  and  critical  voices,  through  arrests,  detentions, 
prosecutions,  convictions continued to  have a negative effect  on the exercise of their freedoms 
and led to self-censorship. A large number of cases continued to be launched against writers and 
journalists.  As  of  September  2022,  69  journalists  and  media  employees  were  in  prison,  either 
pending trial or serving a sentence. In 2021, at least 41 (48 in 2020) journalists were taken into 
custody,  35  (23  in  2020)  journalists  were  sentenced  to  a  total  of  92.5  (103  in  2020)  years  in 
prison. Threats  and physical  attacks, which sometimes resulted into killings, on journalists and 
media organisations due to their work continued in 2021. In February 2022, a journalist  known 
for  his  reporting  on  corruption  was  killed  in  Kocaeli.  According  to  civil  society  reports  56 
opposition  journalists  in  Türkiye  were  physically  assaulted  by  politically  motivated  groups.  In 
June  2022,  20 journalists  and  one  media  worker  from  the  Kurdish  production  companies  were 
detained and later arrested in Diyarbakır. 

Legislative environment 

The  current  laws  on  anti-terrorism,  the  internet,  intelligence  services  and  the  Criminal  Code 
impede  freedom  of  expression  and  run  counter  to  European  standards.  Selective  and  arbitrary 
application  of  legislation  continued  to  raise  concerns  as  it  infringes  the  basic  principles  of  the 
rule of law and right to a fair trial.  

A  large  number  of  allegations  of  violations  of  freedom  of  expression  were  submitted  to  the 
ECtHR.  The  current  legislation  does  not  sufficiently  guarantee  freedom  of  expression  in  line 
with the ECHR and ECtHR case-law and permits restrictive interpretation by the judiciary. The 
Council  of  Europe  Committee  of  Ministers  adopted  an  interim  resolution  in  2021  on  a  long-
standing  series  of  freedom  of  expression  cases  against  Türkiye  and  strongly  urged  the  Turkish 
authorities  to  consider  further  legislative  changes  of  the  Criminal  Code  and  the  anti-terrorism 
law  in  light  of  the  European  Court  of  Human  Rights  case-law.  Despite  the  fourth  judicial 
package  having  introduced  the  need  for  a  strong  evidence  base  in  ‘catalogue  crimes’,  there 
remains a category of crimes that automatically requires ‘arrest pending trial’, for cases relating 
to freedom of expression.  

A circular issued by the President in January 2022 addressed to all print, audio and visual media, 
including social media and digital platforms, aimed inter alia sought to  ‘protect the youth from 

36 

 
 
bad habits and ignorance and protecting the national culture against alienation and degeneration’. 
The  circular  uses  very  generic  definitions  making  it  open  to  arbitrary  interpretations  by  the 
authorities, while threatening undisclosed  ‘steps’, ‘sanctions  enshrined in  the Constitution’ and 
‘any necessary measures’, which have a further restrictive effect on freedom of expression and 
media  in  Türkiye.  The  Union  of  Turkish  Bar  Associations  filed  a  motion  against  this  circular, 
pointing out its negative impact on freedom of expression.  

The Council of State suspended the enforcement of the Ministry of Interior’s April 2022 circular 
issued,  banning  journalists  and  citizens  from  recording  audio  and  video  during  public  protests 
arguing  that  it  restricted  the  freedom  of  communication  and  press  and  concluding  that 
fundamental rights and freedoms should only be restricted by law.  

Implementation/institutions 

Intimidation, prosecution and imprisonment of critical journalists and media outlets on extensive 
charges  of  terrorism,  insulting  public  officials,  and/or  allegedly  committing  crimes  against  the 
state  and  the  government  continued.  The  indictments  and  accusations  fail  to  make  direct  and 
credible links between the alleged offence and the act. The exercise of constitutional rights such 
as attending press statements or trade union activities continue to be cited as crimes and used as 
grounds for indictments. The lack of proportionality in the interpretation and application of the 
existing  legal  provisions  by  courts  and  prosecutors,  which  leads  to  violations  of  freedom  of 
expression and selective and arbitrary application of the legislation continued to raise concerns.  

The Press Advertising Agency (BiK) continued to impose public advertising bans for media that 
criticised  the  government.  Cases  launched  by  the  President  and  his  family  against  journalists 
continued.  The  President,  the  leader  of  the  MHP  party  and  the  Minister  of  Interior  used 
inflammatory  and  polarising  rhetoric  against  those  who  legitimately  criticise  the  government. 
Two  investigations  were  launched  against  an  opposition  Member  of  Parliament  relating  to  his 
criticisms of the state’s alleged relationship with the mafia.  

Article 299 of the Turkish Penal Code, which provides for a maximum sentence of four years in 
prison for insulting the President, continued to be used extensively to prosecute critical voices. 
Tens of thousands of people have been convicted and investigated under this article in Türkiye. 
This  practice  was  condemned  in  several  cases  by  the  ECtHR.  In  the  Vedat  Şorli  case  which 
became  final  in  2022,  the  ECtHR  ruled  that  Article  299  does  not  comply  with  the  ECHR 
principles.  

In  January  2022,  the  ECtHR  ruled  that  German-Turkish  journalist  Deniz  Yücel’s  rights  to 
personal  liberty  and  security,  compensation  for  unlawful  detention,  and  freedom  of  expression 
were violated, adding that holding people who express critical opinions in preventive detention 
had  a  chilling  effect  on  freedom  of  expression.  The  Constitutional  Court  issued  several 
judgements  in  individual  applications  in  which  it  concluded  that  the  right  to  freedom  of 
expression was violated.  

The State of Emergency Commission has still not examined a single case relating to the ‘Peace 
Academics’  since  July  2017,  when  it  started  to  receive  applications,  despite  a Constitutional 
Court decision in July 2019, that established there had been a violation in this case.  

Public Service Broadcasters 

The  public  service  broadcaster  Turkish  Radio  and  Television  Corporation  (TRT)  is  affiliated 
with the Presidential Communication Authority, and the Radio and Television Supreme Council 

37 

 
 
(RTÜK)  with  the  Ministry  of  Culture  and  Tourism.  There  were  no  changes  to  TRT’s  editorial 
policy  of  TRT,  which  reflects  the  government’s  official  lines.  The  concerns  relating  to  RTÜK 
independence and neutrality remained as members continue to be elected by Parliament without 
consulting civil society or professional media organisations. The HDP member of RTÜK is still 
in  prison.  RTÜK  continued  to  suspend  and  impose  fines  on  independent  television  and  radio 
channels for their broadcasting content on the vague grounds that the content is ‘contrary to the 
national and moral values of society, general morality and the principle of family protection’.  

In  2021,  RTÜK  levied  71  administrative  fines  against  independent  channels  critical  of  the 
government,  ordering  them  to  pay  TRY  21  500  000  in  total.  No  fine  was  levied  against  pro-
government media in 2021.  In February 2022, RTÜK requested from Deutsche Welle Turkish, 
Euronews Turkish and Voice of America news sites to apply for a licence within 72 hours. All 
three international media outlets announced that they would not abide by this decision. In April 
2022, RTÜK announced that it would no longer require Euronews to obtain a license, since the 
news channel removed content that would have required a licence. In June 2022 RTÜK decided 
to  ban  access  to  the  Turkish-language  websites  of  the  Voice  of  America  and  Deutsche  Welle. 
This  decision  is  an  attempt  to  further  restrict  media  freedom  and  access  to  information  in 
Türkiye. 

Economic factors 

There  were  no  developments  as  regards  the  Broadcasting  Law,  which  does  not  ensure  fair 
competition as it does not prevent monopolisation. The ownership of the Turkish media outlets 
undermines  the  independence  of  editorial  policies  as  it  lacks  transparency,  and  a  few  holding 
groups  are  close  to  the  government.  Measures  need  to  be  taken  to  ensure  that  the  state 
advertising budget is fairly distributed, accountable and transparent. 

Internet 

Conditions  for  an  open  and  free  internet  are  not  in  place  in  Türkiye.  Numerous  websites  and 
social  media  that  express  views  not  in  line  with  the  positions  of  the  ruling  coalition,  are  often 
blocked and their authors face harassment and at times prosecution.  

In  March  2022,  Türkiye’s  General  Directorate  of  Security  announced  having  ‘started  taking 
action  against  Twitter  accounts’  for  tweeting  ‘provocative’  and  ‘misleading’  that  it  had 
concerning  the  rising  cooking  oil  prices,  as  a  result  of  the  war  in  Ukraine.  The  President  of 
RTÜK,  also  announced  that  necessary  steps  will  be  taken  against  the  ‘misleading  broadcasts 
about food prices’. There are no official statistics on banned websites, or the blockage of content 
based on the rulings of the criminal law judges of peace.  

Türkiye has not been invited to sign a declaration on the future of the Internet launched by the 
EU,  the  USA  and  like-minded  countries  as  it  does  not  fulfil  the  criteria  for  a  trusted  Internet 
which reinforces core democratic principles, fundamental freedoms and human rights. 

Professional organisations and working conditions 

The representation of journalists is still divided between the professional journalists’ associations 
and  the  pro-government  union.  Journalism  in  Türkiye  continued  to  be  a  precarious  and  risky 
profession, with low wages, high risk of judicial harassment and a lack of job security. Working 
conditions continue to be instable, trade union rights are insufficient and labour legislation is not 
properly  applied.  Obtaining  press  cards  and  arbitrary  accreditations  remain  major  problems. 
Investigative journalism, politically sensitive issues continue to be subject to editorial pressure, 

38 

 
 
self-censorship  and  judicial  harassment  (see  also  Chapter  10  -  Digital  transformation  and 
media).  

------------------------------------------------------------------------------------------------------------------- 

There  was  further  backsliding  in  the  area  of  freedom  of  assembly  and  association  where 
legislation  and  its  implementation  are  not  in  line  with  the  Turkish  Constitution,  European 
standards or the international conventions that Türkiye is party to. There was an increase in the 
use  of  bans,  the  disproportionate  use  of  force  and  the  number  of  interventions  in  peaceful 
demonstrations,  investigations,  court  cases  and  administrative  fines  against  demonstrators  on 
charges  of  terrorism-related  activities  or  on  violating  the  law  on  demonstrations  and  marches. 
There is need for urgent application of ECtHR case-law and revision of relevant national laws. 

The Council of Europe Venice Commission’s July 2021 on the compatibility with international 
human rights standards of the law on the prevention of financing of the proliferation of weapons 
of mass destruction found several provisions that threaten freedom of association in Türkiye. In 
October 2021, the Ministry of Interior issued a circular amending the regulation on associations, 
which  requires  NGOs  to  be  audited  based  on  a  risk  analysis  carried  out  by  the  ministry.  The 
regulation was  appealed by the Human Rights Association. In addition to the profiling motive, 
civil society representatives emphasised that such arrangements should not be made by circular, 
but  should only be introduced by  a law.  In March 2022, the Ministry of Interior sent  letters to 
most independent human rights NGOs with reference to the Financial Action Task Force (FATF) 
recommendations.  The  wording  of  the  letters  suggest  that  these  NGOs  have  already  been 
categorised  as  medium  to  high-risk  groups without  their knowledge. This  could  lead to  further 
criminalisation  of  civil  society  actors.  Furthermore,  there  is  no  legislation  that  determines  the 
scope and limits of such risk analysis, nor is there a procedure governing NGOs' right to object. 
Many  human  rights  NGOs  faced  audits,  including  those  receiving  international  funds.  The 
Venice  Commission’s  recommendations  regarding  freedom  of  association  issued  in  July  2021 
should be implemented, including with regard to fundraising activities by NGOs.   

in  Istanbul,  International  Women’s  Day,  as  well  as 

Protests  or  demonstrations  on  human  rights,  environmental  rights,  and  political  and  socio-
economic rights were banned in several provinces on most occasions, including demonstrations 
by dismissed civil servants. Many large gatherings were banned, including those held on Peace 
Day 
the  “Armenian  Genocide 
Commemoration  Day”,  which  had  been  allowed  since  2010.  The  law  on  meetings  and 
demonstrations allows the administration to prohibit meetings and demonstrations on the basis of 
vague, discretionary and arbitrary criteria. All activities and parades to mark Pride month were 
banned in 2022, as was the case in 2021. The 9th Boğaziçi University Pride in Istanbul and the 
Middle  Eastern  Technical  University  (METU)  Pride  were  also  banned  in  June.  The  police 
intervened and detained hundreds of people who gathered for the Istanbul Pride March in June. 
The number of detainees exceeded the number of people detained at all previous Istanbul Prides 
combined.  

There are two ongoing court cases against Boğaziçi University students and alumni, because of 
their participation in protests against the appointment of a rector by the President. Students were 
often  subjected  to  violence  by  police  and  private  security  officers  and  were  detained  several 
times throughout the year.  

Regarding freedom of association, many human rights defenders were detained or arrested and 
NGOs,  especially  in  the  south-east,  were  subjected  to  police  raids,  including  prominent  NGOs 

39 

 
 
such as the Human Rights Association. The court case against 46 human rights defenders and the 
relatives of victims  of enforced disappearances  who are part of the Saturday Mothers  group in 
Istanbul continued.  

The  Constitutional  Court  revoked  the  State  Supervisory  Council’s  (DDK)  power  to  suspend 
association  executives,  which  had  been  adopted  by  a  presidential  decree.  Despite  this  positive 
decision,  the  DDK  continued  to  propose  the  removal  of  executives  from  associations.  The 
appeals launched by the Human Rights Association against the October 2018 regulation,  which 
requested associations to disclose the identity of all their members to the authorities, led to the 
regulation’s annulment by the Council of State in September 2021. However, following a change 
of legislation, the practice of requesting information on the identity of members continued.  

Regarding  political  associations,  the  request  for  establishment  of  the  Green  Party  has  been 
pending before the Administrative Court since 2020. The Court of Appeals sent back the case to 
the local court by accepting the Party’s appeal in October 2021. The file for the establishment of 
the Humanity and Freedom Party is now pending before the Constitutional Court four years after 
the completion of the legal process.  

Issues of labour and trade union rights are further covered in Chapter 19 - Social policy and 
employment. 

On  property  rights,  the  Inquiry  Commission  on  the  State  of  Emergency  Measures  does  not 
provide an effective domestic remedy for confiscations. The Istanbul Metropolitan Municipality 
launched  a  court  case  against  the  Directorate-General  for  Foundations  (DGF)  which  took  over 
the ownership of the Taksim Gezi Park in March 2021.  

The  Constitutional  Court  ruled  on  a  violation  of  the  property  rights  of  the  Kartal  Surp  Nişan 
Armenian  Church  following  expropriation  by  the  Kartal  Municipality.  In  the  south-east,  the 
restoration  of  cultural  and  religious  heritage  and  urban  housing  construction  continued.  Court 
cases regarding the 2016 expropriations in Sur remained ongoing. The restorations of Chaldean 
Catholic  Church  and  the  Armenian  Surp  Giragos  Church  with  state  funding  were  completed. 
Regarding the implementation of the law on foundations of minority communities, most of the 
appeals for the restitution of property remained pending. The case of the Mor Gabriel Monastery 
Syriac Orthodox Church Foundation’s forestry lands remained pending before the ECtHR Grand 
Chamber.  Other  cases  in  relation  to  the  ownership  of  the  land  of  the  Mor  Gabriel  Monastery 
were ongoing.  

Other non-Muslim community foundations also have properties that have not yet been returned. 
The  Council  of  Europe  Resolution  1625  (2008)  regarding  property  rights  on  the  islands  of 
Gökçeada  (Imbros)  and  Bozcaada  (Tenedos)  still  needs  to  be  fully  implemented.  There  is  an 
urgent  need  to  revise  the  relevant  legislation  on  the  issue  of  property  rights  for  non-Muslim 
minorities  and  other  legislation  covering  all  issues  of  property  rights  to  ensure  a  more 
comprehensive framework. 

Legislation on  non-discrimination is  still not  in  line with  European standards and is  not  fully 
enforced in practice. Serious concerns on the implementation of the April 2021 law on security 
investigations  and  archive  checks  continued.  Dismissals  of  civil  servants  with  no  objective 
criteria continued. Reports on profiling and discrimination against civil servants in employment 
on  vague  legal  grounds  continued.  There  have  been  many  reports  of  discrimination  and  hate 
crimes  based  on  ethnic,  religious  and  gender  identities,  including  on  sexual  orientation.  The 

40 

 
 
HREI, which is in charge of applying non-discrimination legislation, only finalised 62 decisions 
in  2021  while  it  received  180  new  applications.  School  textbooks  still  need  to  be  revised, 
especially  regarding  some  content  on  minorities,  secularism,  religion  and  gender  equality. 
Türkiye should urgently adopt a law on combating discrimination in line with the EU acquis as 
well  as  the  ECHR,  covering  grounds  of  sexual  orientation  and  gender  identity.  No  steps  were 
taken  to  ratify  Protocol  12  of  the  Convention,  which  provides  for  the  general  prohibition  of 
discrimination,  or  to  implement  the  recommendations  of  the  Council  of  Europe  against  racism 
and intolerance. Legislation to combat hate crime, including hate speech, is still not in line with 
international  standards  and  it  does  not  cover  hate  offences  on  the  basis  of  sexual  orientation, 
ethnicity, age or gender identity. No progress was made towards the ratification of the Additional 
Protocol to the Convention on Cybercrime concerning the criminalisation of acts of a racist and 
xenophobic nature committed through computer systems. 

The  backsliding  in  the  area  of  gender  equality  and  the  regression  in  relation  to  the  rights  of 
women and girls continued. Court cases related to the annulment of the presidential decision of 
March 2021 to withdraw from the Council of Europe Convention on preventing and combating 
violence against women and domestic violence (‘the Istanbul Convention’) are still pending. The 
Council of State ruled in July that the Presidential decree, allowing Türkiye’s withdrawal from 
the Istanbul Convention, was lawful and rejected the cases asking for its reversal and issued the 
opinion  that  the  President  has  the  authority  to  withdraw  from  international  conventions.  The 
Fourth National Action Plan for Combating Violence against Women (2021-2025) continues to 
be  implemented  but  according  to  reports,  339  women  were  killed  in  2021.  Türkiye  lacks  a 
comprehensive  data  collection  system  in  this  area  to  assess  the  scale  and  nature  of  the  issue. 
Evidence-based  policies  and  strategies  would  benefit  from  the  collection  of  data  on  the 
prevalence of violence. The fourth judicial package adopted in July 2021, notably increased the 
penalty for some crimes of violence against women especially when these target the perpetrator’s 
former or current spouse. The lack of a judicial and administrative deterrence policy towards the 
perpetrators  of  crimes  against  women  continued  to  be  a  matter  of  concern.  The  lack  of  a 
committed  approach  from  the  judiciary,  and  the  lack  of  available  support  services,  were 
exacerbated by the negative rhetoric from the authorities. A Constitutional Court judgment from 
April  2022  limits  the  protection  of  women,  as  it  struck  down  protective  and  preventive 
injunctions  on  the  grounds  that  they  limit  the  rights  of  men  to  a  reasoned  decision.  Türkiye 
should improve its implementation of domestic legislation and ensure that the investigation and 
prosecution of domestic violence cases takes place in accordance with best practice. Similarly, it 
must  ensure  that  the  specialised  services  offered  to  survivors  and  witnesses  of  violence  are  in 
line with international standards.  

The  persistent  low  levels  of  participation  by  women  in  decision-making,  politics  and 
employment is also of concern. Increased conservative attitude towards gender ideology/equality 
worsened  the  socio-economic  conditions  of  women.  The  deteriorating  economic  conditions 
resulted in increased female unemployment, poverty and hunger.  

Hate speech against independent women’s organisations increased. Statements by the Ministry of 
Interior  targeting  rights-based  women’s  organisations  and  feminists  for  alleged  terrorist  links 
continued to threaten the existence of such associations. Women’s marches were met with police 
violence and a court case was launched for closure of a prominent women’s platform called ‘We 
Will Stop Femicides Platform’.  

41 

 
 
Efforts are needed to improve the situation of the rights of the child, including in relation to the 
problems  in  the  juvenile  justice  system.  As  of  September  2022,  152  judicial  interview  rooms 
have  been  set  up  in  147  courthouses  and  the  establishment  of  local  branches  of  the  Judicial 
Support  and  Victim  Services  Department  within  courthouses  continued.  However,  problems  in 
the juvenile justice system persist. There is continued concern that juveniles still face arrest and 
detention  on  charges  of  membership  of  terrorist  organisations,  often  for  long  periods  and  not 
always  in  specialised  institutions  for  children.  The  number  of  child  courts  continues  to  be 
insufficient.  Improvement  in  the  non-custodial  measures  for  children  is  urgently  needed. 
Children convicted of crimes have limited access to legal assistance. Refugee children and their 
families  face  specific  challenges  in  accessing  the  national  child  protection  system.  Consistent 
effort is needed to eradicate child labour, especially among refugees. There was limited progress 
during  the  reporting  period  on  identifying  and  responding  to  child  marriage  and  gender-based 
violence  against  children.  Türkiye  should  rapidly  adopt  an  effective  national  action  plan  to 
combat  child,  early  and  forced  marriages  and  raise  awareness  among  girls  about  the  harmful 
impacts  of  child  marriage.  Cases  of  incest  were  reported  by  civil  society  organisations.  The 
schooling  of  the  Roma  children  and  children  from  low  socio-economic  backgrounds  have 
considerably decreased due to the COVID-19 pandemic and economic difficulties. 

Children removed from parental care are primarily placed in residential care in home-like small 
institutions, though foster care and adoption services are steadily expanding. Türkiye has closed 
down  all  large-scale  care  institutions  for  children  and  is  effectively  pursuing  a  de-
institutionalisation strategy.  

Concerning  the  rights  of  persons  with  disabilities,  the  President  announced  Türkiye’s  ‘2030 
barrier-free vision document’ in December 2021. Preparations for a National Action Plan on the 
Rights of Persons with Disabilities, which will be the implementation tool for the “2030 Barrier-
Free Vision Document” for the first 3 years, have started. Türkiye needs to increase its evidence 
base  regarding  the  situation  of  persons  with  disabilities,  through  qualitative  and  quantitative 
work.  The  country  still  lacks  an  independent  implementation  and  monitoring  framework,  as 
required by the UN Convention on the Rights of Persons with Disabilities. The government runs 
128 barrier-free daytime life centres that provide free care and training services to persons with 
disabilities. The inaccessibility of public buildings remains a serious barrier preventing persons 
with disabilities from participating in society and civic life, and benefiting from various public 
services. 

Türkiye needs to  mainstream  disability policies  across thematic policy areas and monitor them 
with effective participation from independent NGOs working in this field. Türkiye also needs to 
adopt  mental  health  legislation  and  establish  an  independent  body  to  monitor  mental  health 
institutions.  Community-based  care  services,  including  foster  care  and  adoption,  need  to  be 
expanded for minors with disabilities who are in need of state protection. Public awareness and 
opportunities to enjoy the right to independent living need to be enhanced.  

Türkiye continued to invest in its national capacity for inclusive education practices for children 
with special needs. Considering the number of education personnel and the population of school 
age, such efforts need to be stepped up. 

The  lack  of  protection  for  the  fundamental  rights  of  lesbian,  gay,  bisexual,  transgender, 
intersex  and  queer  (LGBTIQ)  persons  continued  to  raise  serious  concerns.  The  current 
legislation  does  not  cover  hate  speech  and  hate  crimes  based  on  sexual  orientation  or  gender 

42 

 
 
identity.  Hate  speech  and  smear  campaigns  by  elected  or  appointed  state  officials  and  media 
against the LGBTIQ community increased. Discrimination, intimidation and violence against the 
LGBTIQ  community  continued.  Hate  speech  and  crimes  against  LGBTIQ  persons  were  not 
effectively prosecuted. A number of court cases, focusing on cases where LGBTIQ persons were 
murdered are still pending. There was a worrying increase in attacks against LGBTIQ persons. 
Access to gender reassignment surgery and to health and social services remain problematic for 
trans persons. LGBTIQ prisoners reportedly suffer from discrimination and solitary confinement. 
LGBTIQ  activities  and  pride  parades  were  banned  or  prevented  by  the  police  in  several 
provinces.  

The Constitutional Court ruled that a local court’s rejection of a transwoman’s request to change 
her  name  violated  her  right  to  private  life.  The  court  case  against  Middle  East  Technical 
University (METU) students who took part in a pride gathering on the university campus in May 
2019 ended in the acquittal of all defendants in October 2021. The case is now pending before 
the Regional Court of Appeals. The court case against the LGBTIQ Assemblies that joined the 
2021  İstanbul  Pride  March  ended  in  the  acquittal  of  all  eight  activists  in  February  2022.  The 
court  case  against  the  Ankara  Bar  Association,  for  criticising  the  Diyanet’s  President’s 
homophobic speech, continues.  

On procedural rights, the legislation is not in line with the EU  acquis or European standards. 
ECtHR judgments condemning Türkiye for violating the right to a fair trial and presumption of 
innocence due to its failure to respect procedural rules continued to be handed down. In addition, 
convicted children have limited access to legal assistance, which is not in line with EU standards 
on providing procedural safeguards for children in criminal proceedings. The implementation of 
a 2018 law amending several  provisions which restrict fundamental  freedoms,  including in  the 
Code  on  Criminal  Procedures  and  anti-terror  law,  was  extended  until  July  2024.  However,  the 
extension of the maximum pre-trial detention period for up to 12 days in certain terrorism-related 
investigations, which was in contradiction with the ECtHR standard stipulating a maximum of 4 
days  ended  on  31  July  2022.  As  of  that  date,  pre-trial  detention  periods  cannot  exceed  a 
maximum  of  4  days.  Lawyers,  especially  those  providing  legal  assistance  to  Human  Rights 
Defenders  and  civil  and  political  activists,  faced  considerable  obstacles  in  carrying  out  their 
work,  including  pressure  and  external  interferences.  In  some  cases,  they  were  subjected  to  ill-
treatment by the law enforcement personnel. Such interferences include the refusal of admissions 
to the profession of lawyer for those who were dismissed by a state of emergency decree, with a 
few  exceptions  following  the  July  2020  judgement  of  the  Constitutional  Court  that  this  was  a 
violation of their right to exercise their profession.  

The  Ministry  of  Justice,  Bar  Associations  and  civil  society  organisations  provided  information 
on legal matters and on relevant procedures to the public. However, public awareness of legal aid 
in rural areas and among disadvantaged groups remained limited aggravated by the low literacy 
rates.  

The Action Plan on Human Rights covers comprehensive activities regarding victim rights and 
various  trainings  and  seminars  have  been  provided  with  the  cooperation  of  the  Department  of 
Victims'  Rights  and  UNICEF  for  judges,  public  prosecutors,  social  workers  and  judicial 
interview room coordinators. 

Hate  speech  and  hate  crime  remain  a  serious  issue  for  minorities.  Acts  of  vandalism  and 
destruction  to  minority  worship  places  and  cemeteries  need  to  be  investigated  and  prosecuted 

43 

 
 
effectively. No steps were taken to revise school textbooks to delete remnants of discriminatory 
references. Minorities continued to face difficulties, such as the lack of legal status for religious 
institutions,  the  absence  of  protection  for  languages,  schooling  support,  clergy  training, 
dwindling  media  in  minority  languages  and  complications  in  enjoying  property  rights  for 
foundations.  The  lack  of  legal  personality  for  minority  communities’  churches,  synagogues, 
patriarchates, monasteries, and chief rabbinates is an impediment to their freedom of association 
and religion and to their property rights. Minority schools receive no public funds. Subsidies to 
the newspapers run by members of the Armenian, Greek, Jewish and Syriac communities need to 
be  granted by the Press  Advertising  Authority.  The Constitutional  Court judgement  preventing 
state  intervention  to  Patriarchal  elections  has  not  been  implemented.  The  court  case  against 
public  officials  involved  in  the  killing  of  Armenian  journalist  Hrant  Dink  in  2007  is  pending 
before the Court of Cassation. The “Armenian Genocide Commemoration Day” was banned by 
the 
the 
killing/disappearance of the Chaldean Catholic couple in Şırnak in 2020. The restoration studies 
continue  on  the  Büyükada  (Prinkipo  Island)  Greek  Orphanage,  a  cultural  heritage  monument. 
Full respect for and protection of language, religion, culture, cultural heritage and fundamental 
rights of minorities in accordance with European standards have yet to be achieved. Mechanisms 
should be in place to support participation by minorities in decision making and ensure they are 
represented in the public administration. As the Venice Commission underlined in 2010, Türkiye 
should continue the reform process and introduce legislation to eliminate all obstacles faced by 
non-Muslim  religious  communities  to  exercising  all  their  rights  and  to  acquiring  legal 
personality. 

In  April  2022,  a  court  case  began 

Istanbul  governorate. 

relation 

in 

to 

Concerning  Roma  people,  Türkiye  needs  to  adopt  a  new  national  strategy  and  an  action  plan 
covering 2022 onwards, in line with the EU Roma Strategic Framework and in order to enhance 
equality  and  participation  of  Roma  citizens.  Roma  inclusion  needs  to  be  mainstreamed  across 
different  thematic  policy  areas.  The  mandate  and  coordination  capacity  of  the  office  of  the 
National  Roma  Contact  Point  needs  to  be  enhanced  or  re-defined  for  that  purpose.  Structural 
problems of the Roma and deterioration in living conditions (due to the increase of the cost of 
living), were exacerbated by the COVID-19 pandemic, especially for those in the east and south-
east  of  Türkiye.  In  the  post  COVID-19  period,  substance  addiction  has  reportedly  become 
widespread in Roma populated districts, affecting children. There is need for a holistic approach 
to  address  the  problem  of  drug  addiction,  notably  taking  the  social  and  economic  factors  into 
account. The inclusion of Roma children into the education system needs to be strengthened, to 
eliminate  child  labour  and  the  practice  of  early  marriages.  School  attendance  rates  in  pre-
primary,  secondary  and  tertiary  education  levels  are  particularly  low.  Abuses  of  the  private 
rehabilitation  subsidy  system  have  continued  with  a  widespread  practice  of  authorising  fake 
disability  reports  for  children  of  low-income  families.  Independent  Roma  NGOs  should  be 
involved  in  all  stages  of  policymaking,  and  in  the  planning,  implementation,  follow 
up/monitoring  of  the  Roma  strategy.  Most  Roma  people  work  in  undeclared,  precarious  jobs, 
with  limited  access  to  social  security  system.  More  structured  efforts  are  necessary  to  fight 
discrimination in the labour market,  and to promote access to the social security system. Since 
summer 2021, various governorates introduced bans on informal waste collectors, most of whom 
are  of  Roma  origin,  which  has  further  deprived  families  of  subsistence  income.  Overall,  the 
housing  situation  has  not  improved,  and  sudden  hikes  in  housing  prices  particularly  impact  on 
vulnerable  Roma  families.  Policy  measures  are  needed  to  combat  prejudice  and  hate  speech 
against  Roma.  The  HREI  and  the  Ombudsman  need  to  step  up  their  efforts  and  build  their 

44 

 
 
capacity in this field. No EU-Türkiye Joint Roma Seminar has been held so far. 

On cultural rights, there were no development on the legislation to allow public services to be 
provided  in  languages  other  than  Turkish.  Legal  restrictions  on  mother-tongue  education  in 
primary  and  secondary  schools  remained  in  place.  Optional  courses  in  Kurdish  and  Circassian 
are provided in public state schools but the requirement of a minimum of 10 students for these 
courses is an impediment. There are university programmes in Kurdish, Arabic, Syriac, Zaza and 
Circassian.  The  limited  or  lack  of  appointment  of  teachers  remains  a  limiting  factor.  The 
increased powers of the governors and arbitrary censorship continued to have a negative impact 
on  arts  and  culture,  which  was  already  negatively  impacted  by  the  COVID-19  pandemic.  The 
past efforts of elected municipalities to promote the creation of language and culture institutions 
in  these  provinces  remained  closed.  Kurdish  cultural  and  language  institutions,  Kurdish  media 
outlets and numerous art spaces remained mostly closed, as they have been since the 2016 coup 
attempt,  which  contributed  to  a  further  shrinking  of  cultural  rights.  (See  also  Chapter  26  - 
Education and culture). 

2.2.2.  Chapter 24: Justice, freedom and security 

The  EU  has  common  rules  for  border  control,  visas,  residence  and  work  permits,  external 
migration and asylum. Schengen cooperation entails the lifting of border controls inside the EU. 
Member States also cooperate with Türkiye in the fight against organised crime and terrorism, 
and  on  judicial,  police  and  customs  matters  all  with  the  support  of  the  EU  justice  and  home 
affairs agencies. 

Türkiye  is  moderately  prepared  in  the  area  of  justice,  freedom  and  security.  Some  progress 
was made in relation to the further strengthening surveillance and protection capacity of the land 
border with Iran. The return of irregular migrants from the Greek islands under the EU-Turkey 
Statement remained suspended since March 2020. Although the number of irregular arrivals to 
Greece  has  decreased  compared  to  pre-COVID  figures,  irregular  arrivals  to  Italy  and  to  the 
government-controlled areas of Cyprus have increased in the past year and new smuggling routes 
have been established. Türkiye has still not implemented the provisions relating to third-country 
nationals in the EU-Türkiye readmission agreement, which entered into force in October 2017. 
Türkiye continued to make significant efforts to host and meet the needs of almost four million 
refugees. Türkiye still needs to align its legislation on data protection with European standards. 
Most of the recommendations of last  year were not addressed and remain valid. In the coming 
year, Türkiye should in particular: 

  fully implement the EU-Turkey Statement of March 2016, notably the returns from Greece 
and the prevention of irregular routes to all Member States and implement all the provisions 
of the EU-Türkiye readmission agreement towards all EU Member States; 

  align  legislation  on  personal  data  protection  with  European  standards,  to  allow  for  the 
conclusion  of  an  international  agreement  between  the  EU  and  Türkiye  on  the  exchange  of 
personal data between Europol and Türkiye; 

  revise legislation and practices on terrorism in line with the European Convention on Human 
Rights,  European  Court  of  Human  Rights  case-law  and  the  EU  acquis  and  practices.  The 
proportionality principle should be observed in practice; 

  adopt  and  implement  a  strategy  and  action  plan  on  border  management  with  the  aim  to 

enhance coordination between border services at national and international levels. 

45 

 
 
Fight against organised crime 

Türkiye has some level of preparation in the fight against organised crime, however there was 
limited  progress  overall.  The  majority  of  the  recommendations  from  last  year  remain  to  be 
addressed: 

In the coming year, Türkiye should in particular: 

  collect  and  use  aggregate  statistics  to  facilitate  threat  assessment,  policy  development  and 
implementation  and  improve  Türkiye’s  track  record  on  dismantling  criminal  networks  and 
confiscating criminal assets; 

  improve the legal framework and practices on counter-terrorism in line with the EU acquis. 
Türkiye also needs to continue addressing outstanding recommendations to be delisted from 
the FATF's ‘grey’-list; 

  demonstrate the establishment of a fully operational centralised bank account register (BAR) 

in line with Article 32 A of the Anti-Money Laundering Directive;  

  improve its legislation on cybercrime and witness protection; 

  establish an Asset Recovery Office in line with the EU acquis; 

  conclude an international agreement on cooperation with Eurojust.  

  enhance  efforts  to  prevent  trafficking  in  human  beings,  specifically  targeting  vulnerable 
groups;  improve  early  identification  of,  support  and  assistance  to  victims  of  trafficking,  in 
particular  those  of  vulnerable  communities;  increase  the  capacity  of  shelters  available  for 
victims  of  trafficking;  expand  training  for  professionals  likely  to  enter  into  contact  with 
victims of trafficking.  

Institutional set-up and legal alignment 

There are a number of specialised departments dealing with various forms of organised crime, 
and  two  main  law  enforcement  agencies,  namely  the  Gendarmerie  and  the  Turkish  National 
Police  (TNP)  attached  to  the  Ministry  of  Interior.  The  Coast  Guard  Command  is  also  an 
important force in preventing migrant smuggling and trafficking in human beings. The Turkish 
financial  intelligence  unit  is  the  Financial  Crimes  Investigation  Board  (MASAK),  which  is 
attached  to  the  Ministry  of  Treasury  and  Finance.  Cybercrime  is  dealt  with  by  a  specialised 
Department  of  Combating  Cybercrime  affiliated  to  the  Turkish  National  Police  as  well  as  the 
Public  Order  Division  of  the  gendarmerie  at  central  level  and  the  30  provincial  gendarmerie 
branches. Türkiye has a witness protection system in place, providing guarantees to protect the 
witnesses from intimidation and threat.  

Operational capacity continued to be strengthened through new recruitments and trainings. . The 
police  in  Türkiye  have  a  total  of  316  509  officers,  equivalent  to  466  officers  per  100  000 
inhabitants,  compared  with  an  EU  average  of  333  (Eurostat,  2018-2020).  The  total  number  of 
staff  of  the  gendarmerie,  excluding  conscripts,  is  167  957,  equivalent  to  737  gendarmerie 
personnel  per  100,000  inhabitants.  Between  April  2021  and  April  2022,  3  055  personnel  were 
dismissed.  These  figures  include  the  personnel  dismissed  due  to  their  affiliation  to  the  Gülen 
movement and PDY.  

46 

 
 
The  legal  framework  for  the  fight  against  organised  crime  and  police  cooperation  is  partially 
aligned with the EU acquis. The legal framework regulating the fight against money laundering 
and terrorist financing needs to be improved in line with the recommendations by the Financial 
Action  Task  Force  (FATF)  and  those  by  the  Venice  Commission  on  the  law  on  preventing 
financing  of  proliferation  of  weapons  of  mass  destruction.  The  scope  of  the  law  on  witness 
protection needs to be expanded to include all types of serious crimes and procedural rules also 
need improvement. The completion of an international agreement between the EU and Türkiye 
on the exchange of personal data between Europol and the Turkish authorities with responsibility 
for fighting serious crime and terrorism is still pending as the Turkish data protection legislation 
is  still  not  in  line  with  the  EU  acquis.  While  Türkiye  is  party  to  the  Council  of  Europe 
‘Budapest’  Convention  on  cybercrime,  it  has  yet  to  sign  its  Second  Additional  Protocol  on 
enhanced cooperation and disclosure of electronic evidence, which was opened for signature in 
May 2022. In relation to the negotiations for a United Nations convention on cybercrime based 
on resolution 74/247 of the United Nations, Türkiye’s voting position did not always align with 
the position taken by the EU and its Member States (swing voting pattern). 

The  implementation  of  activities  outlined  in  the  2019-2021Action  Plan  in  line  with  the  2016-
2021National  Strategy  on  the  Fight  against  Organised  Crime    were  executed  at  a  100 % 
completion rate. The new draft 2022-2027 National Strategy for combating organised crime and 
2022-2024 Action Plan for combating organised crime  are yet to be approved.  

Türkiye’s  Information  and  Communication  Technologies  Authority  of  Türkiye  has  been  a 
member of INHOPE (International Association of Internet Hotlines) since 2011 and cooperates 
with  other  hotlines  to  fight  against  child  sexual  abuse  materials.  MASAK,  is  a  member  of  the 
Egmont  Group  of  Financial  Intelligence  Units,  which  facilitates  cooperation  and  intelligence 
sharing between national financial intelligence units to investigate and prevent money laundering 
and terrorist financing. Türkiye is party to the UN Convention against Transnational Organised 
Crime and the Council of Europe Convention on Laundering, Search, Seizure and Confiscation 
of  the  Proceeds  of  Crime  and  on  the  Financing  of  Terrorism  (CETS  No.  198).  Türkiye  is  a 
member  of  the  Management  Board  of  the  European  Monitoring  Centre  for  Drugs  and  Drug 
Addiction (EMCDDA) and of the Agency’s European Information Network on Drugs and Drug 
Addiction (Reitox). Türkiye is an active member of the Global Coalition against DAESH and co-
chairs the Foreign Terrorist Fighters Working Group. 

Implementation and enforcement capacity 

In  2021,  41  128  cases  of  organised  crime  (Articles  314,  315  and  220  of  the  Turkish  Criminal 
Code) were adjudicated before criminal courts. 17 145 of these cases resulted in convictions with 
21 645 persons being convicted (in 2020, there were 17 305 cases with 21 043 convictions). In 
total, 666 operations have been carried out by the gendarmerie and the Turkish National Police 
(TNP)  to  tackle  organised  crime,  cybercrime,  smuggling  of  migrants  and  trafficking  in  human 
beings. 

In  2021,  20  197  cases  of  cybercrime  (Articles  243/1,  244,  103,  226  of  the  Turkish  Criminal 
Code) were tried before a criminal court. 7 791 cases resulted in the conviction of 7 807 persons. 
Concerning  firearms  trafficking,  5  761  small  and  light  weapons  (SALW)  were  seized  by  the 
Gendarmerie and 3 306 by the TNP during the reporting period. In 2021, 655 cases of firearms 
trafficking (Articles 12 of the Turkish Criminal Code) were brought before a criminal court, 285 
of these were concluded with a conviction involving 480 persons. 

47 

 
 
Türkiye ranks high (12th out of 193 countries) on the Global Organised Crime Index therefore it 
is a country of interest in relation to several priorities of the European multi-disciplinary platform 
against criminal threats (EMPACT), notably firearms and drugs trafficking, trafficking in human 
beings,  migrant  smuggling,  high  risk  criminal  networks,  environmental  crime,  organised 
property  crime,  counterfeiting  and  criminal  finances  as  well  as  money  laundering  and  asset 
recovery. 

Gun  violence  in  Türkiye  surged  in  recent  years,  while  the  overwhelming  majority  of  firearms 
owned  by  individuals  are  unregistered  due  to  lax  enforcement  of  the  law  on  unregistered 
weapons.  

Since July 2004, cooperation between Europol and Türkiye is based on the Strategic Agreement 
on Cooperation. A Turkish Liaison Officer is seconded to Europol since 2016. In Türkiye, 17 EU 
Member States have 30 liaison officers while Türkiye has 8 liaison officers in six EU Member 
States.  A  Cooperation  Agreement  with  the  European  Union  Agency  for  Law  Enforcement 
Training  (CEPOL)  has  been  in  place  since  2010.  Exchange  programmes  and  training 
programmes were carried out involving the Gendarmerie and the TNP. As well as participating 
in the courses held by EU Member States, TNP also organises joint workshops and study visits 
with CEPOL. 

Türkiye  continues  to  be  an  important  transit  and  destination  country  for  trafficking  in  human 
beings. By the end of 2021, the number of victims identified by Turkish authorities stood at 403 
representing an increase compared to 2020 when the number of victims identified was 282. By 
April  2022,  147  victims  of  trafficking  in  human  beings  have  been  identified.  The  main 
trafficking purpose is sexual exploitation followed by labour exploitation. In 2021, 81 cases of 
trafficking  in  human  beings  (Article  80  of  the  Turkish  Criminal  Code)  were  brought  before 
Türkiye’s  criminal  courts.  23  cases  ended  with  convictions.  68  people  accused  of  trafficking 
were convicted by the criminal courts of first instance. 

There  are  two  shelters  in  the  Ankara  and  Kirikkale  provinces  run  by  the  Presidency  for 
Migration Management (PMM). Their capacity to host victims of human trafficking fell from 90 
to  42 persons.  There is  an urgent  need to  increase the  capacity to  host  and provide services to 
victims of human trafficking. Türkiye worked with the Council of Europe (CoE) to improve its 
ability  to  prevent  and  fight  against  trafficking  in  human  beings  by  implementing  the  relevant 
CoE Convention. As part of this initiative funded by the EU, Türkiye provided training on anti-
trafficking  to  law  enforcements  agencies,  prosecutors  and  judges  and  supported  awareness-
raising activities by municipalities on the risk and crime of trafficking. 

The  large  number  of  Syrians  and  other  refugees,  including  children,  are  vulnerable  to  being 
exploited  as  forced  labour.  Reports  of  early  marriages  as  young  as  12  years  old,  making  girls 
vulnerable to domestic servitude and sex trafficking increased in the wake of the pandemic as an 
economic coping mechanism. 

Türkiye  needs  to  expand  and  institutionalise  the  training  of  law  enforcements  agencies, 
prosecutors and judges on taking a victim-centred approach, increase victim identification among 
the  vulnerable  population  of  refugees  and  asylum  seekers  in  particular.  Partnership  with  civil 
society  should  be  sought  to  encourage  the  identification  of  and  provide  shelter  and  services  to 
victims of trafficking. The reasons leading to lack of prosecution of the crime of trafficking in 
human  beings  should  be  identified  and  measures  taken  to  ensure  that  victims  are  allowed  to 
appear in  court via video link, when the circumstances of the  case  and the vulnerability of the 

48 

 
 
persons concerned require so. A new action plan on trafficking in human beings requested by the 
Group of Experts on Action against Trafficking  in  Human Beings (GRETA) of the Council of 
Europe is outstanding. 

Cooperation in the field of drugs 

Institutional set-up and legal alignment 

Türkiye’s institutional set up remains the same. Coordination and monitoring at national level is 
the  responsibility  of  the  High  Council  for  the  Fight  against  Drugs.  The  National  Strategy  and 
Action  Plan  to  combat  illegal  drugs  covering  2018-2023  is  in  place  and  the  civil  society  is 
closely involved in the implementation thereof. All ministers involved in the implementation of 
the  Strategy  and  Action  Plan  are  members  of  the  High  Council.  The  research  committee 
conducts  research  on  drug  addiction  and  a  scientific  committee  provides  recommendations  for 
studies and training on drug abuse. While Türkiye addressed the issues of drug supply and drug 
demand  reduction,  it  does  not  support  harm  reduction  interventions,  contrary  to  the  EU  drugs 
policy.  

The  Turkish  Monitoring  Centre  for  Drugs  and  Drug  Addiction  (TUBİM)  is  the  national  focal 
point  to  the  European  Monitoring  Centre  for  Drugs  and  Drug  Addiction  (EMCDDA).  Türkiye 
has a participation agreement in place with the EMCDDA since 2007. It has a monitoring role at 
national  and  international  level  and  is  drafting  the  annual  Turkish  drug  report.  It  collects  data, 
makes  risk  assessment,  and  provides  recommendations  with  regard  to  the  National  Early 
Warning System on new psychoactive substances. A total  of 991 new psychoactive substances 
have been included in the national legislation, 53 of which were put on the list in 2021, and an 
additional 20 in  the first quarter of 2022.  The instant data flow system,  which uses  encryption 
and anonymisation of personal data for monitoring and reporting, is operational. The responsible 
body for controlling drug precursors is the Turkish Medicine and Medical Devices Agency of the 
Ministry  of  Health,  which  gives  the  licences  and  permissions  for  manufactures,  possession, 
selling, purchase, transportation, usage, consumption, distribution, importation, exportation, and 
legal use including for pharmaceutical and industrial purposes. 

Implementation and enforcement capacity 

Türkiye  remains  a  transit  route  for  drugs  between  Asia  and  Europe.  In  2021,  Turkish  law 
enforcement services conducted operations that resulted in the seizure of, inter alia, 64 125 kg of 
cannabis including skunk (in 2020: 93 741 kg), 2 841 kg of cocaine (in 2020: 1 961 kg), 22 202 
kg of heroin (in 2020: 13 783 kg), 5 528 kg of methamphetamine (in 2020: 4 162 kg), 7 618 013 
ecstasy tablets (in 2020: 11 096 244) and 13 790 648 captagon tablets (in 2020: 2 875 183).  

In 2021, a total of 64 073 cases in relation to Article 188/3 of the Turkish Criminal Code (54 325 
in 2020) involving 85 036 suspects (75 907 in 2020) were launched by the prosecution for illicit 
drug  related  offences  with  24  990  suspects  (18  478  in  2020)  being  convicted.  In  the  field  of 
prevention, the Ministry  of Health (MoH) operates 207 counselling centres in  81 provinces.  In 
2021, 7 new Centres became operational. The anti-drug counselling hotline received 71 326 calls 
in 2021. 

There are 137 treatment centres for drug dependence in 81 provinces, 58 of the centres focus on 
inpatient treatment, and 11 of those are dedicated specifically to treating children. The remaining 
79  centres  are  outpatient  centres  with  9  serving  children  exclusively.  The  waiting  time  for 
applicants to be admitted to the treatment centres is currently 1-3 days. 

49 

 
 
Fight against terrorism 

Türkiye carried on with efforts to tackle terrorism leading to a reduction in terrorist activities and 
an  improved  security  situation.  The  country  continued  to  face  threats  from  various  terrorist 
groups. The EU has condemned all acts of terrorist violence perpetrated in Türkiye. Türkiye has 
prioritised  the  fight  against  the  PKK  and  the  dismantling  of  the  Gülen  movement.  The  PKK 
remains on the EU’s list of persons, groups and entities involved in acts of terrorism. Türkiye has 
a legitimate right to fight terrorism. However, counter-terrorism efforts should be in line with the 
rule  of  law  and  fundamental  rights  and  freedoms  and  must  not  be  used  to  silence  political 
opposition  and  dissent.  Changing  the  Turkish  anti-terrorism  legislation  and  practices  to  bring 
these into line with EU standards remains an essential reform outstanding. 

Institutional set-up and legal alignment 

The institutional set up remains the same; a specialised police unit in the General Directorate of 
Security of the Ministry of Interior holds the responsibility for countering terrorism. Institutional 
capabilities  are  well-developed.  Terrorism  and  terrorism  financing  are  high  priority  crimes  for 
the National Security Council which meets regularly bimonthly. 

Türkiye has been included in the list of jurisdictions under increased monitoring (‘grey list’) by 
the Financial Action Task Force (FATF) in October 2021. Following this decision, Türkiye was 
not  added  to  the  EU’s  list  of  high-risk  third  countries  due  to  its  candidate  status,  high-level 
political commitment to the EU to address outstanding shortcomings identified by the FATF and 
move towards full alignment with the EU acquis. The way Türkiye responds to the concerns of 
the  EU  and  the  FATF  is  being  closely  monitored  in  the  framework  of  the  Association 
Agreement.  The  country  needs  to  continue  addressing  outstanding  recommendations  to  be 
delisted from the FATF's grey list. Failure to make progress on complying with the outstanding 
FATF recommendations would put Türkiye at risk of being included on the EU list of high-risk 
third countries presenting strategic deficiencies in their AML/CFT regimes. 

The  law  on  the  prevention  of  financing  of  the  proliferation  of  weapons  of  mass  destruction 
adopted  in  December  2020  continues  to  raise  concerns  despite  the  amendments  made  to  the 
regulation of associations in September 2021, aiming at carrying out a risk-based, proportionate 
approach  to  auditing  NGOs.  Pressure  further  increased  on  non-partisan  civil  society 
organisations,  notably  in  the  form  of  arbitrary  and  repeated  audits.  It  is  paramount  that  any 
measures  taken  to  counter  terrorism  are  in  line  with  Türkiye’s  obligations  under  international 
law, and in particular international human rights law.  

Implementation and enforcement capacity 

In July 2021, Türkiye announced an over-arching National Strategy for Increasing Effectiveness 
in Anti-Money Laundering and Countering Financing of Terrorism and Confiscation Practices in 
Türkiye  (2021-2025).  The  strategy  inter  alia  aims  to  address  the  outstanding  FATF 
recommendations.  MASAK  continued  to  develop  its  institutional  capacity  and  developed  a 
sound track-record during the reporting period. The number of suspicious transaction reports and 
number  of  files  that  were  analysed  by  MASAK  have  increased  substantially  in  recent  years 
reaching 515 627 in 2022 (250 597 in 2020). Systematic inter-agency cooperation between the 
law  enforcement  agencies,  prosecution  and  MASAK  has  improved.  Consequently,  money 
laundering prosecutions showed a significant increase in recent years. 

50 

 
 
The government continued to freeze the assets of persons and entities designated by the United 
Nations  Security  Council  Sanctions  Committee  in  less  than  a  day.  The  domestic  assets  freeze 
instrument  has  also  been  implemented  in  a  dissuasive  fashion.  In  2021,  1 155  persons,  16 
associations, and legal entity’s assets were frozen through the domestic freeze mechanism. 

Police and judicial cooperation with EU Member States and EU agencies in combating terrorism 
remained  limited  due  to  the  absence  of  a  personal  data  protection  law  in  line  with  European 
standards and the EU  acquis, and differences over the definition of, and  penalties for, terrorist 
offences.  Türkiye  should  continue  its  efforts  to  effectively  prevent  and  counter  radicalisation 
leading to violent extremism and terrorism, in full compliance with fundamental rights.  

Judicial cooperation in civil and criminal matters 

Judicial  cooperation  in  civil  and  commercial  matters  is  regulated  by  the  Law  on  International 
Civil  Law  and  Procedural  Law,  circulars,  and  international  conventions.  Türkiye  is  a  party  to 
most  of  the  international  conventions.  Türkiye  still  needs  to  accede  to  relevant  international 
conventions in the area of civil justice, many of which were drawn by the Hague Conference on 
Private  International  Law,  including  in  particular  the  Hague  Convention  of  30  June  2005  on 
Choice  of  Court  Agreements.  Türkiye  has  not  yet  ratified  the  European  Convention  on  the 
Compensation  of  Victims.  In  2021,  within  the  scope  of  the  Convention  on  Civil  Procedure, 
eleven judicial legal assistance requests were made by EU Member States and 210 by Türkiye. 
Within the scope of the Convention on the Taking of Evidence Abroad in Civil or Commercial 
Matters, 120 judicial  legal  assistance requests were made by  EU Member States and 1 816 by 
Türkiye. 

The main legislation governing judicial cooperation in criminal matters has been in place since 
2016 and Türkiye has acceded to  most of the international  conventions.  The legislation entails 
new  mechanisms  to  speed  up  international  judicial  cooperation  in  criminal  matters,  which  has 
started to yield positive results. Following the introduction of video conferencing, the necessary 
infrastructure  is  in  place  to  enable  statements  to  be  taken  via  video  conference  for  legal 
assistance  requests.  Under  the  new  ‘consensual  extradition’  procedure,  the  extradition  of  an 
offender now takes 1-2 months on average as opposed to the classic extradition procedure which 
lasted  around  a  year.  With  regard  to  the  transfer  of  sentenced  persons,  the  introduction  of  the 
‘exact  execution’  procedure  paved  the  way  to  the  removal  of  the  obligation  for  local  courts  to 
comply  with  the  domestic  legislation.  In  2021,  under  the  new  procedure,  22  convicts  were 
transferred  to  Türkiye  from  other  countries,  while  1  convict  was  transferred  from  Türkiye  to 
another country. However, the independence and accountability of the justice system needs to be 
substantially  strengthened  for  the  smooth  application  of  the  principle  of  mutual  recognition  of 
judgements and court decisions in criminal matters. 

During 2021, trainings on international legal assistance were provided to 1 126 candidate judges 
and prosecutors. 

In  2021,  EU  Member  States  accepted  six  extradition  requests  from  Türkiye,  while  37  were 
rejected  and  133  are  pending.  There  were  nine  extradition  requests  from  EU  Member  States, 
which  are  all  pending.  EU  Member  States  accepted  eight  transfers  of  convicts  to  Türkiye  and 
Türkiye accepted five transfers to EU Member States. Five contact points have been designated 
by Türkiye to coordinate and follow-up judicial cooperation with Eurojust. Türkiye attended an 
online coordination meeting with Eurojust. In 2021, Türkiye was involved in 15 Eurojust cases 
on terrorism, cybercrime, migrant smuggling, illegal drug trafficking and fraud, compared to 20 

51 

 
 
cases  in  2020.  However,  the  personal  data  protection  law  is  not  yet  in  line  with  European 
standards, which prevents the start of negotiations for an agreement with the EU on cooperation 
with  Eurojust.  Cooperative  relations  should  also  be  established  with  the  European  Public 
Prosecutor’s Office (EPPO).  

Legal and irregular migration 

Institutional set-up and legal alignment 

The  former  Directorate-General  for  Migration  Management  has  been  upgraded  and  given  the 
status of Presidency. The entity continues to operate under the Ministry of Interior. The budget 
of the institution increased in  terms of national  currency  by 50 % compared to  2021 (which is 
higher  than  the  30 %  increase  of  the  entire  state  budget).  The  Presidency  of  Migration 
Management  (PMM)  continued  to  employ  a  limited  number  of  psychologists,  social  workers, 
interpreters, and lawyers, some of which are  financed by  the EU. Even though  foreseen in  the 
Law  on  Foreigners  and  International  Protection,  the  PMM  has  not  yet  established  its  overseas 
organisation in Türkiye’s consulates abroad. 

The  implementing  regulation  following  the  amendment  to  the  Law  on  Foreigners  and 
International  Protection  introducing  alternatives  to  detention,  which  entered  into  force  in 
December 2019, still needs to be adopted. 

Türkiye maintained its efforts to improve the operation of the national Assisted Voluntary Return 
mechanism and continued its capacity building  activities targeting the PMM  and Red Crescent 
staff that will be involved in the processing cases eligible for voluntary return. 

Implementation and enforcement capacity 

The  EU-Turkey  Statement  remained  the  main  framework  for  cooperation  between  the  EU  and 
Türkiye and the EU’s engagement with Türkiye on migration intensified. A number of high-level 
contacts,  including  a  high-level  dialogue  on  migration  and  security,  took  place  during  the 
reporting period. Responding also to the EU call, the Turkish Civil Aviation Authority took swift 
measures to curb irregular migration from Iraq to the EU’s eastern borders via Belarus, thereby 
helping tackle organised smuggling of migrants to the EU by Belarus. 

According to the International Organisation for Migration (IOM), 111 migrants lost their lives in 
the Eastern Mediterranean in 2021. In 2022, by 31 July, 64 migrants lost their lives in the Eastern 
Mediterranean. The average number of daily irregular arrivals from Türkiye to  Greece stood at 
20, down from  40 in  2020.  In 2022, by 31 July, the average number of daily irregular arrivals 
from  Türkiye  to  Greece  stood  at  30.  Turkish  irregular  migrants  occupied  the  top  spot  among 
those who arrived to Greece, followed by Afghans and Syrians. In 2021, the number of irregular 
arrivals to Cyprus has reached 11 600 (compared to 5 800 in 2020), most of whom crossed the 
Green  Line  after  having  arrived  from  Türkiye  to  the  non-government  controlled  territories  of 
Cyprus. In 2022, by 31 July, 11 137 arrivals were recorded at the government-controlled area of 
Cyprus.  The  reported  increase  in  crossings  over  the  Green  Line  indicates  the  formation  of  a 
specific  modus  operandi,  in  particular  for  persons  originating  from  African  countries  (Nigeria, 
DR Congo), through the use of ‘student permits’ from so-called ‘universities’ established in the 
occupied  area.  These  persons  pass  into  the  area  under  the  effective  control  of  the  Republic  of 
Cyprus with the help of smuggling networks. 

Concerning Italy, the irregular sea route remained highly active with substantial increase in the 
number of arrivals from Türkiye (from 4 200 in 2020 to 12 900 in 2021; 6 225 arrivals recorded 

52 

 
 
in 2022 as of 31 July). The total number of irregular migrants who arrived from Türkiye to the 
EU  in  2021  stood  at  21 295,  of  which  7 443  to  Greece,  12 916  to  Italy  and  936  to  Bulgaria, 
compared to 18 421 arrivals in the same period in 2020. 

From 1 January until 31 July 2022, 13 163 irregular migrants arrived from Türkiye into the EU, 
representing a 76 % increase compared to the same period in 2021. The sea route to Italy saw a 
significant hike (up by 82 %), while arrivals to Greece increased by 67 %. Similarly, the number 
of arrivals in Cyprus via the Green Line also went up by 144 % between 1 January and 31 July, 
in comparison with the same period in 2021. 

The number of irregular migrants apprehended in Türkiye stood at 162 996 in 2021, compared to 
122 302 in 2020. As in the past  years, irregular migrants from Afghanistan, Syria and Pakistan 
were  the  most  frequently  apprehended  nationalities.  The  Turkish  Coast  Guard  (TCG)  rescued 
23 676 irregular migrants at sea in 2021, up from 20 380 in 2020. The TCG deployed its assets to 
Lake Van in a bid to bolster the authorities’ fight against irregular migration from Iran, following 
the instability in Afghanistan. Turkish officials employed a hostile rhetoric against the European 
Border  and  Coast  Guard  Agency  (Frontex)  and  accused  the  agency  of  alleged  involvement  in 
arrival prevention in the Aegean Sea. 

Turkish authorities apprehended 118 252 irregular migrants in the year up to 16 June, about 16 
700  of  whom  were  intercepted  by  the  TCG.  Nationals  of  Afghanistan,  Syria  and  Pakistan 
continued  to  be  the  top  nationalities.  According  to  the  government,  law  enforcement  forces 
carried  out  7  918  apprehensions  of  human  smugglers  in  2021  reflecting  a  substantial  increase 
when  compared  to  2020  (4 425  apprehensions).  Out  of  these  only  1  946  were  arrested  by  the 
judicial authorities, undermining efforts to fight the crime of migrant smuggling. 

No  progress  was  made  as  regards  the  full  implementation  of  the  EU-Türkiye  Readmission 
Agreement.  Türkiye  maintained  its  position  that  it  would  not  implement  the  provisions 
concerning  third-country  nationals  until  the  visa  requirement  for  its  citizens  travelling  to  the 
Schengen Area is lifted. EU Member States lodged 500 readmission requests concerning Turkish 
nationals; 336 were accepted by Türkiye and 127 were readmitted effectively. 

Return  of  irregular  migrants  from  the  Greek  islands  was  unilaterally  suspended  by  Türkiye  on 
public  health  grounds  in  March  2020  and  remained  so  as  of  June  2022.  The  Commission  and 
Greece  have  repeatedly  called  on  Türkiye  to  resume  return  operations  in  line  with  the 
commitments  made  under  the  EU-Turkey  Statement.  The  resumption  of  returns  to  Türkiye 
remains  key  to  effectively  fighting  irregular  migration  and  migrant  smuggling  networks  in  the 
region. Between 2016 and 2020, 2 140 persons, including 412 Syrian nationals, were readmitted 
to  Türkiye  from  Greece  under  the  ‘One-for-One’  scheme.  The  bilateral  Readmission  Protocol 
between  Greece  and  Türkiye  remained  suspended.  Türkiye  did  not  readmit  third-country 
nationals  from  Bulgaria  under  either  the  bilateral  border  agreement  or  the  EU-Türkiye 
Readmission Agreement. 

As regards resettlement from Türkiye to the EU under the ‘One-for-One’ scheme, 4 225 Syrian 
refugees were resettled to eight EU Member States in 2021. Moreover, the Resettlement Support 
Facility run by the European Union Agency for Asylum in Istanbul facilitated the processing of 
2 557 resettlement candidates. The total number of Syrian refugees resettled from Türkiye to the 
EU Member States under the ‘One-for-One’ scheme reached 35 330 as of 4 September 2022. At 
the  same  time,  503 000  Syrian  refugees  were  voluntarily  repatriated  from  Türkiye  to  Syria 
between  2016  and  2022  according  to  government  data.  Of  these,  approximately  125 000  were 

53 

 
 
monitored by the office of the United Nations High Commissioner for Refugees (UNHCR) with 
respect to the voluntary nature of the repatriations. In June 2022, in the case of Akkad v. Türkiye, 
the ECtHR held that the forced return to Syria of a Syrian national with a valid residence permit, 
under  the  guise  of  a  voluntary  return,  was  in  breach  of  Turkish  law  and  of  the  ECHR.  The 
ECtHR  found  that  there  have  been  violations  of  the  prohibition  of  inhuman  or  degrading 
treatment,  the  right  to  liberty  and  security,  and  the  right  to  an  effective  remedy;  whereby  the 
removal of a valid temporary protection holder to Syria was in  breach of the Convention. The 
Court  noted  the  lack  of  key  procedural  safeguards  in  the  voluntary  return  process,  particularly 
the presence of UNHCR or NGOs mentioned in the law, the right to assistance by a lawyer, and 
the right to be informed about the procedures.      

Türkiye  effectively  returned  46 653  irregular  migrants  to  third  countries  in  2021,  compared  to 
41 379  in  2020.  The  total  number  of  irregular  migrants  returned  since  2018  reached  248 349. 
None of these returns were carried out within the scope of the readmission agreements that are in 
force between Türkiye and third countries. Türkiye did not sign any new readmission agreements 
in the reporting period. 

The possibility of a large number of Afghan nationals arriving in Türkiye following the events in 
Afghanistan in August 2021 led the government to take decisive measures targeted at irregular 
migration  from  Iran.  Türkiye  announced  on  a  number  of  occasions,  including  in  the  United 
Nations General Assembly, that it would no longer admit migrants into its territories. According 
to  the  government,  451 096 irregular migrants  were prevented by Turkish security forces from 
entering Turkish territory at the eastern and southern provinces in 2021. Approximately 120 000 
of these were irregular entry attempts from Iran. In response, rights groups raised concerns about 
alleged  violation  of  the  non-refoulement  principle  and  pushbacks.  Repatriation  operations  to 
Afghanistan from Türkiye resumed in January 2022 after a five-month suspension following the 
Taliban take-over in Kabul. As of 2021, Türkiye was hosting 300 000 Afghan nationals, 120 000 
of whom are estimated to be unregistered, according to the government. The number of Afghan 
irregular migrants apprehended in 2021 stood at 70 000, up from 50 000 in 2020, yet down from 
the  record  201 000  in  2019.  As  of  16  June  2022,  56 813  Afghan  irregular  migrants  have  been 
apprehended in 2022.  

There is  a growing negative perception of migrants in Türkiye and several hate attacks against 
and  fatal  lynching  of  refugees  and  asylum  seekers  were  reported  in  the  media  and  by  NGOs. 
Public discontent regarding the presence of Syrian refugees has become an election issue and a 
matter of constant debate. 

The number of removal centres stands at 30 with a total capacity of 20 000 people. The media, 
civil society and bar associations reported incidents of alleged human rights violations as well as 
pervasive  challenges  relating  to  access  to  rights  and  services  in  the  centres,  particularly  with 
regard to access to information, asylum and legal aid. In 2021 more than 160 000 migrants were 
apprehended, most of whom were subject to return procedures in  removal centres. In the same 
period, only 849 migrants benefited from free legal aid, compared to 945 in 2020. In addition to 
the free legal aid scheme, 16 003 migrants were able to access and meet their lawyers in removal 
centres.  The  lack  of  effective  provision  of  information  in  removal  centres,  in  languages  that 
migrants  understand,  continues  to  serve  as  a  key  barrier  to  accessing  rights  in  detention. 
Compliance with CPT standards should be enhanced, particularly with regard to the presumption 
against detention of families with children as far as possible. 

54 

 
 
The number of foreigners legally residing in Türkiye stood at 1 426 985 in June 2022, compared 
to  886 653  in  2020.  Nationals  of  Iraq,  Turkmenistan  and  Iran  were  the  top  three  nationalities 
among  residence  permit  holders.  In  the  aftermath  of  the  Russian  aggression  against  Ukraine, 
Türkiye increased the minimum amount of immovable property investment required to become 
eligible for Turkish citizenship from USD 250 000 to USD 400 000. In addition, the government 
also enacted a legal amendment allowing foreigners to apply for Turkish citizenship by making a 
contribution  of  at  least  USD  500  000  to  private  pension  funds  specified  by  the  authorities,  on 
condition that the foreigner remains in the pension system for at least three years. Such schemes 
pose risks in relation to  security, money laundering, tax evasion, terrorist financing, corruption 
and  infiltration  by  organised  crime.  As  a  candidate  country,  Türkiye  should  refrain  from  any 
measure that could jeopardise the attainment of the EU’s objectives when using its prerogatives 
to award nationality. 

Asylum 

Institutional set-up and legal alignment 

The  Presidency  of  Migration  Management  (PMM)  is  the  main  institution  responsible  for  all 
asylum-related procedures. The Departments of Temporary Protection, International Protection, 
Country  of  Origin  Information  (CoI)  Research,  Resettlement  and  Voluntary  Repatriation,  and 
Protection  of  Victims  of  Human  Trafficking  have  been  set  up,  under  the  newly  established 
Directorate  General  of  International  Protection.  The  status  determination  processes  are  carried 
out  by  the  provincial  directorates  of  migration  management  (PDMMs)  as  well  as  by  the 
International Protection Bureaus (Decision Centres) in Ankara and Istanbul, established in 2018 
and  2019  respectively,  with  a  view  to  reduce  case  backlog.  Decisions  on  refugee  status 
determination are subject to administrative and judicial appeal procedures, although NGOs and 
lawyers report concerns about the quality of decisions, their reasoned notification and challenges 
with the awareness of- and access to legal aid for appeals. 

Legislation  in  this  area  is  partially  aligned  with  the  EU  acquis.  The  Law  on  Foreigners  and 
International Protection maintains the reservation (geographical limitation) expressed in the New 
York Protocol of the 1951 Geneva Convention, according to which the vast majority of persons 
seeking international protection in Türkiye cannot apply for fully-fledged refugee status but for 
‘conditional refugee’ status and subsidiary protection only. Conditional refugee status limits the 
stay  in  the  country  ‘until  the  moment  a  recognised  conditional  refugee  is  resettled  to  a  third 
country’.  By  law,  Syrian  refugees  are  granted  a  specific  refugee  status  under  the  Temporary 
Protection  Regulation.  However,  in  February  2022,  the  Ministry  of  Interior  announced  that 
newly  arriving  Syrians  who  have  not  been  registered  will  not  automatically  receive  temporary 
protection  status.  According  to  the  announcement,  they  will  first  be  placed  in  camps,  and  be 
subjected  to  an  assessment  on  whether  they  need  temporary  protection,  in  order  to  define  the 
reasons  of  their  arrival  and  limit  migratory  movements  from  Syria  for  economic  motives, 
although  fleeing  for  economic  reasons  is  not  a  valid  reason  for  rejecting  temporary  protection 
applications  or  revoking  temporary  protection  status  according  to  the  temporary  protection 
regulation.   

Implementation and enforcement capacity 

Türkiye continued to host one of the largest refugee populations in the world, with 3.6 million 
Syrians under temporary protection and over 330 000 non-Syrians including those who hold or 
who  have  applied  for  international  protection  status.  The  number  of  asylum  seekers  slightly 

55 

 
 
declined  over  the  reporting  period;  29 256  international  protection  applications  were  lodged  in 
2021,  down  from  31 334  in  2020.  Of  the  29 256  applications,  21 926  were  made  by  Afghans, 
4 961  were  made  by  Iraqis  and  1 032  were  made  by  Iranians,  representing  a  similar  pattern  to 
2020. In 2021, Türkiye granted international protection (refugee status, conditional refugee status 
or  subsidiary  protection)  to  13 227  applicants,  an  increase  from  8 753  in  2020.  The  authorities 
rejected  11 908  applications  compared  to  10 674  in  2020.  The  cumulative  total  of  pending 
international protection applications stands at 304 970. This is a significant backlog that has not 
been  reduced  over  the  years.  There  is  a  lack  of  publicly  accessible  data  on  international 
protection  with  a  breakdown  of  categories  of  decisions  and  of  pending  cases  at  the  end  of  the 
year. 

Though  not  a  neighbouring  country,  the  number  of  Ukrainians  arriving  in  Türkiye  increased 
from 20 000 in March 2022 to 78 000 at the beginning of April 2022, as a result of the war in 
Ukraine. In February 2022, Türkiye officially closed down registration of temporary protection 
applications  in  16  provinces  (including  in  major  provinces,  such  as  Ankara,  Istanbul,  Izmir, 
Bursa) in an attempt to balance refugee population across Türkiye. The rule was revised in June 
2022,  to  prohibit  registration  under  any  category,  in  areas  where  the  number  of  foreigners 
exceeds 20 % of the total population. When asylum seekers are denied registration in a ‘closed’ 
province,  most  often  they  are  not  officially  referred  to  another  province  with  supporting 
documentation. Beyond the officially ‘closed’ provinces, NGOs and lawyers repeatedly referred 
to de facto closure of international protection registrations in other provinces too, save for highly 
vulnerable cases. Such barriers to registration hinder access to all other essential services and put 
asylum seekers in an irregular situation if apprehended. 

Close  to  half  of  all  Syrians  in  Türkiye  are  registered  in  four  provinces  –  Istanbul,  Gaziantep, 
Hatay and Sanliurfa - with the rest residing in various provinces across Türkiye. 50 736 Syrians 
are hosted in seven temporary accommodation centres, down from 57 321 in 2020. The number 
of  Syrians  who  were  granted  Turkish  citizenship  stood  at  193 293  at  the  end  of  2021. 
Throughout  2021,  the  PMM  continued  the  verification  of  data  of  Syrians  under  temporary 
protection, updating and completing the information  gathered during their original  registration. 
Additionally,  in  the  context  of  the  introduced  20  %  rule,  the  PMM  introduced  an  address-
verification  exercise of  Syrians.  As a result of this  exercise, the temporary protection status  of 
more than 600 000 Syrians has been reportedly deactivated, on the grounds that they were found 
to be residing in locations other than their officially registered addresses. The PMM invited these 
individuals  to  approach  their  provincial  offices  to  declare  their  current  residential  addresses, 
thereby  re-activating  their  protection  status.  In  practice,  deactivation  of  the  status  means  no 
access  to  services  such  as  education  and  healthcare.  By  June  2022,  the  status  of  over  150  000 
Syrians had been reactivated. 

A  key  mechanism  for  identifying  vulnerable  asylum  seekers  is  protection  desks  in  PDMMs 
which  interview  and  make  referrals  based  on  their  specific  needs.  In  2021,  protection  desks 
identified and processed referrals for 146 472 asylum seekers. 

In  2021,  3 870  unaccompanied  children  were  referred  to  the  Ministry  of  Family  and  Social 
Policies  (MoFSS)  by  various  agencies.  Unaccompanied  children  continue  to  face  protection 
risks,  particularly  during  initial  identification  and  age  assessment  processes,  which  are 
undertaken  by  different  agencies,  including  law  enforcement  services.  Children  are  referred  to 
hospitals for bone x-rays, which gives a broad two-year age range. In the absence of holistic age-
assessment  processes,  results  indicating  16-18  years  of  age  reportedly  tend  to  be  registered  as 

56 

 
 
adults.  A  multi-disciplinary  approach  to  age  assessment  procedures,  which  take  psychosocial 
aspects into consideration, is necessary to increase compliance with European standards. 

The PMM uses GöçNet, a government database containing data on applicants for temporary and 
international  protection,  including  biometric  data  in  the  form  of  photos  and  fingerprints.  The 
police and gendarmerie have access to GöçNet. 

Applicants  for  international  protection,  conditional  refugee  status  holders  and  people  under 
temporary  protection  (Syrians)  can  apply  for  work  permits.  However,  a  large  majority  of 
refugees and asylum seekers do not have effective access to the labour market, in particular to 
formal  employment,  due  to  low  employability  (lower  levels  of  education  and  skills),  language 
barriers and limited access to information and services. The impact of COVID-19 on the Turkish 
economy  further  worsened  the  situation,  with  more  than  76 %  of  households  receiving  cash 
support under the EU-funded Emergency Social Security Net (ESSN) after reporting a member 
of  the  household  losing  their  employment  due  to  the  pandemic.  Such  prolonged  financial 
insecurity has contributed to an increase in child labour, mental health challenges and an increase 
in domestic violence incidents. Around 426 000 Syrian children in Türkiye, especially in the 15-
18 age group, are out of school. 

The full operational budget of EUR 6 billion of the EU Facility for Refugees in  Turkey (FRIT) 
was committed and contracted by the end of 2020, with over EUR 4.7 billion disbursed by June 
2022.  The  Facility  mobilises  both  humanitarian  and  development  assistance  for  refugees  and 
host  communities in  Türkiye  to  meet  basic  needs,  increase  access  to  education  and  healthcare, 
including  for  vulnerable  groups,  children  and  women.  On  top  of  the  Facility,  the  EU  also 
committed  EUR  535  million  to  continue  the  provision  of  humanitarian  support  to  refugees  in 
2020. In 2021 the Commission committed an additional EUR 860 million, to support the basic 
needs  of  refugees,  inclusive  quality  education  for  refugees  in  Türkiye  and  access  to  higher 
education  as  well  as  for  migration  and  border  management.  This  funding  was  part  of  the 
additional EUR 3 billion mobilised by the EU to continue EU assistance to refugees in Türkiye 
for 2021-2023. 

The  PMM  and  the  European  Union  Agency  for  Asylum  (EUAA)  continued  their  cooperation 
with the implementation of the 2019-2021Cooperation Roadmap. EUAA support to the PMM is 
planned to  continue with the new 2022-2023 Roadmap, offering  capacity  building support and 
peer-to-peer  exchanges  on  best  practices  in  the  fields  of  asylum,  reception,  resettlement  and 
organisational change. 

Visa policy 

Türkiye  made  no  progress  in  meeting  the  six  unfulfilled  benchmarks  of  the  visa  liberalisation 
roadmap, namely on the anti-terror law, personal data protection legislation, the implementation 
of the EU-Türkiye readmission agreement, conclusion of an international agreement with the EU 
on  Europol, 
the  Group  of  States  against  Corruption  (GRECO) 
recommendations  on  anti-corruption,  and  the  judicial  cooperation  with  all  EU  Member  States. 
Negotiations are ongoing with a view to concluding an international agreement between the EU 
and Türkiye on Europol. 

implementation  of 

Türkiye has  introduced the biometric collection of fingerprinting for sticker visas issued by its 
diplomatic missions in a number of countries (primarily in the African continent) with a view to 
increasing the authorities’ capacity to tackle irregular migration. The authorities have relaxed the 

57 

 
 
rules  governing  the  entry  and  residence  of  Ukrainian  nationals  in  Türkiye  following  Russia’s 
invasion of Ukraine. 

Türkiye needs to further harmonise its visa policy with the EU’s visa policy. This would include 
further  aligning  Turkish  visa  requirements  with  the  EU  lists  of  visa-free  and  visa-required 
countries, full phasing-out of the issuing of visas at borders (currently the citizens of 24 countries 
are  eligible  to  obtain  visa  on  arrival)  and  of  electronic  visas,  and  ensuring  that  the  issuing  of 
visas at its diplomatic missions is carried out in line with the conditions and procedures set out in 
the EU Visa Code. Türkiye continues to apply a discriminatory visa regime against nationals of 
Cyprus, while it has abolished the short-stay visa requirements for the other 26 Member States. 

Schengen and external borders 

Institutional set-up and legal alignment 

During the reporting period, no new legislation was adopted. The coordination of the work of the 
state  bodies  dealing  with  border  management  matters  is  the  responsibility  of  the  Directorate-
General  of  Provincial  Administration  under  the  Ministry  of  Interior  (MoI).  The  Border 
Management  Implementation  Board  met  once,  in  September  2021  for  the  fifth  time  since  its 
establishment  in  2016.  Its  supervising  body,  the  Integrated  Border  Management  Coordination 
Board, has not yet met. 

For the coordination of future work of the National Coordination and Joint Risk Analysis Centre 
(NACORAC), the Ministry of Interior created a new department in autumn 2021. Several border 
management services within the Turkish administration assigned staff to  NACORAC, which is 
located  in  Ankara.  Given  its  responsibilities  at  Türkiye’s  ‘green’  border,  personnel  from  the 
Land  Forces  Command  (Ministry  of  National  Defence)  should  be  assigned.  While  formally 
established by the above- mentioned Regulation in 2016, the centre continued not to engage in 
operational  activities,  during  the  reporting  period.  NACORAC  has  received  significant  EU 
funding under several IPA programmes. 

In  February  2021,  the  Institute  of  Heads  of  Civil  Border  Administration  was  established  by 
presidential  decree,  taking  over  certain  border  management  responsibilities  from  governors  in 
eleven border regions (mostly in the East of the country). Until now, six heads have taken over 
the  organisation  of  the  work  of  border  management  services  at  six  airports  (among  which 
Istanbul, Ankara, Izmir and Antalya) upon appointment by the Directorate-General of Provincial 
Administration. This reform seeks to streamline the coordination of border management matters 
at central level. 

Similarly  to  last  year’s  recommendations,  in  order  to  bring  the  country’s  border  management 
system in line with the EU acquis, Türkiye should further improve inter-service and international 
cooperation,  accelerate  the  adoption  of  an  Integrated  Border  Management  (IBM)  strategy  and 
update  its  IBM  National  Implementation  Action  Plan  from  2006.  It  also  needs  to  enact  new 
legislation to  set  up a non-military border management body in  charge of all aspects  of border 
management,  including  border  surveillance  at  the  ‘green’  border,  which  is  currently  under  the 
responsibility of the Turkish Land Forces. 

Türkiye has committed itself to removing all anti-personnel landmines by 31 December 2025 in 
order to fulfil its obligations under the Ottawa Treaty. This deadline has been extended several 
times since 2014. So far, only a relatively small stretch of the total of 2 949 km of land border 
has  been  cleaned  entirely.  Türkiye  needs  to  substantially  increase  its  national  investment  to 

58 

 
 
remove mines along the border with Syria, Iraq, Iran, Armenia as well as inside Türkiye. The EU 
is currently providing significant financial support for de-mining. 

Implementation and enforcement capacity 

Türkiye  continued  to  invest  significant  efforts  and  financial  means  in  modernising  border 
security at the land borer in the east of the country. After the construction of a wall and a barbed-
wire  fence  along  the  Syrian  border  financed  by  the  national  budget,  the  installation  of  modern 
communication and surveillance masts, which continued at the Iranian border and was partially 
funded by the EU. Communication and surveillance masts have been erected also at the western 
land border. 

Relations with  the European Border and Coast  Guard Agency (Frontex), which are based on  a 
three-year Cooperation Plan covering 2020-2022, were negatively impacted by incidents  at  the 
Greek-Turkish land border and the Aegean Sea in 2020 and did not noticeably improve during 
2021.  Harsh  criticism  of  Frontex’  work  by  some  media  outlets  and  high-level  government 
officials continued. The authorities continued to provide monthly reports on irregular migration 
flows  at  the  country’s  western  land  and  sea  borders.  Türkiye  does  not  participate  in  joint 
operations. Frontex has a liaison officer permanently based in Ankara. 

Cooperation with neighbouring Greece and Bulgaria in the framework of a trilateral Police and 
Customs  Co-operation  Centre  at  the  Bulgarian-Turkish  border  crossing  point  Kapitan 
Andreevo/Kapıkule continued. 

Türkiye continued contributing to INTERPOL’s databases such as the ‘Interpol Notices’, ‘Stolen 
and  Lost  Travel  Documents’,  ‘Stolen  Motor  Vehicle’  and  ‘Stolen  Marine  Tools’.  Database 
connections are used by authorised officers of the Turkish  National  Police in  all 81 provinces. 
Certain staff members in the following services have access to the databases: the Presidency of 
Migration  Management  (PMM),  the  Disaster  and  Emergency  Presidency  (AFAD),  the  Nuclear 
Regulatory Authority, the Turkish Atom Energy Authority, the Ministry of Trade (DG Customs 
Enforcement), the Turkish Coast Guard Command and the General Command of Gendarmerie. 

2.3. ECONOMIC CRITERIA 

Table 5.1:  

Türkiye - Key economic figures 
GDP per capita (% of EU-27 in PPS)1) 

Real GDP growth  

Economic activity rate of the population aged 15+ (%), 
total1) 

      female 

      male 

Unemployment rate of the population aged 15+ (%), 
total1) 

      female 

      male 

59 

2019 

2020  2021 

2013-18 
average 

65 

5.6 

51.1 

31.5 

71.2 

10.3 

12.8 

9.2 

59 

0.9 

61 

1.8 

64 

11.0 

52.9 

49.1 

51.4 

34.3 

30.8 

32.9 

71.9 

67.8 

70.3 

13.7 

13.1 

12.0 

16.4 

14.8 

14.7 

12.4 

12.4 

10.7 

 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Employment of the population aged 15+ (annual growth 
%) 

3.2 

-2.3 

-4.8 

7.9 

Nominal wages (annual growth 
%) 

Consumer price index (annual growth %) 

Exchange rate against EUR 

Current account balance (% of GDP) 

Net foreign direct investment, FDI (% of GDP) 
General government balance (% of GDP)1) 

General government debt (% of GDP) 

13.9 

9.9 

3.60 

-4.0 

1.1 

-1.5 

28.8 

Notes:  
1) Eurostat 

2) State government 

Source: national sources 

26.2 

18.0 

19.3 

15.2 

12.3 

19.6 

6.35 

8.03  10.45 

0.7 

0.9 

-5.0 

-1.7 

0.6 

-3.2 

-2.9 

32.6 

39.7 

0.9 

-2.3 
422) 

In line with the conclusions of the European Council in Copenhagen in June 1993, EU accession 
requires the existence of a functioning market economy and the capacity to cope with competitive 
pressure and market forces within the Union. 

Economic governance has become even more central in the enlargement process in recent years. 
The Commission’s monitoring takes place in two processes: the  Economic Reform Programme 
exercise and the below assessment of compliance with the economic criteria for accession. Each 
enlargement  country  prepares  an  Economic  Reform  Programme  (ERP)  annually,  setting  out  a 
medium-term macro-fiscal policy framework and a structural reform agenda aimed at ensuring 
competitiveness  and  inclusive  growth.  The  ERPs  are  the  basis  for  country-specific  policy 
guidance  jointly  adopted  by  the  EU  and  the  Western  Balkans  and  Türkiye  at  ministerial  level 
each year. 

2.3.1. The existence of a functioning market economy 

The  Turkish  economy  is  well  advanced,  but  made  no  progress  over  the  reporting  period. 
Serious concerns persist over the continued proper functioning of Türkiye’s market economy 
as there has been backsliding on important elements, such as the conduct of monetary policy 
and the institutional and regulatory environment. 

The economy recovered strongly from the COVID-19-crisis, growing by 11.4 % in 2021 and 
more than 7% in  the first  half of 2022, despite the fallout  of Russia’s invasion  of Ukraine. 
The overly loose monetary policy and lack of policy credibility have weakened the lira and 
drove  the  official  inflation  to  a  two-decade  high  of  more  than  80  %.  Higher  prices  for 
imported commodities widened external imbalances, which remain a major vulnerability in a 
situation of increased uncertainty and low level  of international  reserves. Budget  execution 
outperformed plans but  government  debt  increased and fiscal  policy has  come increasingly 
under pressure, burdened by unsuccessful attempts to curb rising inflation and underpin the 

60 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
domestic currency. 

The  institutional  and  regulatory  environment  remains  fragile,  particularly  as  regards  the 
predictability, transparency, and implementation  of regulations.  Some important  steps were 
taken in order to improve the resolution of commercial disputes. Despite its gradual decline, 
the  informal  sector  still  accounts  for  a  significant  share  of  the  economic  activity.  State 
intervention  in  price-setting  mechanisms  persists.  The  provision  of  State  aid  lacks  proper 
implementation  rules,  enforcement  and  transparency.  The  banking  sector  remained  largely 
stable  and  capital  adequacy  above  the  regulatory  requirements.  Non-performing  loans 
decreased and profitability improved, but dollarisation and financial stability risks increased. 
The labour market recovered from the pandemic, but deep-seated structural challenges, such 
as  a  huge  gender  gap,  a  high  share  of  youth  unemployment,  and  wide  regional  disparities 
remain. 

The  Commission’s  recommendations  from  2021  were  not  fully  implemented  and  remain 
valid.  In  order  to  improve  the  functioning  of  the  market  economy,  Türkiye  should  in 
particular: 

 

 

 

 

tighten monetary policy and restore the functional independence of the central bank in 
order to reduce inflation and inflation expectations; 

rebalance the policy mix and use some of the available fiscal space in 2022 to cushion 
the impact of adverse shocks through targeted support to vulnerable households and 
firms; 

further  improve  the  business  environment,  reduce  state  interference  in  price  setting, 
and enhance the transparency and control of State aid; 

incentivise  the  labour  market  participation  of  women  and  improve  the  transition  of 
young people into the labour market. 

Economic governance 

An  overly  loose  monetary  policy  has  fuelled  record-high  inflation  and  strained  economic 
fundamentals.  Since  September  2021,  monetary  policy  took  a  turn  towards  a  much  more 
expansionary  stance,  triggering  a  steep  depreciation  of  the  lira  and  significant  increase  in 
inflation and inflation expectations. Attempts to strengthen the lira and curb the rising inflation 
with  the  help  of  other  policy  instruments  have  been  largely  unsuccessful,  exposing  economic 
policy  inconsistencies.  Fiscal  policy,  in  particular,  has  come  increasingly  under  pressure.  The 
frequent changes in the management team of the central bank and in the statistical institute have 
undermined policy credibility further and are a cause of serious concern. The policy guidance set 
out in the conclusions from the Economic and Financial Dialogue of July 2021 has been partially 
implemented. 

Macroeconomic stability 

The Turkish economy recovered strongly from the crisis and continued to grow in the first 
half of 2022 despite multiple challenges. Economic growth reached 11.4 % in 2021, supported 
by  base  effects  and  a  rebound  of  both  domestic  and  external  demand,  bringing  the  average 
growth in the last 5 years at close to 5 %. Despite growing inflationary pressures, a recovering 
labour market and deeply negative real interest rates sustained buoyant household consumption, 
which grew particularly  strongly in the first half of 2022 and returned above trend for the first 

61 

 
 
performance 

time  since  the  2018  currency  crisis. 
Net  exports  had  a  sizeable  positive 
contribution to growth as the strong 
export 
continued 
imports  were 
unabated,  while 
suppressed  by  the  depreciation  of 
the lira. Investment contracted in the 
second  half  of  2021,  remaining 
below its level 5 years earlier, while 
stocks  accumulated  in  the  COVID-
19  crisis  continued  to  unwind  fast. 
Although decelerating in early 2022, 
the  growth  momentum  remained  buoyant  despite  the  fallout  of  Russia’s  invasion  of  Ukraine. 
However, heightened volatility and uncertainty took a toll on economic sentiment and sapped the 
otherwise  very  strong  manufacturing  activity.  Türkiye’s  relatively  strong  performance  in  the 
crisis  strengthened  its  real  convergence,  with  per  capita  GDP  in  purchasing  power  standards 
reaching 64 % of the EU average, although remaining below its 2015 high of 68 %. 

The  large  negative  terms-of-trade  shock  increased  external  imbalances,  which  remain  a 
major vulnerability in a situation of higher uncertainty and weak buffers. The narrowing of 
the  current  account  deficit  to  1.7%  of  GDP  in  2021,  close  to  the  average  in  the  last  5  years, 
turned out to be short-lived as strong increases in international commodity prices, for energy in 
particular, reversed this trend at the end of the year. The rise to record high levels in the exports 
of goods, the recovery in service exports, and suppressed import volumes could not offset these 
price  effects.  External  vulnerabilities  are  exacerbated  by  the  reliance  on  short-term  external 
finance  and  the  very  high  sovereign  risk  premium.  The  five-year  credit  default  swap  started 
increasing,  from  an  already  high 
level,  since 
the  central  bank 
changed  its  monetary  policy  in 
September 2021 and went further 
above  900  bps  in  July  2022, 
reflecting the tightening of global 
financial  conditions,  Türkiye’s 
weakened  policy  credibility  and 
economic exposure to the fall-out 
from the war in Ukraine. The low 
level  of  gross  official  foreign 
exchange reserves and the higher 
foreign 
share 
currencies in it adds to external vulnerabilities. The external debt ratio declined somewhat to 55 
% of GDP in 2021 as the economy recovered, largely unchanged in the last 5 years, but remains 
very sensitive to the depreciation of the lira. The banking sector, in particular, has so far had no 
difficulty  rolling  over  its  short-term  external  debt  while  the  non-financial  sector  has  a  positive 
short-term  net  foreign  exchange  position,  which  are  important  factors  attenuating  external 
vulnerability. 

non-core 

of 

The overly loose monetary policy and lack of policy credibility have weakened the lira and 
drove inflation to a two-decade high. In the last quarter of 2021, the central bank lowered its 

62 

 
 
key  policy  rate  by  500  bps.  to  14  %,  and  further  to  13  %  in  August  2022,  despite  high  and 
growing inflation. Real interest rates turned deeply negative, triggering a strong depreciation of 
the lira and market instability. The lira’s slide was temporarily arrested by sizeable central bank 
interventions and the introduction of a special scheme protecting the foreign exchange value of 
lira time deposits. However, the local currency depreciated further since the start of Russia’s war 
against Ukraine and consumer inflation reached 80.2 % y/y in August. Food and energy prices 
increased markedly, affected by global trends as well, despite the authorities’ administrative and 
tax  policy  efforts  to  soften  their  surge.  Inflationary  pressures  firmed  up  and  became  more 
generalised,  with  producer  prices  rising  144  %  y/y  in  August.  Monetary  policy  has  become 
increasingly  inefficient  as  market  interest  rates  have  largely  decoupled  from  the  central  bank 
policy rate, providing fertile ground for continued volatility. 

The budget balance was lower than targeted but fiscal policy has come increasingly under 
pressure  by  the  rising  inflation.  Since  the  beginning  of  the  pandemic,  budget  execution  has 
consistently  over-performed.  At  around  2.8  %  of  GDP  in  2021,  the  central  government  deficit 
was significantly below the revised 2021 target and the 2020 deficit (both at 3.5 %). The general 
government deficit declined further from 2.8 % in 2020 to 2.3% of GDP in 2021. Total revenue 
fell 1.5 pps to 28.2 % of GDP due to the changed GDP structure towards less revenue-rich net 
exports. Total expenditure declined by 2.0 pps as reduced pandemic-related budget support and 
high  inflation  supressed  compensation  of  employees  and  current  transfers.  Interest  payments 
remained elevated at 2.6 % of GDP, reflecting the strong depreciation of the lira, while capital 
expenditure increased slightly, although remaining far below its historic average. In an attempt to 
cover some of the surging energy costs, budget lending and transfers, mainly to the state energy 
company  BOTAŞ,  shot  up  at  the  end  of  2021,  and  continued  apace  in  2022.  The  2022  budget 
targets  a  budget  deficit  of  TRY  278.4 
billion  (3.5  %  of  GDP);  although  the 
headline  target  seems  achievable,  it  is 
based  on  unrealistic  macroeconomic 
assumptions  and  was  already  outdated 
at  the  time  of  its  adoption.  The  budget 
did  not  take  into  account  a  number  of 
measures  with  significant  budgetary 
impact  both  on  the  revenue  and  the 
expenditure  side,  trying  to  address  the 
rising  energy  costs,  limit  the  general 
price surge, and support the value of the lira. A budget revision was proposed in June, increasing 
significantly revenue estimates and expenditure plans, while preserving the deficit target, and the 
medium-term macroeconomic framework was updated in  early September. Debt vulnerabilities 
and fiscal risks increased. The much weaker lira pushed government debt up to 42 % of GDP in 
2021, despite the relatively small budget deficit and debt management efforts. Debt composition 
worsened  with  a  higher  share  of  foreign-currency-denominated  bonds.  Fiscal  policy  has  also 
become more opaque as the new measures to support the holding of lira deposits have brought 
not  only  direct  costs  to  the  budget,  but  also  potentially  significant  contingent  liabilities 
depending on exchange rate dynamics. 

The  macroeconomic  policy  mix  has  largely  focused  on  the  pursuit  of  growth  but 
undermined  financial  and  economic  stability.  The  policy  mix  has  underpinned  a  robust 
economic recovery in 2021 and in the first half of 2022, but an overly loose monetary stance led 

63 

01020304050-4-202201620172018201920202021Graph 5.3: Türkiye -Fiscal developmentsPrimary balance (lhs)Interest (lhs)GG balance (lhs)Public Debt (rhs)Source: Nationalsources% ofGDP 
 
to very high inflation, weakened the lira and worsened country risks. Attempts by fiscal policy to 
remedy  some  of  these  negative  consequences  came  at  an  increased  budgetary  cost,  higher 
government  debt,  and  rising  fiscal  risks.  In  addition,  institutional  weaknesses  and  low  policy 
credibility continue undermining the effectiveness of the policy mix. 

Functioning of product markets 

Business environment 

Türkiye’s institutional and regulatory environment remains fragile, although some actions 
were taken to improve dispute settlement. Starting a business is still relatively cumbersome, 
while market exit has also remained costly and time-consuming, with a low recovery rate. The 
number of newly established businesses increased by 8.3 % in 2021. In parallel, the number of 
liquidated companies increased significantly by 22.5 % while the number of closed ones by 5.6 
%.  Türkiye  has  taken  some  positive  steps  by  facilitating  the  setting-up  of  specialised  courts, 
ratifying  the  Singapore  Convention  for  international  commercial  disputes,  bringing  changes  in 
the  concordat  regime  and  providing  online  access  to  court  decisions.  The  authorities  also 
introduced new modalities for the financial restructuring regime. Even though alternative dispute 
resolution mechanisms have been promoted, commercial judicial processes are slow, and a large 
backlog  of  commercial  court  cases  remains.  Türkiye  still  lacks  a  systematic  consultation 
mechanism  with  business  organisations  and  social  partners  during  the  preparation  of  new 
legislation. 

Türkiye is at an early stage of applying the EU acquis and European standards in the area 
of  judiciary.  Major  issues  identified  in  previous  reports,  in  particular  the  systemic  lack  of 
independence  of  the  judiciary  and  systemic  violations  of  human  rights,  remained  unaddressed 
(see Chapter 23) and serious backsliding continued in the reporting period. Intellectual property 
right  enforcement  remains  very  weak.  According  to  Europol,  Türkiye  is  the  second  largest 
source  country  of  pirated  products  affecting  the  EU  single  market  and  of  counterfeit  products 
seized  at  the  EU’s  external  borders  (See  Chapter  7).  The  acquisition  and  management  of 
companies  under  the  trusteeship  of  the  Savings  Deposits  Insurance  Fund  (SDIF)  remains  non-
transparent. Moreover, the number of companies managed under the trusteeship of SDIF is still 
high.  As  of  the  end  of  June  2022,  the  management  of  677  companies  based  in  36  provinces 
across Türkiye with a total asset value of TRY 97.2 billion (1.0% of GDP) and with a total of 32 
699 employees, remained under the trusteeship of the Fund. Neither a schedule for resolving the 
release of all companies from trusteeship, nor appropriate, effective, and timely means of legal 
redress are in place. 

The  informal  sector  remained  structurally  high  and  well  above  the  OECD  average.  The 
share of unregistered employment fell to 25.8 %, while in the non-agricultural sector it was 16.5 
% in the first quarter of 2022. The government pursued its efforts to implement the Action Plan 
and Strategy for the fight against the informal economy (2019-2021). With this action plan, the 
Revenue  Administration  aimed  most  of  all  to  increase  the  level  of  voluntary  compliance, 
strengthen audit capacity, review and regulate the legislation, enhance interagency data sharing 
and  increase  awareness.  However,  the  plan  lacks  performance  indicators  to  track  its 
implementation progress. 

State influence on product markets 

64 

 
 
The state expanded its intervention in the price-setting mechanism of key sectors. More than 
a quarter of the consumer basket is composed of goods whose prices are set or heavily influenced 
by public authorities (including through price limits and tax rate adjustments). Since July 2021, 
the annual increase in residential rent was limited to 25 %. The authorities have continued using 
a  sliding  scale  system  to  curb  the  inflationary  pressures  coming  from  oil  prices.  Furthermore, 
from  the  beginning  of  2022,  the  Energy  Market  Regulatory  Authority  has  implemented  an 
electricity  tariff  system  based  on  the  level  of  consumption  (block  tariffs).  It  has  been  also 
authorised to set up a tariff for vulnerable consumers before the gradual lifting of some subsidies. 
Meanwhile,  the  regulators  have  continued  carrying  out  intensive  price  audits  to  investigate 
alleged  unfair  pricing  and  stockpiling  practices.  The  start  of  the  implementation  of  a  2  % 
accommodation  tax  has  been  put  on  hold  until  2023  on  the  grounds  of  the  impacts  of  the 
COVID-19  outbreak  and  the  deterioration  of  the  economic  situation.  As  part  of  the  efforts  to 
fight  against  inflation,  in  early  2022,  the  VAT  was  also  reduced  for  almost  all  food  products 
from 18 % to 1 % and for hygiene products from 18 % to 8 %. The delivery of the COVID-19 
vaccines is still subject to a 1 % VAT until 31 December 2022. 

State  aid  transparency  and  control  remained  weak.  Legislation  to  implement  the  State  aid 
law  has  not  been  adopted.  However,  the  legislative  framework  was  amended  by  a  presidential 
decree  establishing  a  Directorate  General  for  State  Aids  responsible  for  evaluating  State  aid 
proposals  and  recommending  proposals,  change,  or  cancellation  of  new  State  aid  schemes. 
Türkiye has not formally set up a comprehensive State aid inventory or adopted an action plan to 
align  all  State  aid  schemes  with  the  EU  acquis.  The  current  structure  of  State  aid  control  is 
considered  neither  independent  nor  operational  (see  Chapter  8).  As  of  September  2022,  the 
committed investment amount for the supported 45 projects reached TRY 335 billion (2.7% of 
GDP). The amount of investment incentive has doubled with a single project (worth TRY 145.2 
billion) aiming to support the drilling activities in the Black Sea.  However, as it is the case for 
the  general  incentive  scheme,  Türkiye  failed  to  publish  data  concerning  the  actual  support 
granted to these projects. Small and medium enterprises (SMEs) benefit from numerous support 
measures and initiatives, for which there is however a lack of systematic monitoring. The SME 
Development  Organisation  of  Türkiye  (KOSGEB)  conducted  evaluations  on  five  support 
programmes under its mandate and published them on its website. 

Privatisation and restructuring 

The sovereign wealth fund expanded further its presence in the economy, while the scope of 
privatisation  remained  limited.  The  privatisation  receipts  increased  marginally  to  USD  413 
million  in  2021.  The  Privatisation  Administration  has  targeted  the  privatisation  of  electricity 
generation plants, ports and real assets in 2022. The Turkish Wealth Fund (TWF) holds shares in 
major  companies  in  the  financial  (including  large-scale  state-owned  banks  and  Borsa  Istanbul, 
consolidated  public  insurance  companies),  telecommunications,  petrochemicals,  real  estate, 
mining, agriculture, and transport sectors. In March 2022, the TWF increased its share to 61.68 
%  of  Turk  Telekom  and  thus  became  its  majority  stakeholder  and  the  largest  player  on  the 
telecom market (See Chapter 8). In an effort to strengthen public banks and ensure economic and 
financial stability, TWF has increased the core capital of public banks. The TWF continues to be 
exempted  from  various  taxes,  charges  and  rules  related  to  (publicly  held)  corporations’ 
transactions, merger and acquisition, unlawful exercise of control, and shareholders’ rights. TWF 
total assets increased to TRY 2.2 trillion (44 % of GDP) at the end of 2020, up from TRY 1.5 
billion (35 % of GDP) in 2019. 

65 

 
 
Functioning of the financial market 

Financial stability 

The banking sector remained largely stable, although facing some legacy issues and rising 
financial stability risks. The banking sector remained well capitalised. Since September 2021, 
the regulatory capital adequacy ratio increased by 0.7 pps to 18.0 % and core capital by 1 pps to 
14  %  in  July  2022.  Capital  adequacy  of  state-owned  banks  improved  following  a  large  capital 
injection (TRY 51.5 billion) by the Türkiye Wealth  Fund in  early 2022, but  it has deteriorated 
markedly  since  April  and  remained  well  below  the  average  for  the  banking  system.  Some 
prudential measures have remained relaxed to protect capital adequacy ratios, such as the use of 
a  252-business  day  rolling  average  FX  rate  and  the  suspension  of  mark-to-market  accounting 
rules.  The  non-performing  loans  ratio  declined  further  to  2.4  %  in  July  (1.7  %  in  state-owned 
banks) and loan-loss  provisioning went up to  82.5 %  for the banking system (88.3 % in  state-
owned  banks).  At  around  10%,  however,  the  share  of  stage  2  loans  under  close  monitoring 
remained  elevated.  Bank  profitability  improved  and  the  average  return  on  assets  reached  2.0% 
and the return on equity 25.2 % in July, but they remained markedly lower in state-owned banks 
and negative in real terms. Deposit dollarisation increased further, peaking at 67.1 % at the end 
of 2021, before subsiding to 54.9 % in August. However, the underlying dollarisation remained 
higher if FX-protected deposits, representing another 16 % of all deposits, are taken into account. 
This new financial instrument presents particular challenges and risks not only to the government 
budget,  but  to  financial  stability  as  well  in  case  of  a  sudden  shift  back  to  foreign  exchange-
denominated deposits. 

Access to finance 

Prudential  policies  have  shifted  to  tame  credit  growth.  Most  of  the  financial  stability  and 
credit stimulus measures, adopted in the context of the pandemic, were lifted in 2021 and credit 
growth  decelerated  strongly  as  a  result.  Lending  remained  subdued  in  early  2022,  declining  in 
real terms mostly in the households segment due to the very high inflation rate. However, loans 
to non-financial companies accelerated strongly, prompting the central bank to introduce macro-
prudential measures to tame its growth and direct it to uses and sectors deemed more beneficial 
to  economic  and  financial  stability.  Consumer  loans  were  curtailed  and  a  10%  reserve 
requirement  that  was  later  increased  to  20  %,  was  imposed  on  the  banks’  and  financial 
companies’  lira-denominated  commercial  loans  extended  since  April  2022,  with  a  penalty  for 
banks  with  a  loan  growth  since  the  beginning  of  the  year  above  20  %  by  end-May.  Loans  to 
SMEs,  export,  investment,  tradesmen,  agriculture,  and  some  other  categories  were  exempted 
from  this  rule.  As  part  of  their  ‘liraisation’  efforts,  in  June  the  authorities  introduced  new 
revenue-indexed  bonds  and  restricted  access  to  lira-denominated  loans  to  companies  with 
significant FX cash assets (including gold and FX deposits). Total credit stood at 62 % of GDP 
in  June, declining somewhat  since the beginning of the  year. Total bank assets increased from 
121  %  of  GDP  in  2020  to  127  %  in  2021,  while  the  share  of  foreign-owned  banks  in  total 
banking  sector assets increased from 25.1 % to  25.9 %. After being stable throughout  most of 
2021,  the  USD  and  lira  interest  rate  spreads  between  commercial  loans  and  deposits  have 
increased markedly since the end of November. 

Functioning of the labour market 

The labour market has recovered from the pandemic but deep-seated structural challenges 
remain. The strong economic growth lifted the  labour market  and the number of jobs  reached 

66 

 
 
new heights in 2022. The activity and employment rates increased markedly, to pre-crisis levels. 
Job creation was particularly strong in services and industry, extending its gains in early 2022, 
while  the  sector  of  agriculture  shed  jobs.  The  number  and  share  of  workers  without  social 
security  registration  declined  further  to  their  lowest  level  on  record  in  early  2022. 
Unemployment declined from its peak and the headline unemployment rate went down to single 
digits  in  June  for  the  first  time  since  2018.  The  labour  market  slack,  however,  remains 
structurally  high,  as  evident  by  the 
elevated  composite  measure  of 
labour  underutilisation  at  nearly 
20%, which takes into account time-
related 
and 
potential  labour  force.  Despite  the 
economic  rebound,  the  gap  between 
male 
employment 
female 
remained  significant,  with  female 
activity  and  employment  rates  less 
than  half  of  male.  In  June,  almost  a 
quarter  of  all  young  people  (15-24 
years) were not in employment, education or training and the youth unemployment rate remained 
very high, although falling below 20 % in the second quarter of the year. Regional labour market 
disparities  have  declined  but  are  still  significant,  with  the  unemployment  rate  across  different 
regions ranging from 5.8 % to 29.8 % in 2021. The wage policy was procyclical as the minimum 
wage nearly doubled in 2022, after two hikes – of around 50 % in the beginning of the year and 
another one of close to 30 % in early July. 

underemployment 

and 

2.3.2. The capacity to cope with competitive pressure and market forces within the Union 

Türkiye has a good level of preparation and made limited progress in achieving the capacity 
to cope with the competitive pressure and market forces within the EU. Despite some progress 
in  improving  vocational  training,  the  mismatch  between  the  education  system  and  labour 
market  needs  persists.  Expenditure  on  research  and  development  continued  to  increase  at  a 
very  slow  pace  and  remained  well  below  the  government’s  target.  Investment  activity 
weakened in the second half of 2021. Progress continued with regard to the diversification of 
energy  supplies  and  increasing  the  share  of  energy  generated  from  renewable  sources.  The 
extension  of  local  content  requirement  practices  in  the  renewable  energy  generation  sector 
raises concerns.  Türkiye removed some of the additional custom duties; however, extensive 
deviations from its obligations under the EU-Turkey Customs Union hinder bilateral trade. 

The Commission’s recommendations from 2021 were not fully implemented and remain valid. 
In  order  to  improve  competitiveness  and  support  long-term  growth,  Türkiye  should  in 
particular: 

→  continue  increasing  enrolment  in  education  (especially  for  pre-education),  improve 
vocational education and training and better adapt education and training to labour market 
needs; 

→  deepen  natural  gas  market  reform  and  revise  the  natural  gas  market  law  to  ensure 

compatibility with the EU's Third Energy Package; 

67 

 
 
→ remove all protectionist measures not in line with the EU-Turkey Customs Union. 

Education and innovation 

Türkiye  has  made  some  progress  towards  improving  vocational  education.  Total 
expenditure on education stood at 5.4 % of GDP in 2020, representing a real increase of 4.5 % 
year-on-year. Government  spending  was around  three quarters of it or 4.0 % of GDP in 2020, 
decreasing by 0.4 pps from 2019. The highest increase in education expenditure per student was 
observed in tertiary education. In the 2020-2021 school  year, net enrolment rates decreased for 
primary  (first  4  years)  and  for  lower  secondary  education  (second  4  years),  whereas  it  has 
increased for upper secondary (final  4  years) and tertiary education. The  COVID-19 pandemic 
had  a  negative  impact  on  pre-school  attendance  (See  Chapter  26).  Türkiye  continues  to  score 
poorly  in  educational  attainment  in  the  Gender  Gap  Index  calculated  by  the  World  Economic 
Forum,  ranking  101st  of  156  countries  in  2021.  The  proportion  of  students  in  vocational  and 
technical secondary education fell further to 27.4 % in 2021 (from 35.9 % five years ago). The 
share  of  pupils  in  religious  education  remained  broadly  stable  at  close  to  11  %  in  the  upper 
secondary education, but increased in the lower secondary education to 13.7 %, up from 10.1 % 
five years ago. There is a persistent mismatch between the requirements of the labour market and 
the  skills  acquired  in  the  education  system.  With  the  adoption  of  the  National  Youth 
Employment  Strategy  and  Action  Plan,  Türkiye  is  increasing  its  efforts  to  improve  vocational 
training and to reduce the NEET rate to 20 % by end of 2023.  

Investment  on  research  and  development  (R&D)  continues  to  increase,  but  Türkiye  still 
lags  in  the  EU  innovation  scoreboard.  R&D  expenditure  increased  gradually  from  0.8  %  of 
GDP in 2013 to around 1.1 % in 2020, although remaining below the government’s target of 1.8 
% by 2023 and EU average of 2.3 %. With the largest share in  R&D expenditures (65 %), the 
private  sector  continues  to  be  the  main  driver  behind  the  R&D  in  Türkiye,  although  there 
remains  scope  for  strengthening  its  cooperation  with  research  institutions.  Türkiye  adopted  its 
first National Artificial Intelligence Strategy (2021-2025) in August 2021, showing its growing 
interest  to  shift  towards  innovation-driven  economy.  In  the  Global  Innovation  Index  2021, 
Türkiye’s overall score has improved significantly over a year, ranking in the  41st place among 
132  countries.  However,  according  to  the  EU  innovation  scoreboard,  Türkiye’s  innovation 
performance relative to the EU declined markedly from 74 % in 2020 to 55 % in 2021. While the 
number  of  domestic  patent  applications  increased  by  2.9  %  in  2021  as  compared  to  2020, 
Türkiye’s total international patent applications decreased further by 13.1 % in the same period. 
The  implementation  of  Türkiye’s  action  plan  to  boost  the  national  research  and  innovation 
capacity contributed positively to Türkiye’s performance in Horizon 2020. In October 2021, the 
European Commission and Türkiye signed the association agreement for Horizon Europe for the 
period 2021-2027. 

Physical capital and quality of infrastructure 

Despite  continued  weakness  of  construction,  investment  rebounded  somewhat.  Investment 
activity  was  strong  in  the  first  half  of  2021  but  has  been  rather  subdued  since  then.  Total 
investment  accounted  for  28.1  %  of  GDP  in  2021,  close  to  the  historic  average.  The  share  of 
construction in total investment fell further to 43 % in 2021 – the lowest in more than a decade. 
The government announced a series of new loan schemes in May 2022, to revive the real estate 
sector.  The  share  of  investment  in  machinery  and  equipment,  on  the  other  hand,  reached  new 
highs, increasing further to 46 % in 2021. Public investment had been broadly stable for years at 

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close to 4 % of GDP but fell sharply below 3 % since 2019. 

Although diversification of energy supplies improved and the use of renewables increased, 
competition and pricing mechanism issues in the energy sector persist. Limited progress was 
made on natural gas market reforms, as the unbundling of the state-owned gas company BOTAȘ 
was  once  again  suspended.  As  a  result,  BOTAȘ  remained  vertically  integrated  comprising  gas 
trade, pipeline and LNG infrastructure and retained its dominant market position, thus hindering 
a transparent, cost-reflective, and non-discriminatory pricing. Türkiye continued to be a reliable 
transit country ensuring the smooth operation of the Trans Anatolian Pipeline (TANAP), which 
as part of the Southern Gas Corridor (SGC) transmits natural gas from Azerbaijan to Europe by 
connecting to the Trans Adriatic Pipeline (TAP). As regards renewable energy, Türkiye pursued 
its  efforts  to  maximise  the  use  of  domestic  and  renewable  sources  and  raised  the  share  of 
renewable  energy  in  the  country’s  installed  power  mix  to  53 %  at  the  end  of  2021.  Private 
investments kept driving the growth in renewable installations, on the back of a preferential feed-
in-tariff extended until 2030. The local content requirement practices in Türkiye continue to raise 
concerns as they contradict WTO and the EU-Turkey Customs Union rules and affect the EU’s 
and other international companies’ competitiveness on the Turkish energy market. 

The COVID-19 pandemic has been an important accelerator of the digital transformation 
 % in 2021, the sector 
of the Turkish economy. Although its share in GDP remains low at 2.8 
of information and communication grew significantly over the last two years, by 14.5 % and 21.8 
%  respectively  in  2020  and  2021.  The  number  of  broadband  internet  subscribers  reached  88.2 
million  in  2021,  up  from  82.4  million  in  2020  and  76.6  million  in  2019.  Mobile  broadband 
penetration  slightly  increased,  though  it  is  still  below  the  OECD  average.  The  share  of 
households  with  access  to  internet  at  home  grew  from  90.7  %  in  2020  (88.3  %  in  2019)  to 
92.0 % in 2021. Over the same period, internet usage by individuals aged 16-74 also increased 
from  79.0  %  in  2020  (75.3  %  in  2019)  to  82.6  %  in  2021.  The  share  of  individuals  using  e-
government services reached 58.9 % in 2021. The number of 4.5G subscribers increased to 80.2 
million in 2021, of which 61.9 million were active users. The digitalisation in business has also 
accelerated,  with  14  %  of  the  enterprises  having  started  or  increased  their  e-sales  during  the 
COVID-19 pandemic. 

Sectoral and enterprise structure 

The services sector continued to dominate the economy, having recovered significantly with 
the  lift  of  pandemic-related  restrictions  as  of  the  second  quarter  of  2021.  Services  sector 
activities  increased  by  double-digits  in  2021,  with  the  accommodation,  entertainment,  and 
information  and  communication  sectors  recording  the  fastest  pace  of  growth.  Financial  and 
insurance  activities  contracted  as  credit  activity  decelerated.  Services  accounted  for  55.3  %  of 
employment in 2021, down by 0.6pps from their 2020 level. Previously one of the main sectors 
driving economic growth, the construction sector has slowed down since 2018, with a share of 
GDP  falling  to  5.1  %  in  2021.  However,  the  construction  sector’  share  in  total  employment 
increased  slightly  to  6.2  %,  up  by  0.4  pps  from  its  2020  level.  Although  its  share  of  GDP 
decreased from 6.7 % in 2020 to 5.5 % in 2021, agriculture continues to be an important sector, 
employing 17.2 % of the workforce (down by 0.5pps from its 2020 level). 

Small  and  medium-sized  enterprises  (SMEs)  are  the  backbone  of  the  economy.  SMEs 
employ  around  three  quarters  of  Türkiye’s  workforce  and  generate  more  than  half  of  the 
economy’s  total  value  added.  Türkiye  continued  to  implement  various  economic  support 

69 

 
 
to  companies  on  R&D, 

schemes,  mostly  targeting  SMEs.  The  SME  Development  Organisation  KOSGEB  provides 
support 
internationalisation, 
entrepreneurship and for investments in high technology and strategic products. In addition, there 
are SMEs support schemes implemented by the Scientific and Technological Research Council 
of Türkiye (TÜBİTAK) as well. 

innovation,  product  development, 

Economic integration with the EU and price competitiveness  

Economic integration  with the EU declined, although remaining high. Türkiye is  the EU’s 
sixth largest trading partner, while the EU is by far Türkiye’s largest trading partner. The share 
of  the  EU  in  Turkish  exports  was  broadly  unchanged  at  41.3  %  in  2021,  while  the  share  of 
Turkish imports originating in the EU-27 decreased from 33.4 % to 31.5 %. The EU’s share of 
foreign direct investment (FDI) inflows in Türkiye fell from 52 % in 2020 to 34 % in 2021, but 
rebounded again in the first half of 2022. 

The EU’s share in the overall stock of FDI declined from around 60 % 5 years ago to around 50 
% in 2020 and 2021. Trade openness increased markedly  in 2021, surpassing 70% of GDP for 
the  first  time  and  was  up  10  pps  over  the  previous  year,  as  the  growth  of  exports  of  goods 
continued unabated and the exports of services rebounded. 

Türkiye removed some of the additional duties imposed on a large number  of products of non-
EU origin and in free circulation within the EU-Turkey Customs Union. Yet, a large number of 
additional  duties  remain  in  force,  in  contradiction  with  the  rules  of  the  EU-Turkey  Customs 
Union. Non-tariff barriers such as import surveillance and excessive customs checks continued 
to  hinder  trade  flows.  Following  the  WTO  appeal  ruling,  Türkiye  now  must  remove  its 
inconsistent localisation and prioritisation measures in the pharmaceutical sector. 

2.4. PUBLIC PROCUREMENT, STATISTICS, FINANCIAL CONTROL 

Chapter 5: Public procurement 

EU  rules  ensure  that  the  public  procurement  of  goods  and  services  in  any  Member  State  is 
transparent  and  open  to  all  EU  companies  on  the  basis  of  non-discrimination  and  equal 
treatment. 

Türkiye is moderately prepared in the area of public procurement but made no progress over 
the  reporting  period  and  large  gaps  remained  in  its  alignment  with  the  EU  acquis.  Türkiye 
continued  its  discriminatory  domestic  price  advantage  and  offset  practices  favouring  local 
content. The recommendations of the 2021 report were not implemented. 

In the coming year, Türkiye should in particular: 

70 

01020304020142015201620172018201920202021Graph 5.5a: Türkiye -Exports of goodsEUCEFTAOtherSource: WiiW% ofGDP01020304020142015201620172018201920202021Graph 5.5b: Türkiye -Imports of goodsEUCEFTAOtherSource: WiiW% ofGDP 
 
 
 
  revise  its  public  procurement  legislation  to  further  align  it  with  the  2014  EU  Directives  on 
public  procurement,  including  utilities,  concessions  and  public  private  partnerships  and  to 
increase transparency; 

  refrain  from  excessive  use  of  the  negotiation  procedure  that  limits  competition  and 

transparency; 

  repeal  exemptions  that  are  incompatible  with  the  EU  acquis  and  refrain  from  the 

discriminatory domestic price advantage and offset practices. 

Institutional set-up and legal alignment 

In  terms  of  the  legal  framework,  Türkiye's  national  public  procurement  legislation  broadly 
reflects  the  principles  of  the  Treaty  on  the  Functioning  of  the  European  Union.  However, 
compulsory  domestic  price  advantages  and  offsets  allow  authorities  to  demand  compensating 
measures if goods are not produced domestically, which is discriminatory and contradict the EU 
acquis. 

The  Public  Procurement  Law  (PPL)  is  partially  aligned  with  the  EU  Public  Procurement 
Directives  of  2014.  The  coverage  of  public  procurement  rules  is  limited  by  a  growing  list  of 
exclusions.  Additionally,  many  sector-specific  laws  limit  transparency.  The  use  of  the  State 
Supply Office for the procurement of goods and services is mandatory for public institutions and 
organisations.  The  implementation  of  this  mandatory  centralised  purchasing  system  practically 
also expands the scope of exclusions as the State Supply Office procurements under TRY 33.5 
million are exempt from the PPL. The thresholds are also higher than those used in the EU for 
supplies and services. 

Türkiye  still  lacks  a  unified  framework  for  coordinating,  supervising,  and  monitoring  public-
private partnership (PPP) operations. Türkiye needs to ensure a more consistent legal framework 
for concessions and PPP to increase transparency and efficiency. Furthermore, information with 
regard to the PPP contracts is not shared with the public in a transparent manner in order to avoid 
allegations of political influence on public tenders; this transparency would also ensure a better 
evaluation of contingent fiscal liabilities. 

Türkiye's Green Deal Action Plan, adopted in 2021, does not include strategies for transitioning 
to  green  procurement,  which  would  contribute  significantly  to  sustainable  consumption  and 
production.  
Türkiye's  11th  Development  Plan  (2019-2023)  aims  at  increasing  domestic  production, 
particularly  for  chemicals,  pharmaceuticals  and  medical  devices,  electronics,  machinery  and 
electrical  equipment,  automotive  and  railway  services  sectors,  by  means  of  using  public 
procurement as a subsidising tool. For such purpose, a compulsory domestic price advantage of 
up  to  15  %  remains  available  for  some  ‘medium  and  high-technology  industrial  products’  and 
offset  practices  are  encouraged.  The  percentage  of  international  tenders  where  domestic  price 
advantage is  applied is  high and has increased from  37 %  in  2017  to  45 %  in  2021, while the 
overall  value  of  such  tenders  increased  from  44  %  to  50  %  of  the  total  during  the  same 
timeframe.  A  domestic  price  advantage,  distorting  competition  against  international  tenderers, 
was applied in 63 % of supply, 40 % of work, 21 % of consultancy and 79 % of service tenders, 
corresponding to 46 %, 57 %, 33 % and 84 % of total value, respectively. 

The operational  independence of the Public Procurement Board within the Public Procurement 

71 

 
 
Authority  (PPA)  is  potentially  impaired  since  the  President  of  the  Republic  is  authorised  to 
directly  appoint  its  president  and  members  without  specific  regard  to  education  and  sector 
experience. 

Implementation and enforcement capacity 

The size of the public procurement market narrowed down from 7.5 % of GDP in 2017 to 3.3 % 
in 2019 but reversed its course by increasing marginally to 3.4 % in 2020 and further expanding 
to 4.1 % of GDP in 2021. 

Monitoring of the contract awards and implementation is satisfactory. The PPA issues statistics 
on a six-month basis, which allows for measuring performance and making improvements to the 
public  procurement  system.  The  capacity  of  contracting  authorities  to  manage  public 
procurement processes continued to improve. Electronic procurement expanded and reached 30 
198 tenders (17 359 in 2020). 

Mechanisms to identify and address corrupt and fraudulent practices are in place, including rules 
on  integrity  and  conflict  of  interest.  However,  the  use  of  the  negotiated  procedure  increased 
significantly in the last five years, corresponding to more than one fourth of all tenders (both in 
value  and  number).  When  using  this  procedure,  the  contracting  authorities  are  allowed  to 
exercise  discretion  in  certain  unforeseen  circumstances,  which  cannot  be  objectively  measured 
and limit competition and transparency independent of any threshold. In 2021, it was the case in 
90 % of the tenders (in value) where the negotiated procedure applied. Such a widespread use of 
this practice, which limits transparency and competition, led to allegations of political influence 
on  public  tenders.  Türkiye  needs  to  develop  instruments  to  evaluate  contract  performance  and 
benchmark the economy, effectiveness, and efficiency of public procurement procedures and of 
contract  management  by  an  individual  contracting  authority  or  entity.  Türkiye  should  also 
develop  a  risk  indicator  system  that  alerts  on  potential  integrity  problems  in  the  procurement 
process. 

Efficient remedy system 

The right to a legal remedy is secured in the Constitution and the PPL lays down the institutional 
set  up  and  mechanism  for  handling  complaints.  The  review  and  remedies  system  ensures  that 
complaints and sanctions are handled and resolved in an efficient, timely and competent manner. 
However,  further  alignment  with  the  EU  Remedies  Directive  is  required.  To  that  end,  Türkiye 
needs  to  establish  a  fully  independent  procurement  review  board,  separate  from  the  public 
procurement authority and ensure the independence of board members. 

The implementation capacity of the Public Procurement Board remains stable with 330 staff. The 
Public Procurement Board received 2 343 complaints in 2021 (3.25 % of contracts that allow for 
complaints), compared  with  2 316  complaints  in  2020, at  the time amounting to  3.53 % of the 
contracts. The appointment policy and the Board’s position as part of the PPA remained source 
of concern. A fully independent Public Procurement Board would eliminate potential conflicts of 
interest and increase transparency. 

Chapter 18: Statistics 

EU  rules  require  that  Member  States  are  able  to  produce  good  quality  statistics  in  line  with 
the  principles  of  the  European  statistics  Code  of  Practice  and  based  on  professional 
independence,  impartiality,  reliability,  transparency,  and  confidentiality.  Common  rules  are 
provided for the methodology, production and dissemination of statistical information. 

72 

 
 
Türkiye  is  moderately  prepared  in  the  area  of  statistics  and  made  limited  progress  in  the 
reporting  period.  Last  year’s  recommendations  were  implemented  to  a  limited  degree.  Türkiye 
continued efforts to further align with the EU acquis and improved in particular its compliance 
with  respect  to  the  timeliness  of  annual  national  accounts  and  its  adherence  to  the  excessive 
deficit  procedure  methodology.  However,  frequent  managerial  changes  within  the  Turkish 
Statistical  Institute  (TurkStat)  over  the  last  few  years,  including  in  the  reporting  period,  have 
significantly  undermined  the  institution’s  credibility.  The  reliability  of  key  economic  data  has 
been repeatedly called into question. 

In the coming year, Türkiye should in particular: 

 ensure the credibility of TurkStat as well as reliability and public trust in the macroeconomic 
statistics,  including  through  the  establishment  of  transparent,  professional  criteria  on  the 
appointment  of  the  president  of  TurkStat  and  of  the  causes  for  his/her  dismissal,  which 
cannot include reasons compromising professional or scientific independence;  

 step up efforts to fully align national accounts with the European System of Accounts 2010 

(ESA 2010); 

 improve statistics on agriculture, migration and asylum; 

 continue strengthening cooperation between TurkStat and other data providers. 

As  regards  statistical  infrastructure,  Türkiye’s  statistics  legislation  is  based  on  the  European 
Statistics  Code  of  Practice.  A  five-year  programme  of  the  official  statistics  (2022-2026)  was 
adopted  in  December  2021.  Efforts  continued  to  improve  the  use  of  public  institutions' 
administrative records and to strengthen the cooperation between the Turkish Statistical Institute 
(TurkStat)  and  other  data  providers.  New  alternative  data  collection  methods  were  adopted 
during  the  COVID-19  pandemic.  Registers  in  the  statistical  office  are  updated  regularly.  The 
main classifications are aligned with the EU acquis. 

TurkStat  is  an  associated  institution  to  the  Ministry  of  Treasury  and  Finance.  The  president  of 
TurkStat  replaced  the  Minister  of  Treasury  and  Finance  as  the  chair  of  the  Statistical  Council. 
However,  the  transparency  of  the  appointment  and  dismissal  procedures  within  TurkStat, 
including  of  its  president,  continue  to  raise  increasing  concerns.  The  frequent  managerial 
changes over the last few years, including in the reporting period, have significantly undermined 
the institution’s credibility.  

There  are  growing  concerns  about  the  reliability  of  key  macroeconomic  statistics.  Efforts 
continued  to  integrate  administrative  records  into  the  national  accounting  system.  Türkiye 
improved  the  timeliness  of  national  accounts  and  reported  these  accounts  for  most  output, 
expenditure  and  income  variables.  However,  Türkiye  did  not  provide  employment  data 
according to ESA 2010. Türkiye needs to ensure that GNI calculations are fully in line with ESA 
2010  as  well  as  update  its  GNI  inventory,  aligning  it  with  the  latest  Eurostat  GNI  Inventory 
Guide.  The  transmission  of  the  quarterly  national  accounts  is  still  incomplete.  Türkiye 
transmitted  almost  complete  non-financial  sector  accounts  for  2009-2020.  The  last  excessive 
deficit  procedure  (EDP)  notification  tables  were  provided  in  April  2022.  Türkiye  made  some 
progress in the implementation of Eurostat’s methodology guidance, the provision of extensive 
explanatory  notes  on  the  data  and  the  delimitation  of  the  general  government  sector.  Further 
efforts are still required to improve timeliness and quality of the transmission of excessive deficit 
procedure  notification  and  government  finance  statistics.  Türkiye  produces  highly  compliant 

73 

 
 
statistics  on  international  trade  in  goods.  It  continued  reporting  quarterly  balance  of  payments 
and international investment position data. Monthly data for the harmonised index of consumer 
prices were provided. 

Türkiye  continues  extending  the  use  of  administrative  data  in  the  production  of  business 
statistics. Short-term  business  statistics are partly  aligned. Research and development  statistics 
are  highly  compliant,  although  Türkiye  did  not  provide  data  for  2020.  The  annual  surveys  on 
information and communication technology meet EU standards to a large extent. Rail, maritime 
and  regional  transport  statistics  are  highly  compliant,  while  progress  is  needed  on  road  freight 
data.  Tourism  statistics  need  to  be  further  aligned  with  the  EU  acquis.  No  data  has  been 
transmitted to Eurostat yet on foreign affiliates statistics. 

As for social statistics, the results of the 2021 combined population census, prepared mostly on 
the  basis  of  administrative  registers,  were  partially  released.  The  survey  on  income  and  living 
conditions is carried out in compliance with EU standards and data are sent to Eurostat. Social 
protection statistics are highly compliant with EU standards and labour market statistics are fully 
aligned. TurkStat is yet to provide Eurostat with labour force survey (LFS) data in line with the 
new  acquis.  Monthly  results  started  to  be  estimated  directly  from  LFS.  However,  the 
transmission of monthly unemployment rate to Eurostat became irregular during 2021. Türkiye 
provides  regularly  data  for  the  labour  cost  index,  albeit  incomplete.  The  Structure  of  Earnings 
Survey  is  conducted  every  four  years,  in  compliance  with  EU  legislation.  In  August  2021, 
Türkiye  started  to  transmit  quarterly  data  for  job  vacancy  survey.  Statistics  on  education  and 
vocational  training  are  available.  Public  health  statistics  are  available,  but  further  progress  is 
needed  on  data  in  the  area  of  health  expenditure  and  non-monetary  healthcare.  Some  data  is 
provided regarding the functioning of the justice system and prison statistics. Türkiye is regularly 
invited to contribute to the data collections on international immigration and emigration statistics 
to Eurostat but so far it has not sent such statistics.  

No  agricultural  statistics  census  has  been  carried  out  since  2001.  Statistics  for  crop  and  for 
most of the  critical  animal  production, milk  and  dairy  are  available. Supply balance sheets  are 
also available for most basic crop products and wine. The economic accounts for agriculture are 
still not fully compliant with the EU acquis. The 2016 farm structure survey results have still not 
been transmitted to the Eurofarm system. 

Energy  statistics  are  mostly  compliant  with  the  EU  requirements.  Traditional  monthly  and 
annual  energy  statistics  are  transmitted  regularly.  Some  recently  introduced  annual  data 
collections are not transmitted to Eurostat. Energy prices data are regularly sent in good quality 
to Eurostat. As for environmental statistics, waste and water statistics are produced, but further 
progress  is  still  needed  on  water  resources,  water  abstraction  and  waste  generation  statistics. 
Statistics related to greenhouse gas emission, environmental taxes, material flow, environmental 
protection expenditure accounts are available. 

Chapter 32: Financial control 

The  EU  promotes  the  reform  of  national  governance  systems  to  improve  managerial 
accountability,  sound  financial  management  of  income  and  expenditure,  and  external  audit  of 
public  funds.  The  financial  control  rules  further  protect  the  EU’s  financial  interests  against 
fraud in the management of EU funds and the euro against counterfeiting. 

Türkiye has a good level of preparation on financial control. No progress was made during the 

74 

 
 
reporting  period.  The  Public  Internal  Financial  Control  policy  paper  has  not  yet  been  updated. 
The  anti-fraud  coordination  service  (AFCOS)  network  has  not  yet  been  re-established.  The 
purpose,  authority  and  responsibility  of  internal  audit  is  undermined  by  the  absence  of  a  legal 
requirement  to  have  internal  audit  units  in  Ministries.  Last  year’s  recommendations  were  not 
addressed. In the coming year, Türkiye should in particular: 

  organise  a  new  Public  Expenditures  and  Financial  Accountability  (PEFA)  exercise  to 
facilitate the preparation of a comprehensive public financial management strategy and update 
the Public Internal Financial Control policy paper and its action plan; 

 re-establish the AFCOS network and adopt a national anti-fraud strategy; 

 reconsider the arrangements that would include municipalities and state-owned enterprises in 

the treasury single account. 

Public internal financial control (PIFC) 

The strategic framework is partially in place. The update of the Public Internal Financial Control 
policy  paper  has  not  made  progress  since  2012.  Türkiye  still  lacks  a  comprehensive  strategic 
framework for public administration reform and for public finance management. Public finance 
management related goals are found in different planning documents and strategies, and there is 
no  mechanism  in  place  to  coordinate  implementation  of  reforms  and  to  ensure  regular 
monitoring and reporting.  

The  Turkish  administration  has  a  uniform  management  structure  that  combines  elements  of 
managerial  accountability  and  delegation  with  a  results-oriented  performance  management 
system.  The  Public  Financial  Management  and  Control  (PFMC)  Law  applies  to  all  public 
institutions and defines the elements of financial control. It sets out the relevant responsibilities 
of the heads of public institutions, including managerial duties and the delegation of authority to 
authorising  officers,  with  the  Ministry  of  Finance  and  Treasury  assigned  a  coordinating  role. 
Further  efforts  are  needed  to  address  harmonisation  of  legislation,  managerial  accountability, 
including reporting structures, delegation of decision-making responsibilities, and functioning of 
internal  control.  The use of PFM diagnostic tools such as PEFA could  help  identify better and 
address current gaps in PFMC law implementation. 

The  PFMC  Law  regulates  internal  control,  which  functions  largely  in  line  with  international 
standards. Full implementation  of internal  control systems  continues to  be negatively impacted 
by  capacity  and  ownership  issues.  Work  in  the  area  of  application  of  risk  management  should 
continue. Monitoring and reporting of irregularities are yet to be further developed. Türkiye has a 
treasury  single  account,  but  the  inclusion  of  local  administrations  and  state-  owned  enterprises 
within its scope raises concerns. 

Internal audit practice is regulated in line with international standards in the PFMC Law. An 
internal audit manual and a code of ethics are in place, as are manuals prepared  by the Central 
Harmonisation  Unit,  but  they  have  not  been  updated  since  2013.  Secondary  legislation  on 
Working Procedures and Principles of Internal audit was adopted and efforts have been made to 
increase the number of internal auditors and in the provision of trainings. However, there is no 
legal requirement for ministries to have an internal audit unit, just internal auditors, and there is 
no formal status for heads of internal audit as a unit head. There is no entity performing the role 
of an audit committee and auditors report directly to their deputy ministers or a senior manager. 
These  reporting  arrangements  could  compromise  auditors’  independence  in  planning  and 

75 

 
 
performing  their  work.  There  is  generally  a  lack  of  data  on  internal  audit  planning  and 
implementation of recommendations. There is no systematic follow-up of the implementation of 
internal audit recommendations. The existing lack of clarity in the legislation and in the practice 
between the internal audit and inspection organisations do compromise the effectiveness of the 
internal audit function. 

Two Central Harmonisation Units (CHUs) are tasked with setting standards, monitoring and 
reporting  on  PIFC  implementation.  The  CHU  for  financial  management  and  control  defines 
standards  and  methodology,  provides  guidance,  training  and  overall  coordination  to  public 
administrations in this field, and does not perform internal control quality reviews. The Internal 
Audit  Coordination  Board  is  the  CHU  for  internal  audit,  which  notably  monitors  the  internal 
audit  systems  of  the  public  administrations,  develops  internal  audit  standards  and  publishes 
manuals.  The  CHU  for  internal  audit  has  prepared  a  draft  guide  on  Internal  Control  Quality 
Reviews  and  completed  pilot  implementation  in  one  public  administration.  The  Internal  Audit 
Coordination Board consists of seven members appointed by the President for a period of four 
years and is now fully attached to the Ministry of Finance and Treasury. Efforts should be made 
to ensure its independence and to strengthen its  capacity, organisational structure and adequate 
resources to fulfil its mandate. 

External audit 

The constitutional and legal framework provides for the independence of the Turkish Court of 
Accounts  (TCA).  The  TCA  law  is  in  line  with  International  Organisation  of  Supreme  Audit 
Institutions (INTOSAI) standards. It provides for an almost exhaustive audit mandate and gives 
the TCA full discretion in discharging its responsibilities. Concerns exist around fiscal discipline, 
transparency  and  accountability  in  relation  to  the  Türkiye  Wealth  Fund  (TWF),  chaired  by  the 
President of the Republic and not fully subject to the direct audit by the TCA. Some companies 
in the TWF portfolio are audited by the TCA and some TWF activities are not subject to external 
audit.  The  TWF  is  audited  by  an  independent  audit  firm  and  by  auditors  appointed  by  the 
President.  Audit  reports  of  the  TWF  are  submitted  to  the  Plan  and  Budget  Committee  of  the 
Parliament. Last year’s audit report was not published on the TWF website. There are no notes 
accompanying the financial statements, which may raise concerns in terms of full transparency. 
Concerns  remain  also  in  relation  to  the  TWF  legal  framework,  scope  and  operations.  Recent 
amendments  to  the  Law  on  the  Establishment  of  the  Türkiye  Wealth  Fund  Management 
Company (TWFMC) introduced exemptions and exceptions. These new elements will apply to 
companies,  funds  and  their  subsidiaries  of  which  the  TWF  or  the  TWFMC  will  become  the 
controlling  shareholder.  Furthermore,  the  key  role  the  TWF  will  play  in  the  Istanbul  Financial 
Centre  (IFC)  also  raises  concerns  about  the  IFC  operations  and  management.  They  will  be 
carried out by a managing company of the TWF that will not be accountable to the TCA. 

The TCA has both audit and judicial functions. In 2021, it had 1 920 staff, including 865 auditors 
in comparison to 1 874 staff in 2020, of which 830 were auditors. The TCA is implementing its 
2019-2023  Strategic  Plan  which  notably  foresees  the  development  of  risk-based  audit  and 
strengthening  its  human  resources  capacity.  It  has  updated  its  manuals  for  public  enterprises 
audit, performance audit, audit reporting and local government companies’ audit.  

The  TCA  has  improved  the  quality  of  audit  work  and  now  carries  out  “value  for  money” 
performance audits as per international standards (3 were completed in 2021) and published on 
TCA  website.  The  TCA  annually  submits  four  audit  reports  to  the  Parliament  (External  Audit 

76 

 
 
General  Evaluation  Report,  Accountability  General  Evaluation  Report,  Financial  Statistics 
Evaluation Report, and Report on State-owned Economic Enterprises) in addition to a statement 
of general conformity. The reports of the TCA are only considered by the Parliament during its 
deliberations on the budget. 

Regarding  the  impact  of  audit  work,  the  TCA  assesses  the  internal  control  environment  of 
audited entities as  part of its audit work,  and thus  contributes to  PIFC development.  The TCA 
reports on state-owned enterprises are analysed by the commission of state-owned enterprises of 
the Parliament, while other audit reports are analysed by the Parliament committee on planning 
and  budget.  The  TCA  reports  are  published  online  every  year,  with  the  exception  of  those  on 
state-owned economic enterprises. TCA recommendations should be systematically and swiftly 
implemented by the audited institutions. A working group between the TCA and the Ministry of 
Treasury and Finance is operational. Increased parliamentary scrutiny on TCA audit findings and 
recommendations is still needed. There is a need for separating discussion on budget and audit 
issues.  The  establishment  of  a  working  group  between  the  TCA  and  the  Parliament  solely 
dedicated to discuss performance of public institutions and their spending could be instrumental 
in this regard. 

Protection of the EU’s financial interests 

While Türkiye has reached a good level of EU acquis alignment, it still needs to fully align its 
legislation with the EU Directive on the fight against fraud to the Union’s financial interests by 
means of criminal law. The State Supervisory Council (SSC) was designated as the  anti-fraud 
coordination  service  (AFCOS),  but  an  AFCOS  network,  involving  other  relevant  authorities, 
has yet to be re-established. Türkiye also needs to adopt a national anti-fraud strategy. Türkiye 
reported 740 cases to the Commission via the online irregularity management system from 2006 
to 2021, of which 67 cases in 2021. Türkiye should significantly strengthen its track record on 
cooperation  with  the  European  Commission  during  investigations,  and  continue  to  report 
irregularities and suspected fraud cases.  

Protection of the euro against counterfeiting 

Türkiye  has  reached  a  high  level  of  EU  acquis  alignment  in  this  area.  Technical  analysis  of 
counterfeit money, including euro banknotes and coins, is carried out by a dedicated department 
in the central bank and technical analysis of counterfeit coins including euro coins are performed 
by the Turkish State Mint. Credit institutions that do not withdraw counterfeits from circulation 
are subject to financial penalties. In the past, Türkiye participated in a few actions of the Pericles 
2020 programme. 

3. GOOD NEIGHBOURLY RELATIONS AND REGIONAL COOPERATION 

Cyprus 

While  there  were  no  unauthorised  drilling  activities  by  Türkiye  in  the  Eastern  Mediterranean 
during  the  reporting  period,  tensions  have  been  rising.  In  October  2021  and  January  2022, 
Turkish warships obstructed the survey activity in the Cypriot Exclusive Economic Zone (EEZ). 
Throughout  the  reporting  period,  Türkiye  issued  many  Navigational  Telexes  (NAVTEX)  for 
conducting seismic surveys and scientific research activities in areas encompassing parts of the 
Cypriot EEZ. Türkiye’s military exercises in the maritime zones of Cyprus continued. Violations 

77 

 
 
 
by  Turkish  military  aircrafts  and  unmanned  aerial  vehicles  in  the  Nicosia  flight  information 
region and the national airspace of the Republic of Cyprus also continued unabated. The Ercan 
(Tymbou)  airport,  which  is  not  recognised  by  the  International  Civil  Aviation  Organisation 
(ICAO),  was  designated  as  a  domestic  Turkish  airport  in  June  2022.  Türkiye  continued  to 
increase  the  militarisation  of  the  occupied  area  by  upgrading  the  military  drone  base  in 
Lefkoniko and the naval base in Bogazi. The harassment of Cypriot fishing vessels by Türkiye 
also continued. 

In November 2021, following the second review of the framework for restrictive measures, the 
Council  extended  the  regime  for  one  more  year  until  12  November  2022.  Currently,  two 
individuals are subject to sanctions.  

The EU remains fully committed to the comprehensive settlement of the Cyprus problem on the 
basis of a bicommunal, bizonal federation with political equality, in accordance with the relevant 
UN Security Council Resolutions and in line with the EU acquis and the principles on which the 
EU  is  founded.  The  European  Union  would  continue  to  play  an  active  role  in  supporting  the 
process. However, Türkiye repeatedly advocated for a two-state solution in Cyprus, contrary to 
relevant UN Security Council Resolutions.  

Despite  international  condemnations,  and  the  inadmissibility  of  the  settlement  of  any  parts  of 
Varosha  by  people  other  than  its  inhabitants  as  stipulated  in  UNSC  resolution  550  (1984), 
Türkiye continued with its plan to open the entire fenced-off area of Varosha, creating a new fait 
accompli  on  the  ground.  To  that  end,  within  the  fenced-off  area,  roadworks  and  construction 
works  continued  along  the  line  of  the  entire  beachfront  as  well  as  the  setting  up  of  a  camera 
surveillance system. A new section was also opened within the beachfront of the fenced-off area 
of Varosha. Following renovation works, the Bilal Aga Mosque, the Pertev Paşa Mausoleum and 
the Cypriot National Garden were opened. New barriers and checkpoints for access control were 
installed  and  the  Turkish  military  took  up  a  defensive  military  posture  in  the  area.  During  the 
reporting  period,  additional  restrictions  were  imposed  on  the  activities  of  the  United  Nations 
peacekeeping  force  in  Cyprus  (UNFICYP)  within  the  fenced-off  area  of  Varosha,  challenging 
UNFICYP’s ability to exercise its tasks in accordance with its mandate and in violation of UNSC 
Resolution  789  (1992).  These  developments  continued  to  undermine  the  prospect  of  resuming 
negotiations and reaching a comprehensive settlement of the Cyprus problem. 

As emphasised in the Negotiating Framework and Council declarations, Türkiye is expected to 
actively  support  the  negotiations  on  a  fair,  comprehensive  and  viable  settlement  of  the  Cyprus 
issue within the UN framework, in accordance with the relevant UN Security Council resolutions 
and in line with the principles on which the EU is founded and the EU acquis. It is important that 
Türkiye  reaffirms  its  commitment  to  the  UN-led  settlement  talks  on  Cyprus  in  line  with  the 
relevant UN Security Council Resolutions, including in its external aspects. No unilateral actions 
should  be  taken  that  could  raise  tensions  on  the  island  and  undermine  a  return  to  talks.  On 
Varosha,  Türkiye  must  immediately  reverse  the  unilateral  actions  announced  on  20  July  2021 
and  all  steps  taken  since  October  2020  that  run  contrary  to  relevant  UN  Security  Council 
resolutions. The EU underlines the importance of the status of Varosha and calls for full respect 
of UN Security Council Resolutions, in particular Resolutions 550, 789 and 1251. 

Türkiye continued to refuse to recognise the Republic of Cyprus. Despite repeated calls by the 
Council and the Commission, Türkiye has still not complied with its obligations as outlined in 
the Declaration of the European Community and its Member States of 21 September 2005 and in 

78 

 
 
Council Conclusions,  including those of December 2006  and December 2015. Türkiye has not 
fulfilled its obligation to ensure the full and non-discriminatory implementation of the Additional 
Protocol to the Association Agreement and has not removed all obstacles to the free movement 
of goods, including restrictions on direct transport links with the Republic of Cyprus. 

Türkiye  continued  to  veto  applications  by  the  Republic  of  Cyprus  to  join  several  international 
organisations, including the Organisation for Economic Co-operation and Development (OECD). 

Peaceful settlement of border disputes 

The  improved  dynamic  in  EU-Türkiye  relations  observed  since  December  2020,  following  the 
de-escalation  in  the Eastern Mediterranean, prevailed for several  months before tensions  in  the 
Aegean resumed in April 2022. Greece and Türkiye held the 64th round of exploratory talks in 
February  2022,  providing  a  valuable  channel  of  communication  between  the  sides  to  find 
common ground for the start of negotiations on the delimitation of the continental shelf. These 
direct  talks  should  continue  as  a  matter  of  priority.  The  Greek  Prime  Minister  and  Turkish 
President met on 13 March 2022 in Istanbul and agreed to build a positive agenda. However, the 
Turkish President has refused to hold talks with the Greek Prime Minister as of 23 May 2022 and 
has stated that the Greek-Turkish  High  Level  Cooperation Council scheduled for autumn 2022 
would not take place.  

The possible extension of Greek territorial waters to 12 nautical miles in the Aegean Sea under 
Article 3 of the United Nations Convention on the Law of the Sea continued to weigh on Greece-
Türkiye  relations,  as  the  1995  declaration  of  the  Turkish  Grand  National  Assembly,  that  any 
unilateral action by Greece to extend its territorial waters would be considered  casus belli, still 
holds.  

Greece  and  Cyprus  continued  to  report  on  Türkiye’s  militarisation  and  repeated  violations  of 
their  territorial  waters  and  airspace.  Relations  with  Greece  deteriorated  as  of  April  2022, 
following  massive  and  repeated  violations  of  Greek  airspace  by  Turkish  fighter  jets  and 
unmanned aerial vehicles in the Aegean, including a large number of flights over inhabited areas, 
as well as threatening Turkish statements regarding the sovereignty of Greek islands.  

In  its  conclusions  of  June  2022,  the  European  Council  expressed  deep  concern  about  recent 
repeated actions and statements by Türkiye. Türkiye must respect the sovereignty and territorial 
integrity  of  all  EU  Member  States.  Recalling  its  previous  conclusions  and  the  statement  of  25 
March  2021,  the  European  Council  expected  Türkiye  to  fully  respect  international  law,  to  de-
escalate tensions in the interest of regional stability in the Eastern Mediterranean, and to promote 
good neighbourly relations in a sustainable way. 

As highlighted by the Council, and most recently in the European Council conclusions of June 
2022, and stemming from obligations under the Negotiating Framework, Türkiye is expected to 
unequivocally  commit  to  good  neighbourly  relations,  international  agreements  and  to  the 
peaceful  settlement  of  disputes  having  recourse,  if  necessary,  to  the  International  Court  of 
Justice.  Türkiye  must  avoid  threats  and  actions  that  damage  good  neighbourly  relations, 
normalise  its  relations  with  the  Republic  of  Cyprus  and  respect  the  sovereignty  of  all  EU 
Member  States  over  their  territorial  sea  and  airspace  as  well  as  all  their  sovereign  rights, 
including inter alia the right to explore and exploit natural resources, in accordance with EU and 
international law, in particular the United Nations Convention on the Law of the Sea (UNCLOS).  

79 

 
 
The bilateral Memorandum of Understanding on the delimitation of maritime jurisdiction areas 
between  Türkiye  and  the  National  Accord  Government  of  Libya  signed  in  November  2019 
remained in place, despite the fact that it ignores Greece’s sovereign rights in the area concerned, 
infringes  upon  the  sovereign  rights  of  third  States,  does  not  comply  with  the  United  Nations 
Convention on the Law of the Sea and cannot produce any legal consequences for third States.  

Regional cooperation 

Good  neighbourly  relations  form  an  essential  part  of  Türkiye’s  accession  process.  Bilateral 
relations  with  other  enlargement  countries  were  generally  good  but  remained  challenging  with 
neighbouring EU Member States, particularly  Greece and Cyprus.  Tensions in  the Aegean Sea 
and  Eastern  Mediterranean  were  not  conducive  to  good  neighbourly  relations  and  undermined 
regional stability and security. 

Türkiye’s policy in the Western Balkans is generally aligned with the EU’s strategic objectives 
of  regional  stability,  Euro-Atlantic  integration  and  economic  development.  Türkiye  portrays 
itself as an EU partner in the region while leveraging its distinctive cultural and economic ties. 
During  the  reporting  period,  Türkiye  maintained  good  relations  with  all  Western  Balkan 
countries  and  nurtured  its  image  as  a  good  and  honest  partner.  Türkiye  continued  to  ask  for 
action against the presence of alleged members of the Gülen movement in the region and asked 
their extradition and the closure of all schools linked to this movement. This has caused tensions 
with some countries. 

Türkiye’s relations with Albania were strengthened with the Turkish President’s official visit in 
January 2022, as the two countries agreed to bring their bilateral relations to the level of strategic 
partnership.  The  two  leaders  held  regular  exchanges  and  the  Albanian  Prime  Minister  visited 
Türkiye in August 2022 at the occasion of the 5th Islamic Solidarity Games. 

Türkiye  remains  close  to  Bosnia  and  Herzegovina  and  its  President  visited  the  country  in 
August 2021. Türkiye maintains regular contacts with all members of Bosnia and Herzegovina’s 
tripartite  presidency,  keeping  a  balanced  approach  and  supporting  the  country’s  territorial 
integrity  and  stability.  Türkiye  supports  the  Office  of  the  High  Representative.  The  two 
countries  signed  a  cooperation  agreement  on  the  construction  of  the  Bosnian  stretch  of  the 
Sarajevo-Belgrade  highway,  the  largest  integrated  infrastructure  project  in  Bosnia  and 
Herzegovina. 

Türkiye’s  relations  with  Serbia  have  been  improving  significantly  in  all  fields.  The  two 
Presidents  maintain frequent  contacts; the Serbian President  paid  an official  visit to  Türkiye in 
January  2022  and  co-chaired  the  third  meeting  of  the  Türkiye-Serbia  High-Level  Cooperation 
Council. 

Türkiye  has  strong  cultural  and  economic  ties  with  Kosovo    and  continued  to  lobby  for  its 
recognition. High-level bilateral meetings took place in the margins of the South-East European 
Cooperation  Process  (SEECP)  Summit  in  June  2021  and  Kosovo’s  President  paid  an  official 
visit to Türkiye in February 2022. 

Türkiye’s  relations  with  Montenegro  are  stable  aiming  at  developing  further  their  bilateral 
cooperation. The Turkish President visited the country in August 2021. 

  This  designation  is  without  prejudice  to  positions  on  status,  and  is  in  line  with  UNSCR  1244/1999  and  the  ICJ 
Opinion on the Kosovo declaration of independence. 

80 

 
 
                                                           
Türkiye  and  North  Macedonia  continue  to  engage  actively,  in  the  economic,  educational  and 
cultural sectors.  

4. 

ABILITY TO ASSUME THE OBLIGATIONS OF MEMBERSHIP  

CLUSTER 2: INTERNAL MARKET  

This  cluster  covers:  free  movement  of  goods  (Chapter  1),  freedom  of  movement  for  workers 
(Chapter 2), right of establishment and freedom to provide services (Chapter 3), free movement 
of  capital  (Chapter  4),  company  law  (Chapter  6),  intellectual  property  law  (Chapter  7), 
competition  policy  (Chapter  8),  financial  services  (Chapter  9),  and  health  and  consumer 
protection (Chapter 28). This cluster is key to the good functioning of the EU-Turkey Customs 
Union and to integrating Türkiye into the EU’s single market. 

Preparations  in  the  areas  of  freedom  of  movement  for  workers  and  right  of  establishment  and 
freedom to provide services are at an early stage as many professions are closed to EU nationals. 
Türkiye  has  achieved  a  good  level  of  preparation  for  the  free  movement  of  goods.  Technical 
barriers to trade remained in place. Türkiye is moderately prepared on free movement of capital, 
as  limitations  continue  on  foreign  ownership  and  on  capital  movement.  Türkiye  needs  to 
continue  to  address  outstanding  issues  in  its  framework  regulating  the  fight  against  money 
laundering and terrorist financing, but needs to ensure that implementation does not restrict the 
legitimate rights of NGOs.  

Türkiye  is  well  advanced  in  the  area  of  company  law  but  needs  to  make  further  progress  in 
aligning with the EU acquis. Türkiye has a good level of preparation in the area of intellectual 
property  law  but  needs  to  improve  enforcement.  Türkiye  has  some  level  of  preparation  in  the 
area  of  competition  policy.  Serious  concerns  persist  in  relation  to  the  legislative  framework, 
enforcement  capacity  and  transparency  in  the  field  of  State  aid.  Türkiye  has  a  good  level  of 
preparation  in  the  area  of  financial  services  and  made  some  progress,  including  with  the 
development  of  new  alternative  financing  instruments.  There  is  a  good  level  of  preparation  in 
terms  of  legislative  alignment  of  consumer  and  health  protection,  with  some  progress  made, 
notably on aligning with the EU acquis and in strengthening inter-sectoral cooperation. 

Chapter 1: Free movement of goods 

The  free  movement  of  goods  ensures  that  many  products  can  be  traded  freely  across  the  EU 
based  on  common  rules  and  procedures.  Where  products  are  governed  by  national  rules,  the 
principle  of  the  free  movement  of  goods  prevents  these  from  creating  unjustified  barriers  to 
trade. 

Türkiye  has  achieved  a  good  level  of  preparation  for  the  free  movement  of  goods.  It  made 
limited  progress  in  addressing  last  year’s  recommendations.  Alignment  with  the  EU  acquis 
under  the  “Old  Approach”  continued  and  there  were  limited  developments  in  the  “New  and 
Global  Approach”.  However,  technical  barriers  to  trade  remained  in  place.  Although  Türkiye 
decreased its product safety controls under its risk-based import control system as compared to 
last  year,  there  were  still  unjustified  checks  and  delays  in  EU  products’  access  to  the  Turkish 
market,  and  new  barriers  to  trade  were  put  in  place.  Requirements  discriminating  against  EU 
products remained, violating Türkiye’s obligations under the Customs Union. 

In the coming period, Türkiye should in particular: 

  eliminate  non-tariff  barriers  to  the  free  movement  of  goods  that  are  in  breach  of  Customs 

81 

 
 
Union  obligations,  such  as  surveillance  regimes  for  the  import  of  certain  products,  export 
restrictions, prior registration requirements, conformity assessments and inspections, licensing 
surveillance  and  other  documentation  requirements  for  imports,  and  non-  acceptance  of  EU 
good manufacturing practices certificates; 

  reconsider  schemes  imposing  local  content  requirements  or  relocation  of  production 

particularly in the area of medicines for human use; 

 increase the coverage and effectiveness of market surveillance measures. 

General principles  

The framework for the free movement of goods largely remains in place in Türkiye. However, 
implementation issues still remained, as Türkiye still had a range of non-tariff barriers to the free 
movement  of  goods  in  place  that  are  in  breach  of  Customs  Union  obligations,  and  some  were 
introduced in the reporting period. These include surveillance regimes for the import of certain 
products,  export  restrictions,  prior  registration  requirements,  conformity  assessments  and 
inspections  under  the  risk-based  import  control  system,  licensing  surveillance  and  other 
documentation  requirements,  as  well  as  non-acceptance  of  EU  good  manufacturing  practices 
certificates  and  discrimination  against  EU  products.  Furthermore,  schemes  to  ensure  the  local 
manufacture or local content requirements create de facto market access barriers for EU products 
and  are  considered  not  in  line  with  the  Customs  Union.  Türkiye’s  product  safety  controls  on 
imported  goods  processed  through  the  electronic  TAREKS  system  may  require  additional 
documentation  and  information  for  products  coming  from  the  EU,  contrary  to  the  Customs 
Union provisions. 

Non-harmonised area 

Türkiye’s legal framework on mutual recognition in the non-harmonised area is in line with the 
EU  acquis.  Türkiye  has  notified  only  three  product  legal  act  in  the  non-harmonised  area  as  of 
2022. However,  given the size of Türkiye’s economy and  legislative  activity and link with  the 
European Union under the Customs Union, this is insufficient.   

Harmonised area: quality infrastructure 

Türkiye  is  aligned  with  the  EU  acquis  on  technical  regulations,  standards,  conformity 
assessment, accreditation, metrology, and market surveillance. Implementing regulations are also 
in place regarding general product safety, the European Conformity mark (CE mark), conformity 
assessment bodies, notified bodies and conformity assessment methods.  

for  Standardisation 

The  Turkish  Standards  Institute  is  independent  and  able  to  implement  European  and 
international standards, and has adequate staff resources and financing. It is a full member of the 
European  Committee 
for 
Electrotechnical Standardisation (CENELEC) since 2012. By April 2022, it had adopted 22 792 
national  standards  aligned  with  European  standards.  The  rate  of  harmonisation  with  CEN  and 
CENELEC  standards  continued  at  99  %  and  96  %,  respectively.  Seven  Turkish  economic 
operators are full members of the European Telecommunications Standards Institute (ETSI) and 
one is an observer. 

the  European  Committee 

(CEN)  and 

Türkiye had 55 notified bodies, two technical approval bodies and five recognised third- party 
organisations  in  place  as  of  June  2022.  The  Turkish  Accreditation  Agency  (TÜRKAK)  is  a 
signatory of all ten multilateral agreements as part of the European cooperation for Accreditation 

82 

 
 
association  and  takes  part  in  the  mutual  recognition  of  data  agreement  (MAD)  of  the  OECD 
Good  Laboratory  Practices  Working  Group  (OECD-GLP).  The  National  Metrology  Institute 
(TÜBITAK-UME)  is  a  member  of  the  European  Association  of  National  Metrology  Institutes 
(EURAMET). TÜBİTAK-UME chairs a Technical Committee and participates in the Committee 
of  the  European  Metrology  Programme  for  Innovation  and  Research  (EMPIR)  at  EURAMET. 
The  Ministry  of  Industry  and  Technology  participates  in  the  European  Legal  Metrology 
Organisation (WELMEC). 

Türkiye  performs  market  surveillance  in  line  with  the  EU  acquis  and  submits  its  annual 
programme  to  the  European  Commission.  Türkiye  adopted  a  new  framework  regulation  on 
market surveillance in July 2021 as part of the implementing regulations of the Product Safety 
and  Technical  Regulations  Law.  According  to  the  annual  market  surveillance  report  of  the 
Ministry of Trade for 2021, the overall budget allocated to market surveillance increased by 103 
% in 2021 as compared to 2020 in a high inflation environment. Yet, there was a decrease of 33 
% in the number of active market surveillance inspectors. There was an increase of 12 % in the 
number of products subject to market surveillance checks in 2021 as compared to 2020. Market 
surveillance  is  not  performed  on  the  basis  of  risk  assessment  as  the  number  of  non-safety 
findings  remains  low  particularly  amongst  the  products  tested.  Surveillance  remained  limited 
with  regard  to  e-commerce,  while  the  volume  of  online  shopping  increased.  The  Ministry  of 
Trade’s  market  surveillance  report  for  2021  reveals  that  administrative  fines  and  measures  are 
not  consistently  applied  on  unsafe  products.  This  raises  concerns  about  the  enforcement  of 
product safety legislation. 

Harmonised area: sectoral legislation 

On  the  ‘new  and  global  approach’  product  legislation,  Türkiye  adopted  legislation  to  align 
with the EU acquis on lifts. 

On  ‘old  approach’  product  legislation,  Türkiye  adopted  new  legislation  to  align  with  EU 
acquis  on  aerosol  dispensers,  medicinal  products  licensing,  medicinal  products  for  human  use, 
and  on  non-road  mobile  machinery.  Türkiye  also  adopted  amending  legislation  on  motor 
vehicles, cosmetics, biocidal products and metrology mostly updating the provisions and/or the 
technical annexes of the related legislation to align with updates in the EU acquis. Problems on 
the  implementation  of  the  EU  acquis  on  cosmetics  due  to  specific  Turkish  requirements  were 
largely  solved,  apart  from  the  complex  barcode  requirements  for  the  national  product  tracking 
system. Turkish legislation on cosmetics is not yet aligned with the EU acquis. Türkiye does not 
accept  EU  good  manufacturing  practice  (GMP)  certificates  on  medicines  for  human  use,  in 
contradiction  to  the  rules  of  the  Customs  Union,  though  it  has  assessed  the  GMP  dossiers  of 
priority  medicines  submitted  for  licensing  applications  without  an  on-site  visit  under  certain 
conditions.  Türkiye  continued  to  implement  schemes  imposing  the  requirement  of  local 
manufacturing  on  medicines  for  human  use  and  on  agricultural  and  forestry  tractors,  which 
create market access barriers for EU products. The European Chemicals Agency (ECHA)’s 2021 
study  on  readiness  to  implement  the  EU  acquis  on  chemicals  assessed  that  Türkiye  is  almost 
fully  aligned  with  the  European  Regulation  on  Registration,  Evaluation,  Authorisation  and 
Restriction  of  Chemicals  (REACH),  but  needs  to  further  align  with  the  EU  acquis  on  biocidal 
products.  

On  procedural  measures,  specific  licensing  and  regulation  system  are  in  place  for  economic 
operators  dealing  with  drug  precursors,  with  a  strict  follow-up  and  monitoring  system  in 

83 

 
 
cooperation  with  the  police  and  customs  authorities.  Türkiye  is  aligned  with  the  EU  acquis 
regarding licensing procedures for  firearms. There was no progress on alignment with the EU 
acquis on cultural goods. 

Chapter 2: Freedom of movement for workers 

Citizens of one Member State have the right to work in another Member State and must be given 
the same working and social conditions as other workers. 

Preparations in the area of freedom of movement for workers are at an early stage and there was 
no progress during the reporting period. 

There  was  no  progress  on  access  to  the  labour  market  or  coordination  of  social  security 
systems. So far, Türkiye has concluded 15 bilateral social security agreements with EU Member 
States, but no new bilateral social security agreements were signed during the reporting period. A 
new regulation on the implementation of the law on international labour force was published in 
February 2022. 

Chapter 3: Right of establishment and freedom to provide services 

EU natural and legal persons have the right to establish themselves in any Member State and to 
provide  cross-border  services.  For  certain  regulated  professions,  there  are  rules  on  mutual 
recognition of qualifications. Postal services are gradually being opened up to competition. 

Preparations in the area of right of establishment and freedom to provide services are at an early 
stage.  There  was  no  progress  in  the  reporting  period.  Substantial  efforts  are  still  required  to 
align with the EU acquis. There was no implementation of the 2021 Report's recommendations, 
which remain valid. 

In the coming year, Türkiye should in particular: 

align with the Services Directive on the provision of cross-border services and set up a Point 

of Single Contact; 

align with EU acquis in the area of postal services; 

align  its  national  legislation  with  the  EU  acquis  in  the  area  of  the  mutual  recognition  of 

professional qualifications. 

There  was  no  progress  on  the  right  of  establishment  where  many  requirements  continue  to 
restrict this right. 

Regarding  the  freedom  to  provide  cross-border  services,  registration,  licensing  and 
authorisation requirements are still in place for service providers registered in the EU. The Point 
of Single Contact has not been established yet.  

No progress was made in the area of postal services. Türkiye is yet to align with the provisions 
of the Postal Services Directive as a reserved area in the letter mail market is maintained for the 
universal service provider. National legislation also still needs to be aligned with the provisions 
of the Regulation on cross-border parcel delivery services. 

On  the  mutual  recognition  of  professional  qualifications,  the  Vocational  Qualifications 
Authority published a communication on national qualification of persons working in dangerous 
and  very  dangerous  conditions.  Some  regulated  professions  still  required  reciprocal  mutual 

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recognition.  Nationality  and  language  requirements  were  not  removed.  Alignment  of  national 
legislation with the EU acquis in this area needs to continue. 

Chapter 4: Free movement of capital 

In  the  EU,  capital  and  investments  must  be  able  to  move  without  restriction  and  there  are 
common  rules  for  cross-border  payments.  Banks  and  other  economic  operators  apply  certain 
rules to support the fight against money laundering and terrorist financing. 

Türkiye is moderately prepared on free movement of capital. Overall, there was no progress 
in  this  area  in  the  reporting  period.  Limitations  on  foreign  ownership  persist  in  numerous 
sectors. There are few restrictive rules imposed on capital movements and foreign exchange-
denominated transactions. Türkiye improved its legal framework to align further with the EU 
Payment Services Directive. Türkiye was included in the list of jurisdictions under increased 
monitoring (“grey list”)  by the  Financial  Action  Task Force (FATF) in  October 2021.  There 
was no implementation of the 2021 Report's recommendations. 

In addition to addressing the shortcomings set out below, Türkiye should in particular: 

  minimise limitations on foreign ownership and on capital movements; 

  further  align  with  the  EU  acquis  by  strengthening  measures  to  prevent  the  misuse  of  its 

financial system for the purpose of money laundering and terrorist financing; 

  continue to address outstanding recommendations to be delisted from the FATF's grey-list, 
taking into account the recommendations of the Venice Commission regarding the law on 
the prevention of financing of the proliferation of weapons of mass destruction. 

Concerning the capital movements and payments, restrictions in foreign ownership were still 
in  force  in  many  sectors,  including  aviation  and  maritime  transportation,  financial  sector, 
electricity  market  and  real  estate.  Türkiye’s  legislation  on  real  estate  acquisition  by  foreigners 
remains opaque and does not apply to all EU nationals in a non-discriminatory way, contrary to 
the  EU-Turkey  Association  Agreement.  Immovable  property  acquisition  by  citizens  of 
neighbouring  countries  in  border  provinces  continued  to  be  restricted  for  national  security 
reasons.  Türkiye  introduced  new  conditions  for  foreigners  wishing  to  obtain  the  Turkish 
citizenship  through  capital  or  real  estate  investments.  Although  the  amount  is  determined  in  a 
foreign  currency,  the  invested  foreign  currency  needs  to  be  converted  to  lira  through  a  bank 
operating  in  Türkiye  prior  to  the  transaction.  Restrictions  introduced  after  the  August  2018 
currency  crisis  on  capital  movements  for  residents  and  non-banking  corporations,  in  particular 
for  transactions  denominated  in  foreign  currencies  were  still  in  place  and  were  reinforced.  In 
April 2022, the payment obligation in lira was introduced for movable sale contracts (except for 
vehicle sale contracts) even if denominated in foreign currency. Meanwhile, the requirement for 
Turkish companies to repatriate their export earning into the country within 180 days was still in 
force.  Exporting  companies  were  requested  to  sell  to  the  central  bank  40%  of  their  foreign-
earned  incomes.  Furthermore,  if  the  foreign  currency  obtained  from  foreign  exchange  earning 
services or transactions was sold to banks, at least 40% of these foreign exchanges had to be sold 
afterwards to the central bank. 

Türkiye  has  reached  a  good  standard  in  payment  systems.  The  central  bank  adopted  new 
implementing legislations to align further with the EU acquis on payment services. It laid down 
the  principles  and  procedures  for  the  authorisation  and  activities  of  payment  institutions  and 

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electronic  money  institutions,  the  provision  of  payment  services  and  the  issuance  of  electronic 
money to payment service providers. The new legislation introduced standards for open banking 
licenses.  The  central  bank  made  good  progress  in  the  implementation  of  the  Instant  and 
Continuous Transfer of Funds (FAST) system. The transaction amount limit for money transfers, 
which  was  initially  set  as  TRY  50  in  January  2021,  was  increased  gradually  to  TRY  5  000  in 
February  2022.  The  use  of  crypto  currency  and  crypto  assets  directly  or  indirectly  as  an 
instrument of payment remained banned in Türkiye. 

Türkiye made limited progress in the fight against money laundering and terrorist financing. 
Türkiye was included in the list of jurisdictions under increased monitoring (“grey list”) by the 
Financial Action Task Force (FATF) in October 2021. Following this decision, Türkiye was not 
added to the EU’s list of high-risk third countries due to its candidate status, high-level political 
commitment  to  the  EU  to  address  outstanding  shortcomings  identified  by  the  FATF  and  aim 
towards full alignment with the EU acquis. The Financial Crimes Investigation Board (MASAK) 
continued  to  develop  a  sound  track-record.  The  number  of  suspicious  transaction  reports 
submitted  increased  significantly  from  237  531  in  2020  to  504 995  in  2021.  The  money 
laundering prosecutions also  showed an incremental trend over the last  years. There were only 
70  cases  resulting  in  conviction  between  2013  and  2018.  Meanwhile,  225  people  have  been 
convicted in 89 cases of money-laundering since 2018. 

The  overarching  national  strategy  document  to  improve  Türkiye’s  anti-money  laundering  and 
counter terrorist financing (AML/CTF) system was promulgated in July 2021. The government 
continued  to  freeze  the  assets  of  persons/entities  designated  by  the  United  Nations  Security 
Council  Sanctions  Committee  in  less  than  a  day  during  the  reporting  period.  The  government 
also continued to use the domestic assets freeze instrument dissuasively. In 2021, 1 155 persons, 
16 associations and legal entities’ assets were frozen through the domestic freeze mechanism. 

Chapter 6: Company law 

The  EU  has  common  rules  on  the  formation,  registration  and  disclosure  requirements  of  a 
company, with complementary rules for accounting and financial reporting, and statutory audit. 

Türkiye is  well advanced  in  the area of company  law although no progress  was made on the 
2021  recommendations  during  the  reporting  period  and  they  remain  valid.  In  the  coming  year, 
Türkiye should in particular: 

make  progress  in  alignment  with  the  EU  acquis  in  the  company  law  area,  including  in  the 

field of shareholder rights and encouragement of long-term shareholder engagement; 

adopt the financial reporting standards for small and micro companies to achieve further EU 

acquis alignment. 

On  company  law,  no  legislative  action  was  taken  during  the  reporting  period.  Alignment  is 
needed on some outstanding issues in the context of cross-border mergers, domestic mergers and 
divisions,  and  takeovers.  As  regards  the  disclosure  of  company  documents  in  the  business 
register, there are still no provisions in place requiring the publication of annual accounts for all 
limited  liability  companies  or  the  online  filing  of  company  documents,  and  no  fully  online 
registration process of limited liability companies. Further alignment is necessary with the 2019 
EU  acquis  on  the  use  of  digital  tools,  cross-border  operations,  as  well  as  with  the  rules  on 
shareholder rights and encouragement of long-term shareholder engagement.  

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As  regards  transparency  rules  applying  to  companies  listed  on  capital  markets,  the  Capital 
Markets Law regulates general responsibilities of issuers and implementing rules are published 
by the Capital Markets Board; aimed at aligning with the EU acquis in this area. 

Concerning  company  reporting  and  statutory  audit,  in  March  2022,  the  Public  Oversight, 
Accounting  and  Auditing  Standards  Authority  (POA)  issued  amendments  to  the  financial 
reporting  standard  of  large  and  medium  scale  enterprises  in  high  inflation  economies. 
Additionally, in line with  International Ethics Standards Board for Accountants, revisions were 
published to  the Code to Promote the Role and Mindset  Expected of Professional  Accountants 
and  Revisions  to  the  International  Standard  for  Assurance  Engagements.  However,  alignment 
with  the  EU  acquis  on  financial  reporting  standards  for  small  and  micro  companies  is  long 
pending,  and  there  is  still  no  clarity  concerning  alignment  of  non-financial  information  and 
reports on payments to government. Overall, further work is required to align with the EU acquis 
on accounting and statutory audit. 

Chapter 7: Intellectual property law 

The EU has harmonised rules for the legal protection of intellectual property rights (IPR) and of 
copyright  and  related  rights.  Rules  for  the  legal  protection  of  IPR  cover,  for  instance,  patents 
and  trademarks,  designs,  biotechnological  inventions  and  pharmaceuticals.  Rules  for  the  legal 
protection  of  copyright  and  related  rights  cover,  for  instance,  books,  films,  computer 
programmes and broadcasting. 

Türkiye  has  a  good  level  of  preparation  in  the  area  of  legislative  alignment  and  institutional 
building.  There  was  limited  progress  during  the  reporting  period.  There  was  an  increased 
number  of  training  for  various  target  groups,  but  raising  awareness  of  the  general  public  and 
ensuring the sustainability  of the specialised units in  the judiciary, the police, and the customs 
remain  a  priority.  The  amount  and  variety  of  counterfeit  and  pirated  goods  originating  from 
Türkiye  or  transiting  through  Türkiye  increased.  Recommendations  from  last  year’s  report 
remain valid.  

In the coming year, Türkiye should in particular: 

improve enforcement measures to efficiently fight against industrial and intellectual property 
infringements,  including  online  sales  of  counterfeit  and  pirated  goods,  improve  the 
specialisation  in  courts  dealing  with  IPR  infringements  and  solve  difficulties  in  judicial 
procedures to obtain search and seizure warrants in criminal enforcement; 

improve co-operation with IPR owners for efficient implementation and effective enforcement 
of  the  new  Industrial  Property  Law,  in  particular  in  cases  of  accelerated  and  simplified 
destruction procedures by the judiciary and at the customs; 

ensure  collection  and  processing  of  accurate  statistical  data,  especially  on  effective  judicial 
enforcement  of  intellectual  and  industrial  property  rights,  with  a  view  to  facilitating  the 
analysis of systemic IPR deficiencies. 

Concerning  copyright  and  related  rights,  the  long  pending  copyright  law  was  not  adopted. 
Training  on  the  protection  of  copyright  and  related  rights  continued  for  various  target  groups. 
The  Directorate  General  for  Copyrights  published  an  implementing  regulation  on  collective 
management organisations (CMOs) in order to increase institutional building and transparency in 
CMOs,  as  well  as  to  align  with  the  EU  acquis.  However,  systemic  issues  with  regard  to 

87 

 
 
collective  rights  management,  lack  of  autonomy  and  supervision  of  CMOs  and  discrimination 
against  foreign  right  holders  in  the  management  of  CMOs  continued.  A  number  of  issues 
remained unresolved, in  particular the lack of fair distribution of private copy levies, licencing 
difficulties during the COVID-19 pandemic, uncertainties in online education exceptions, public 
performance right problems,  unauthorised use of copyrighted material via online platforms and 
well-known e-commerce websites.  

With  regard  to  industrial  property  rights,  the  Turkish  Patent  and  Trademark  Office  (TPTO) 
continued to raise awareness. Uncertainties about the legal status of applications for well-known 
and  famous  trademarks  continued.  Revocation,  opposition  and  invalidation  procedures  for 
trademarks remained expensive and lengthy. 

Concerning judicial enforcement, efforts to increase and sustain the number of specialised and 
experienced  IPR  judges  and  prosecutors  remains  a  priority.  Despite  the  possibility  to  demand 
higher  sanctions,  criminal  courts  rarely  order  deterrent  fines  for  commercial  scale  IP 
infringements.  Inefficient  litigation  procedures  including  at  courts  of  appeal,  difficulties  and 
inconsistencies in deciding preliminary injunctions and monetary compensation claims, storage 
and destruction problems and financial burdens of counterfeit goods, overuse of expert witness 
statements remained a concern. 

Even though right-holders provide strong evidence about counterfeiting, difficulties in obtaining 
search  and  seizure  warrants  against  counterfeit  goods  further  worsened.  Actions  against  IP 
infringements by enforcement authorities, in particular the police and judges, were not efficient, 
despite some resources and training. Whereas online sales of counterfeit goods at well-known e-
commerce  marketplaces  increased,  Türkiye  did  not  apply  notice  and  take-down  procedures  to 
stop these infringements. Fight against counterfeiting at open bazaars was insufficient. 

Guidelines  on  counterfeit,  illicit  or  out-of-the  legal  supply  chain  medicines  were  published  in 
January  2022.  Although  Türkiye  regulates  and  monitors  the  domestic  pharmaceutical  market, 
online  sales  of  counterfeit  pharmaceuticals,  cosmetics  and  sanitary  products  pose  threats  to 
consumer safety and public health. Deaths from fake alcoholic beverages continued. Türkiye was 
the  second  largest  source  country  of  pirated  products  affecting  the  EU  single  market  and 
counterfeit products seized at the EUs external borders. Counterfeiting concerns a wide range of 
products from food and alcoholic beverages to vehicles, vehicle accessories and spare parts. The 
fast depreciation of the Turkish lira and decline in purchasing power also following the COVID-
19 pandemic, boosted demand for cheaper and fake goods.  

The legitimisation  of counterfeiting and piracy in public opinion stems  from the deeply-rooted 
belief  that  these  are  petty  crimes.  However,  most  of  the  offences  are  committed  by  organised 
crime  networks  which  are  also  involved  in  fraud,  corruption,  cybercrimes,  money  laundering, 
drug smuggling and human trafficking. There is a need for awareness campaigns run by public 
institutions on the dangers of counterfeiting and piracy on public health, consumer safety, rule of 
law, and labour market,  as well as on the economic benefits  of  IPR-intensive sectors. Stronger 
political commitment is needed to enforce IPR and to stop counterfeit trade from Türkiye to the 
EU. 

Chapter 8: Competition policy 

EU  rules  protect  free  competition.  They  include  antitrust  rules  against  restrictive  agreements 
between  companies  and  abuse  of  dominant  position  and  also  include  rules  on  concentrations 

88 

 
 
between  companies,  which  would  significantly  impede  effective  competition.  EU  rules  also  set 
out a system of State aid control. Governments are only allowed to grant State aid if restrictive 
conditions are met, with a view to prevent distortion of competition. 

Türkiye has some level of preparation in the area of competition policy. It made no progress in 
addressing  last  year’s  recommendations.  Serious  concerns  persist  in  relation  to  the  legislative 
framework, enforcement capacity and transparency in the field of State aid. 

In addition to addressing the shortcomings set out below, Türkiye should in particular: 

  ensure  the  independence  and  functionality  of  the  State  aid  institutional  framework  and  that 

State aid rules are published transparently; 

  ensure  implementation  of  the  State  aid  law  by  adopting  implementing  legislation  without 

further delay; 

 make publicly available, transparent and up-to-date inventory of all aid schemes. 

Anti-trust and mergers 

The legislative framework is broadly aligned with the EU acquis. The Law on the Protection of 
Competition  broadly  reflects  Articles  101  and  102  of  the  Treaty  on  the  Functioning  of  the 
European  Union.  Implementing  legislation  in  this  field  is  largely  in  place.  In  March  2022, 
Türkiye  amended  the  merger  control  communiqué  and  removed  the  notification  thresholds  for 
the  technology  undertakings  operating  in  Türkiye.  As  a  result,  transactions  involving  such 
undertakings  will  be  subject  to  extensive  scrutiny  by  the  Competition  Authority,  regardless  of 
their magnitude. 

In  terms  of  the  institutional  framework,  the  Turkish  Competition  Authority  is  in  charge  of 
enforcing the Law on the Protection of Competition. Its decision-making body, the Competition 
Board is comprised of seven members. Despite being affiliated with the Ministry of Trade, the 
Turkish Competition Authority has administrative and financial autonomy. 

The  enforcement  capacity  of  the  Turkish  Competition  Authority  is  adequate.  In  2021,  overall 
implementation  was  effective  and  the  number  of  decisions  in  the  area  of  antitrust  (74,  as 
compared  to  65  in  2020),  exemption/negative  clearance  decisions  (22,  as  compared  to  34  in 
2020)  and  merger/acquisition/joint  venture/privatisation  (309,  as  compared  to  280  in  2020) 
remained  in  the  same  range  as  in  the  previous  year.  The  total  amount  of  fines  imposed  by  the 
Authority  for  the  infringements  of  competition  cases  (fines  related  to  substance)  significantly 
increased to  TRY 4.2 billion  from  an average of TRY 580 million  for the previous five  years. 
The total number of ex-officio investigations and preliminary investigations increased (from 8 in 
2020, to 15 in 2021). The Turkish Competition Authority conducted an average of 58 dawn raids 
throughout 2021. In 2021, 74 % of the 54 judgements concluded as a result of the appeals against 
the Turkish Competition Authority decisions were upheld by Turkish courts. 

State aid 

The legislative framework is partially in line with the EU acquis. State aid regulations would still 
need to cover the agriculture, fisheries and services sectors, which are not part of the EU-Turkey 
Customs Union. Türkiye’s primary State aid law is broadly in line with Articles 107 and 108 of 
the Treaty on the Functioning of the European Union. However, it is not enforceable due to the 
lack  of  implementing  legislation  and  an  operational  institutional  framework.  The  country’s 

89 

 
 
President  is  empowered  to  postpone  the  enforcement  of  implementing  legislation  indefinitely. 
Türkiye still needs to adopt an action plan for the alignment of its legislation with the EU acquis. 

In 2021, Türkiye avoided implementing State aid control by neglecting to establish a functional 
organisational structure and did not address the absence of implementing legislation. In terms of 
the institutional framework, in June 2022 a new presidency decree re-established the Directorate 
General for State Aids (DGSA), under the Presidency of Strategy and Budget, which itself is also 
granting  State  aid.  The  mandate  to  develop  policy  proposals  remained  with  the  Economic 
Policies Council, whose members are appointed by the President of the Republic. The State aid-
related  responsibilities  of  the  Directorate-General  for  Economic  Programs  and  Research 
(DGEPR),  which  is  part  of  the  Ministry  of  Treasury  and  Finance,  was  also  transferred  to  the 
newly established DGSA. According to the new decree, the DGEPR will still fulfil the State aid 
related tasks to be given by the President. The new decree commits to issuing the implementation 
regulation for the DGSA within one year.  

In 2021, the implementation of the project-based investment programme, where public support is 
provided on a selective basis, reached 39 projects with an investment amount of TRY 152 billion 
(45  projects  with  an  investment  amount  of  TRY  335  billion  as  of  September  2022).  The  lack  of  a 
transparent  State  aid  inventory  covering  all  aid  schemes,  including  the  amount  or  budgeted 
amount of the state support granted, remains a source of concern. 

Liberalisation 

Competition  and  State  aid  rules  apply  to  state-owned  enterprises.  However,  the  competence 
concerning  the  privatisation  process  lies  with  the  President,  who  has  assumed  power  over  the 
privatisation decisions and procedures. In March 2022, the Turkish Wealth Fund (TWF) acquired 
55% share of Turk Telekom (TT), a transaction which effectively reversed the privatisation and 
reduced significantly the liberalisation of the telecommunications market.  

Chapter 9: Financial services 

EU  rules  aim  at  ensuring  fair  competition  among  and  the  stability  of  financial  institutions, 
namely banking, insurance, supplementary pensions, investment services and securities markets. 
They include rules on authorisation, operation and supervision of these institutions. 

Türkiye  has  a  good  level  of  preparation  in  the  area  of  financial  services.  There  was  some 
progress  during  the  reporting  period,  with  the  development  of  new  alternative  financing 
instruments.  Türkiye  also  continued  taking  important  steps  towards  accelerating  the  digital 
transformation  of  the  banking  sector  and  the  strengthening  of  the  insurance  sector.  There  was 
some implementation of the 2021 recommendations. 

In the coming year, Türkiye should in particular: 

  further  strengthen  bank  governance  and  supervision,  crisis  management  and  the  resolution 

framework; 

 improve the transparency of asset quality review; 

 continue to support the development of Turkish capital markets and their proper supervision. 

Regarding  banks  and  financial  conglomerates,  to  mitigate  the  impact  of  the  COVID-19 
pandemic  on  the  economy,  relaxed  prudential  measures  still  protect  capital  adequacy  ratios,  in 
particular by using a 252 business day rolling average FX rate and suspending mark-to-market 

90 

 
 
accounting  rules,  thereby  postponing  the  recognition  of  related  losses.  The  ratio  of  non-
performing loans continued to decrease to 2.5 % in June 2022, in a context where credit growth 
was very strong. Banking system duality continued, as state-owned banks’ expansion during the 
crisis  came  at  the  price  of  weaker  capital  and  profitability  positions.  State  banks  have  been 
recapitalised  several  times  in  the  last  years.  In  the  beginning  of  2022,  they  were  recapitalised 
again  (TRY  52  billion)  with  the  view  to  prepare  them  to  lead  again  a  new  cycle  of  credit 
expansion.  The  capital  adequacy  ratio  of  the  banking  sector  had  improved  in  the  beginning  of 
2022,  reaching  20.4  %  in  April,  but  then  dropped  slightly  in  May  and  June  to  18  %.  In  June 
2022, the Banking Regulation and Supervision Agency (BDDK) took a series of new measures 
to  slow  down  loan  growth.  In  July  2021,  the  BDDK  adopted  new  regulations  aiming  at 
strengthening  the  financial  sector  by  improving  asset  quality  of  the  banking  sector  and 
reinforcing capacity of asset management companies. BDDK was given the authority to request a 
bank,  under  some  specific  conditions,  to  form  a  strategy  for  distressed  assets  loans  and  to 
establish  resolution  units.  Nevertheless,  Türkiye  needs  to  conduct  transparent  third-party  asset 
quality review and adopt a more comprehensive resolution plan in the event of a surge in  non-
performing loans. 

Türkiye  continued  taking  significant  steps  towards  the  digitisation  of  its  financial  sector,  by 
implementing  new  regulations  in  the  areas  of  digital  banking  and  open  banking  services.  The 
BDDK adopted a regulation enabling banks to provide services through digital channels without 
the  existence  of  physical  branches.  The  regulation  also  introduces  service  banking  model, 
enabling financial technology companies and other businesses to present financial products. The 
Capital  Markets  Board  also  adopted  new  regulations  allowing  remote  identification  and  the 
establishment  of  contractual  relationships  in  electronic  environment  for  financial  leasing, 
factoring, financing and savings companies. 

Türkiye made good progress in the area of insurance and occupational pensions. Following the 
amendment introduced in the Insurance Law in May 2021, the Special Risk Management Centre 
was set  up. The centre aims at  providing coverage for the risks for which it is  difficult  to  find 
collateral.  The  regulation  on  arbitration  in  insurance  was  amended,  transferring  the  duties  and 
authorities  related  to  insurance  arbitration  from  the  Ministry  of  Treasury  and  Finance  to  the 
Insurance and Private Pension Regulation and Supervision Agency (SEEDK). A new regulation 
was adopted in November 2021 on internal systems in the insurance and private pension sectors, 
laying down the principles and procedures as regards internal control, risk management, actuarial 
and internal  audit systems.  In January 2022, significant changes were introduced to the private 
pension system, such  as  raising the state contribution to  the system,  allowing the enrolment  of 
workers older than 45, and providing more flexibility for the withdrawal of savings without the 
need to leave the system. 

As regards financial market infrastructure, the law on Istanbul Financial Center was adopted 
in June 2022, aiming to turn Istanbul into a global financial hub. The Index-based circuit breaker 
system was activated in December 2021 when the losses in the BIST 100 index reached 5 %, and 
transactions  in  all  sectors  at  the  stock  exchange  were  temporarily  suspended.  Meanwhile,  the 
methodology of Borsa Istanbul Sustainability Index was updated in October 2021 to encourage 
companies to adopt more sustainable business model. 

There was some progress in  the area of  securities  markets and investment services.  Türkiye 
took  some  steps  to  deepen  its  capital  market  and  diversify  its  products.  The  Capital  Markets 
Board adopted the implementing regulation for project-based securities and project finance funds 

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in July 2021. Türkiye also took measures aiming to regulate debt-based crowdfunding. In June 
2022, the Board announced the establishment of a commodity market within Borsa Istanbul. In 
February  2022  a  guideline  was  published  to  encourage  the  financing  of  capital  investments 
contributing to environmental sustainability. 

The  Russian  MIR  payment  system  was  widely  used  in  Türkiye  amid  the  acceptance  of  MIR 
cards  by  an  increasing  number  of  Turkish  banks,  facilitating  bilateral  exchanges  with  Russian 
citizens and businesses. 

Chapter 28: Consumer and health protection 

EU  rules  protect  consumers’  economic  interests  in  relation  to  product  safety,  dangerous 
imitations and liability for defective products.  The EU also ensures high common standards for 
tobacco control, blood, tissues, cells, patients’ rights and communicable diseases. 

There  is  a  good  level  of  preparation  for  legislative  alignment  of  consumer  and  health 
protection. Türkiye made some progress in implementing some of last year’s recommendations, 
on aligning with the EU acquis on ‘communicable diseases” and on “blood” and in establishing a 
constructive dialogue with stakeholders in consumer protection.  

In the coming year, Türkiye should continue to: 

  strengthen  consumer  rights  enforcement  and  further  improve  coordination  and  cooperation 
with  the  consumer  movement  and  with  enforcement  bodies;  increase  raising  awareness 
activities  and  take  more  measures  on  infringements  in  the  digital  environment  and  for 
vulnerable consumers; 

  increase  its  institutional/administrative  capacity,  financial  resources  and  appropriate 
diagnostic  facilities  to  address  public  health  issues  at  central  and  provincial  level  for 
a resilient health system; 

 make further progress in strengthening its surveillance system for reinforcing health security. 

Consumer protection 

Türkiye’s national legislation is mostly aligned with the EU acquis on consumer protection in 
non-safety  related  issues.  The  national  consumer  information  system  (TÜBİS),  which  allows 
consumers to submit and track their complaints electronically, is complex. Consumer awareness 
of TÜBİS could  be improved;  consumers experience problems  with  it, especially on electronic 
goods, leading them to having difficulties in enforcing their rights. The consumer movement and 
links between consumers and consumer NGO both remain weak. Consumer NGOs lack financial 
and  professional  support  and  are  unable  to  participate  actively  in  law-  and  public  decision-
making  mechanisms.  Consumer  face  rights  enforcement  problems  and  difficulties  in  using  the 
right  to  choose.  Consumer  awareness  and  education,  cooperation  and  coordination  of  sectoral 
stakeholders  also  remain  weak.  Consumer  arbitration  committees  need 
to  be  fully 
institutionalised to ensure better enforcement of consumer rights, and members need to be fully 
trained in relevant specialisations to ensure a common understanding of the legal issues.  Of the 
630 852 decisions taken by Consumer Arbitration Committees in 2021, 52 % were in favour of 
consumers and 48 % against consumers. Cooperation between out-of-court and court consumer 
systems needs to be reinforced. 

With regard to safety-related measures, consumer awareness about the national unsafe products 

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information  system  (GÜBİS)  should  be  reinforced.  Sales  of  counterfeit  products  threatening 
public  health  and  consumer  safety  via  e-commerce  need  regular  monitoring  and  stronger 
regulatory  tool  (see  Chapter  7-  Intellectual  property  law).  Türkiye  adopted  a  new  framework 
regulation on market surveillance in July 2021. Market surveillance is not performed on the basis 
of  risk  assessment,  and  remained  very  limited  with  regard  to  e-commerce.  According  to  the 
annual market surveillance report of the Ministry of Trade for 2021, the overall budget allocated 
to  market  surveillance  increased  by  103  %  in  2021  as  compared  to  2020  in  a  high  inflation 
environment.  Yet,  there  was  a  decrease  of  33  %  in  the  number  of  active  market  surveillance 
inspectors.  There  was  an  increase  of  12  %  in  the  number  of  products  subject  to  market 
surveillance checks in 2021 as compared to 2020 (see Chapter 1-Free movement of goods). 

Public health 

In  the  field  of  public  health,  by  June  2022  Türkiye  experienced  over  15  million  COVID-19 
cases, with almost 100 000 deaths. The country witnessed two peaks of pandemic in 2021, and a 
sharp increase was observed in February 2022 with the emergence of the Omicron variant. The 
number  of  COVID-19  cases  has  been  decreasing  since  then,  along  with  the  occupancy  rate  of 
intensive  care  units.  The  vaccination  coverage  with  two  doses  is  64  %  of  total  population. 
Increases  in  health  workers  salaries,  promised  as  a  recognition  for  the  additional  workload 
caused  by  the  pandemic,  did  not  come  into  effect.  The  pandemic  has  highlighted  a  need  for 
additional health service provision in some areas, such as mental health routine or maternal and 
child health services, which were particularly affected due to the prioritisation of pandemic care 
and mitigation/distancing policies taken to slow the spread of COVID-19. Apart from ensuring 
continuity of pregnancy follow-ups and facilitating access to medication for people living with 
HIV, the absence of central planning for the continuity of overall sexual and reproductive health 
services  during  the  pandemic  indicates  a  significant  deficiency  in  terms  of  Türkiye’s  health 
strategy to fight against the pandemic. 

Türkiye is facing a growing burden from non-communicable diseases, which cause 87 % of all 
deaths, with an 18 % probability of dying before reaching the age of 70. Social restrictions and 
economic  disruption  caused  by  COVID-19  increased  the  risk  factors  due  to  lack  of  physical 
exercise, increasing stress levels and possible negative coping mechanisms such as smoking, use 
of drugs, and alcohol consumption. Tobacco is a known risk factor for these diseases as well as 
for infectious respiratory diseases.  

During  the  COVID-19  outbreak,  good  progress  was  achieved  in  addressing  communicable 
diseases. Türkiye is part of viral respiratory disease surveillance networks managed by European 
Centre  for  Disease  Prevention  and  Control  (ECDC)  and  reports  to  it  on  several  communicable 
diseases,  though  it  opted  out  of  some  ECDC  activities.  In  order  to  strengthen  the  capacity  to 
detect  and  counter  threats  posed  by  outbreaks  of  infectious  diseases,  Türkiye  accelerated  the 
integration  of  the  diagnostic  capacity  of  laboratories  with  field  epidemiology.  The  national 
virology reference laboratory increased its sequencing capacity and its international collaboration 
and contribute to the global understanding of the pandemic. Türkiye has a national action plan on 
antimicrobial  resistance  (AMR),  and  a  national  surveillance  system  for  AMR  in  humans. 
According  to  the  ministry  of  health,  17  %  of  the  population  face  mental  health  issues,  and 
antidepressant consumption has increased by 56 % in five years with COVID-19 scaling up the 
challenges since 2020. 

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In the field of substances of human origin, several tools were developed to ensure safe blood 
transfusion, efficient use of blood, safety of a patient and reduction of blood wastage ratios in the 
country.  In  January  2022,  two  selected  regional  blood  centres  were  licenced  by  the  European 
Medicines  Agency  for  plasma  production.  The  administrative  capacity  of  the  competent 
authority  for  blood  remained  insufficient  for  enforcement,  inspection  of  blood  banks  and 
transfusion centres at central and local levels and for tissue and organ transplantation. 

CLUSTER 3: COMPETITIVENESS AND INCLUSIVE GROWTH  

This  cluster  covers:  digital  transformation  and  media  (Chapter  10),  taxation  (Chapter  16), 
economic  and  monetary  policy  (Chapter  17),  social  policy  and  employment  (Chapter  19), 
industrial  policy  (Chapter  20),  science  and  research  (Chapter  25),  education  and  culture 
(Chapter 26), and customs union (Chapter 29).  

Türkiye  has  some  level  of  preparation  in  the  area  of  digital  transformation  and  media.  It 
continued to backslide as it did not address concerns regarding inadequate competition, lack of 
transparency  of  media  funding,  concentration  of  media  ownership,  political  influence  on 
editorial policies and the lack of independence of regulatory authorities. Türkiye’s preparations 
in the area of science and research are well advanced and Türkiye made good progress during 
the  reporting  period,  notably  with  the  conclusion  of  the  association  agreement  for  Horizon 
Europe for the 2021-2027 period. Türkiye is moderately prepared on education and culture and 
made some progress, in particular on vocational education, national qualifications systems and 
in terms of Türkiye’s participation in the EU programmes.  

On  the  economy-related  chapters,  backsliding  continued  on  economic  and  monetary  policy, 
reflecting inefficient policy on ensuring price stability and anchoring inflation expectations. The 
central bank remains under significant political pressure and its functional independence needs 
to  be  restored.  Türkiye  made  limited  progress  on  enterprise  and  industrial  policy  and  major 
challenges  in  relation  to  measures  incompatible  with  EU  industrial  policy  principles  remain 
unaddressed. No progress was made during the reporting period in the area of social policy and 
employment,  with  concerns  remaining  over  trade  union  rights,  the  lack  of  genuine  social 
dialogue and persistent levels of informal economic activity. 

While  Türkiye  is  moderately  prepared  on  taxation,  it  made  no  progress  during  the  reporting 
period and there remains a need for a clear strategy, avoiding frequent changes in tax rates and 
enabling tax information exchange with all EU Member States. Türkiye maintains a good level 
of  preparation  for  the  customs  union  but  made  limited  progress,  notably  by  removing  some 
additional  duties  applied  on  imports  of  products  originating  in  third  countries.  However, 
Türkiye’s  deviations  from  its  obligations  under  the  EU-Turkey  Customs  Union  continue, 
contributing to a high number of trade irritants. 

Chapter 10: Digital transformation and media 

The EU supports the smooth  functioning of  the internal market  for  electronic communications, 
electronic  commerce  and  audio-visual  services.  The  rules  protect  consumers  and  support 
universal availability of modern services. 

Türkiye  has  some  level  of  preparation  in  the  area  of  digital  transformation  and  media. 
Backsliding continued. Lack of competition in broadband market, excessive taxation as well as 
costs and burdens for operators and consumers of information and communications technologies 
remained.  Türkiye  is  moderately  aligned  in  the  audiovisual  sector.  Concerns  remain  regarding 

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the lack of transparency of media funding, concentration of media ownership, political influence 
on  editorial  policies,  restrictions  on  freedom  of  expression  and  lack  of  independence  of 
regulatory authorities.  

The  last  year’s  recommendations  were  not  addressed  and  remain  valid.  In  the  coming  year 
Türkiye should in particular: 

  align  the  universal  service,  authorisation  arrangements,  market  access  and  rights  of  way  in 

electronic communications with the EU acquis 

 strengthen the independence of the regulatory authority and its board members and amend the 
Internet Law in line with the Venice Commission’s recommendations with a view to ensuring 
media pluralism; 

 take steps to strengthen the public broadcaster’s independence. 

On electronic communications and information technology, no progress was made in aligning 
the legislation with the EU acquis on market access and universal service. The lack of financial 
and  administrative  independence  of  the  regulatory  authorities  remains  a  concern.  More 
transparency in spending and more allocation for improving a competitive and consumer friendly 
market is needed to ensure relevant competitive safeguards. 

Competition  in  fixed  voice  market  improved.  The  market  share  of  alternative  fixed  voice 
operators was 9.8 % at the end of 2021. Lack of sufficient competition in the broadband market 
remains a concern. Mobile broadband penetration slightly increased to 86.4 % in the third quarter 
of 2021 against the OECD average of 121.4 %. The fixed broadband penetration rate was 25.2 % 
compared to  the OECD  average of 33.8 %. The  number of 4.5G subscribers remained broadly 
stable  with  80.2  million  by  the  end  of  2021  compared  to  76.5  million  subscribers  in  the  last 
quarter of 2020. 

While no progress in procurement of 5G was reported, there is a need for allocating additional 
frequencies for the development and predictability  of the sector.  Internet  use was  at  82.6 % in 
2021, compared to 79 % in 2020. National IDs were integrated with e-signatures. The number of 
legal transactions which can be completed with e-signature, increased. 

Implementing regulation on consumer rights in electronic communication was amended in order 
to protect consumers against unfair contract terms and to maximise data protection and e-security 
of consumers. In 2021, consumer arbitration committees received 51 514 complaints on internet 
service  subscription  contracts  and  18  436  complaints  on  mobile  phone  service  agreements. 
Enforcement  of  consumer  rights  in  the  telecommunication  sector  remained  very  weak. 
Complaints  to  the  arbitration  committees  about  telecommunication  services  were  the  most 
frequent amongst all consumer complaints. 

The  number  of  services  offered  from  the  E-Government  Gateway  reached  6  001  by  October 
2021.  The  number  of  integrated  institutions  rose  from  791  to  824  by  October  2021.  The 
proportion of citizens using e-government slightly increased from 51.2 % in 2019 to 58.9 % at 
the end of 2021. 

Digital Single Market 

The volume of e-commerce transactions increased by 69 % in 2021 as compared to 2020. Large 
scale  e-sellers  cover  79  %  of  the  e-commerce  market  in  Türkiye.  Fashion  and  accessories, 
furniture, glassware, notions, food and drinks are the most frequently traded products. 

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The  e-commerce  law  was  amended  in  July  2022.  Amendments  aim  at  preventing  unfair 
competition  and  monopolisation  in  e-commerce  market  by  ensuring  better  market  access  and 
equal  opportunities  for  all  participants,  including  through  administrative  fines  for  unfair 
commercial practices. 

In the area of audio-visual policy, pro-government mainstream media continue to dominate the 
information  space.  According  to  independent  research,  the  40  largest  media  organisations  are 
controlled  by  companies  operating  in  industry  and  trade,  predominantly  belonging  to  owners 
affiliated  with  the  government.  Their  commercial  ties  with  the  government  obstruct  media 
independence, lead to self-censorship and limit the scope of public debate. 

Channels critical of the President and the government faced heavy monetary fines by the media 
regulator Radio  and Television Supreme Council  (RTÜK). Media channels  were also  fined for 
reporting on issues of public interest, like criticising the price hikes of gas, convictions related to 
the  Gezi  trial,  child  abuse  in  Quran  courses  or  violence  against  women.  During  the  reporting 
period,  Netflix  was  fined  over  an  animation,  which  was  claimed  to  violate  the  principles  of 
“national  and  moral  values  of  the  public”  and  had  two  movies  removed.  RTÜK  also  ordered 
Spotify  to  remove  playlists  and  content  which  contained  insults  against  the  President,  political 
party  leaders  and  other  state  officials.  While  pro-government  media  is  seen  to  be  favoured  by 
advertisement  revenue,  RTÜK’s  fines  concentrate  on  critical  media  outlets.  The  People’s 
Democratic  Party  HDP,  filed  a  motion  for  a  parliamentary  inquiry  commission  on  this  matter, 
which was rejected by the ruling coalition. 

In  January  2022,  a  presidential  circular  was  issued  on  press  and  broadcasting  activities.  The 
circular  aimed  to  “protect  the  youth  from  bad  habits  and  ignorance,  protecting  the  national 
culture  against  alienation  and  degeneration,  as  well  as  preventing  any  adverse  impact  on  the 
physical  and  mental  development  of  children  and  youth”.  The  circular  uses  generic  definitions 
while threatening with the use of undisclosed measures. This may have a further restrictive effect 
on  freedom  of  expression  and  the  media.  There  is  a  pending  application  by  the  Turkish  Bar 
Association at the Council of State to halt and cancel the execution of the circular on the basis 
that it violates basic rights and freedoms and will lead to self-censorship.  

According to RTÜK, 1 661 sanctions were imposed on broadcasters (radios/TVs) amounting to 
nearly TRY 56 million in 2021. 71 administrative fines were levied against independent channels 
critical of the government, according to media reports, ordering them to pay TRY 21 500 000 in 
total. No fine was given against pro-government media in 2021. 236 of RTÜK’s decisions were 
taken  to  court  by  broadcasters.  91  court  cases  ended  in  favour  of  RTÜK,  11  against  them  and 
134 are ongoing. RTÜK filed 129 criminal complaints against various media service providers, 
real persons and social media accounts. RTÜK also imposed 102 broadcast bans received from 
various courts requested by institutions or real persons. 

In  February  2022,  the  media  regulator  gave  72  hours  to  three  foreign  news  sites  operating  in 
Türkiye to apply for a license due to broadcasting videos. In April 2022, RTÜK announced that 
it  would  no  longer  require  one  of  them  to  obtain  a  license,  since  the  news  channel  ‘removed 
content  that  would  have  required  a  license’.  In  June  2022  RTÜK  decided  to  ban  access  to  the 
Turkish-language  websites  of  the  other  two  news  sites.  This  decision  is  an  attempt  to  further 
restrict media freedom and access to information in Türkiye. Concerns were not addressed over 
the 2019 regulation on radio, television and voluntary online broadcasts, which lacks clarity in 

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terms of its scope, definitions, licencing criteria, controversial provisions regarding jurisdiction 
and restricting access to online content. 

Concerns  over  the  independence  of  RTÜK  remain.  Although  the  parliament  elects  the  nine 
members of the Supreme Council in proportion to the political party groups, İYİ Party and HDP 
are  not  represented.  Moreover,  there  is  no  consultation  of  civil  society  or  professional  media 
organisations in the process (see also Political Criteria -Freedom of expression). 

Chapter 16: Taxation 

EU  rules  on  taxation  cover  value  added  tax  and  excise  duties  as  well  as  aspects  of  corporate 
taxation. They also deal with cooperation between tax administrations, including the exchange of 
information to prevent tax evasion. 

Türkiye  is  moderately  prepared  in  the  area  of  taxation,  where  no  progress  was  made.   
Recommendations from previous years were not addressed and remain valid. Türkiye still needs 
to  activate  effective  exchange  relationships  with  all  EU  Member  States  in  the  tax  screening 
process for the purposes of the EU list of non-cooperative jurisdictions, concerning the automatic 
exchange of financial account information. 

In the coming year, Türkiye should in particular: 

 establish an effective implementation of the automatic exchange of tax information with all 

EU Member States; 

 align the range of excisable energy products with the EU acquis; 

  continue  its  fight  against  the  informal  economy  and  present  progress  transparently  through 

performance indicators. 

In the area of indirect taxation, a wide range of products continued to be subject to a 1 % value 
added tax (VAT), contrary to the EU acquis. The implementation of the reduced 8 % VAT rate 
for a long list of goods and services and the 1 % VAT rate for COVID-19 vaccines, which were 
introduced  in  2020  as  part  of  the  measures  against  the  pandemic,  was  extended  subsequently 
until the end of September 2021 and December 2022. The implementation of the accommodation 
tax,  which  was  introduced  in  December  2019,  was  postponed  to  2023.  In  2021,  VAT  on 
refurbished mobile phones was  reduced from 18 % to  1 % and defence  industry projects  were 
exempted from VAT. In 2022, VAT for almost all food products and for hygiene products was 
reduced  respectively  from  18  %  to  1  %  and  from  18  %  to  8  %  in  order  to  counter  high  and 
growing inflation. Türkiye needs to further align the legislation on structure, exemptions, special 
schemes and the scope of reduced rates with the EU acquis. 

Although the overall level of taxation on cigarettes is close to EU levels, Türkiye’s legislation on 
cigarette excise duties differs from that of the EU acquis in terms of the specific and proportional 
elements  of  the  tax.  Excise  duties  on  energy  products  are  below  the  EU  minimum  rates  and 
contrary  to  the  EU  acquis,  coal  and  electricity  are  not  subject  to  excise  duties.  Kerosene  is 
subject to excise duty, but a 0 % tax rate applies. Since March 2020, a 7.5 % digital services tax 
(on digital advertising, content, and intermediary services) has been in effect.  

In the area of direct taxation, the tax amnesty on the repatriation of foreign assets, which started 
in  2018, was extended until June 2022. Such uninterrupted periods of capital  repatriation have 
adverse  effects  on  sustainable  voluntary  tax  collection.  In  April  2021,  Türkiye  once  again 

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impaired the predictability of the tax structure by  temporarily raising the corporate income tax 
from 20 % to 25 % for the current year and to 23 % for 2022. Corporate income tax had already 
been temporarily increased from 20 % to 22 % for 2018, 2019 and 2020. However, in January 
2022,  corporate  income  tax  for  manufacturing  and  exporting  companies  was  reduced  by  one 
percentage  point  and  some  additional  cuts  on  withholding  and  corporate  income  tax  were 
provided in  order to  encourage the  FX-  and  gold-protected TRY time deposit  account  scheme, 
which  was  introduced  in  December  2021  to  stop  the  fast  depreciation  of  the  Turkish  lira. 
Furthermore, in April 2022, a higher corporate income tax rate of 25 % was imposed on financial 
institutions'  2022  earnings.  Recent  corporate  income  tax  rates  are  above  the  22  %  average  for 
statutory corporate income tax among EU Member States. 

Türkiye  exempted  the  minimum  wage,  including  the  tax  on  all  wages  corresponding  to  the 
minimum wage, from income tax as of 2022. In 2021, individual social media content producers, 
for  content  shared  in  the  form  of  written  text,  audio,  visual  or  video,  and  mobile  application 
developers were exempted from income tax for earnings up to TRY 880 000 (2022 bracket). 

Administrative cooperation and mutual assistance 

Regarding administrative cooperation and mutual assistance, Türkiye remained in Annex II of the 
Council’s  Decision  on  non-cooperative  jurisdictions.  In  its  conclusions  of  24  February  2022,  the 
Council  considered  that  the  progress  made  by  Türkiye  was  still  not  fully  in  line  with  the 
commitments required under the conclusions of the ECOFIN Council of 22 February 2021 and 5 
October  2021.  It  called  on  Türkiye  to  begin  or  continue  the  technical  work  on  the  effective 
exchange of data from Türkiye with all Member States to meet the agreed international standards 
and fully comply with the requirements set in the above mentioned conclusions of the ECOFIN 
Council.  Furthermore,  the  Council  reiterated  that  the  effective  automatic  exchange  of 
information with all Member States according to the OECD calendar and standards is a condition 
for Türkiye to fulfil a criterion on the EU list and to fully comply with the requirements set out in 
the abovementioned Council conclusions. 

Türkiye’s  compliance  with  the  Multilateral  Convention  to  Implement  Tax  Treaty-Related 
Measures  to  Prevent  Base  Erosion  and  Profit  Shifting  measures,  particularly  with  respect  to 
country-by-country  reporting,  is  also  being  monitored  within  the  scope  of  the  EU  list  of  non-
cooperative jurisdictions for tax purposes. Türkiye remained committed to  improving its rating 
(due  towards  the  end  of  2022)  by  the  Global  Forum  on  Transparency  and  Exchange  of 
Information for Tax Purposes for the implementation of the international standard for exchange 
of information on request. Failure to fulfil these commitments would put Türkiye at risk of being 
included in the EU list for non-cooperative tax jurisdictions. 

Operational capacity and computerisation 

Regarding  operational  capacity  and  computerisation,  the  Turkish  Revenue  Administration 
actively uses an electronic document management system. The e-tax statement implementation, 
initiated  in  2004,  reached  99.87  %  in  2021.  Efforts  to  establish  an  integrated  public  finance 
management information system are ongoing. The implementation of the strategy and an action 
plan for the fight against the informal economy (2019-21) continued.  

Chapter 17: Economic and monetary policy 

EU  rules  require  the  independence  of  central  banks  and  prohibit  them  from  directly  financing 
the  public  sector.  Member  States  coordinate  their  economic  policies  and  are  subject  to  fiscal, 

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economic and financial surveillance. 

Türkiye  has  some  level  of  preparation  in  the  area  of  economic  and  monetary  policy. 
Backsliding continued during the reporting period, as the monetary policy became inefficient in 
ensuring  price  stability  and  anchoring  inflation  expectations.  The  central  bank  remains  under 
significant political  pressure to  keep the real  interest  rate deeply negative. Türkiye made some 
progress in the preparation of the Economic Reform Programme (ERP) and in the transmission 
of fiscal notifications. There was limited implementation of the 2021 report's recommendations. 

In the coming year, Türkiye should: 

    restore  the  functional  independence  of  the  central  bank  and  reinforce  the  credibility  of  the 

monetary policy framework; 

 implement an appropriate monetary policy stance with a stronger focus on price stability and 

re-anchoring inflation expectations; 

 further align fiscal reporting and notifications under the excessive deficit procedure with ESA 

2010. 

On  monetary  policy,  over  the  last  decade  the  central  bank  drifted  away  from  its  5  %  official 
inflation target set jointly with the government. Amid rising inflation and inflation expectations, 
the central bank significantly loosened its monetary policy stance, cutting its key policy rate by 
500 basis points from 19 % to 14 % between September and December 2021. This low interest 
rate policy led to  strong depreciation  of the lira  in  the autumn 2021. Foreign  exchange market 
interventions  and  the  introduction  of  new  financial  instruments,  including  FX-  and  gold- 
protected lira time deposit schemes, have helped  stabilising the lira  for some time, but  the lira 
continued to slide in 2022. Despite the increased macroeconomic vulnerabilities, extremely high 
inflation and the uncertainties exacerbated further by Russia’s invasion of Ukraine in  February 
2022, the  central bank lowered its interest rate to 13 % in  August  2022. The  authorities relied 
mostly  on  the  new  financial  instruments  and  macroprudential  and  other  measures  to  limit  the 
exchange  rate  and  inflationary  pressures.  Nevertheless,  the  inflation  rate  reached  a  two-decade 
high level, officially exceeding 79 % on an annual basis in July 2022. The growing gap between 
producer  and  consumer  prices  and  the  persistence  of  a  very  high  negative  real  interest  rate 
remain important sources of concern in relation to the possibility of taming inflation. The current 
monetary policy framework has proved to be inefficient in anchoring inflation expectations and 
restoring market confidence. Furthermore, the low foreign exchange reserves increased Türkiye's 
vulnerability to shocks, thus raising further its risk premium. 

The President of the Republic has extensive powers in the appointment and dismissal procedures 
of  the  central  bank  top  management.  The  three  successive  dismissals  of  the  central  bank 
governor  in  less  than  two  years  and  frequent  changes  in  the  position  of  deputy  governors  and 
members  of  the  Monetary  Policy  Committee  reflect  growing  political  interference  in  monetary 
policy. The lack of a coherent and transparent monetary policy framework, the increased focus 
on  the  ‘liraisation’  objective  at  the  expense  of  the  inflation  target,  combined  with  the  political 
pressure on the central bank to keep the real interest rates very low, undermine significantly the 
bank’s institutional and operational independence, as well as its credibility. The costs of the FX- 
and gold-protected time lira deposit scheme introduced by the government are significant and are 
borne  by  both  the  Ministry  of  Treasury  and  Finance  and  the  central  bank.  According  to  the 

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central  bank  law,  monetary  financing  of  the  public  sector  is  prohibited  and  the  public  sector 
cannot have privileged access to financial institutions.  

On  economic  policy,  Türkiye  made  some  progress  in  public  finance.  The  Medium-Term 
Program  and  Medium-Term  Fiscal  Plan  have  been  combined  under  a  single  document. 
Furthermore, Türkiye adopted the performance-based budgeting system  in its 2021 budget  and 
continued its efforts to strengthen its programme budgeting. However, the 2022 budget is based 
on  optimistic  and  outdated  economic  assumptions,  and  failed  to  reflect  the  impact  of  several 
measures  introduced  since  its  adoption.  In  view  of  the  markedly  different  macroeconomic 
situation  and  the  much  higher  inflation,  the  government  proposed  a  supplementary  budget  in 
June.  Türkiye  is  not  aligned  with  the  directive  on  requirements  for  budgetary  frameworks  and 
lacks numerical fiscal rules and independent fiscal body to monitor compliance with these rules. 
The  excessive  deficit  procedure  (EDP)  notification  tables  for  2020,  provided  in  October  2021, 
were largely completed. However, there is still room for improvement as regards the timeliness 
and  the  quality  transmission  of  EDP  notification  and  government  finance  statistics.  Türkiye 
needs to improve the credibility of its macroeconomic forecasts, while also presenting alternative 
scenarios. 

The Economic Reform Programme 2022-2024 was submitted on time. Türkiye further improved 
the presentation of its structural reform priorities and introduced measures to support the green 
transition and digital transformation. However, further efforts are needed to improve the quality 
of these measures in terms of description, timeline, estimated impact, risks and key performance 
indicators.  The  policy  guidance  set  out  in  the  conclusions  of  the  Economic  and  Financial 
Dialogue of July 2021 was partially implemented, with a lower rate of implementation compared 
to the previous year.  

Chapter 19: Social policy and employment 

EU  rules  in  the  social  field  include  minimum  standards  for  labour  law,  equality,  health  and 
safety at work and non-discrimination. They also promote social dialogue at European level. 

Türkiye has some level of preparation in the area of social policy and employment. There was 
no progress during the reporting period. The 2021 recommendations were not implemented and 
therefore remain valid. In the coming year Türkiye should in particular: 

  remove  obstacles  limiting  the  enjoyment  of  trade  union  rights  and  use  social  dialogue 

mechanisms effectively; 

  improve  the  implementation  of  legislation  pertaining  to  workers’  rights,  in  fields  related  to 

labour law and health and safety at work; 

  promote  employment  of  women  by  stepping  up  appropriate  work-life  balance  policies  and 
care  services,  and  assess  the  impact  of  active  labour  market  programmes  and  employment 
incentives. 

Türkiye  is  moderately  prepared  in  the  field  of  labour  law.  The  rate  of  undeclared  work 
continued to decline in non-agricultural sectors in 2021, falling below 17.5 %. Overall, 29 % of 
employment was undeclared, higher for women than men. Such levels of informality restrict full 
enjoyment of labour rights in practice. Türkiye has 951 labour inspectors and they carried out 24 
099 inspections in 2021. Average weekly working hours are highest in Europe, right below the 
45  hours  of  legal  limit  in  place.  The  legislative  framework  on  teleworking  also  needs  to  be 

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improved in that regard. Türkiye needs to improve the evidence base on the situation of domestic 
and  platform  workers.  The  ratification  of  the  ILO  Maritime  Labour  Convention  was  not 
concluded. Implementation of Türkiye’s National Programme for Elimination of Child Labour is 
at  an  advanced  stage.  However,  child  labour  is  still  common,  particularly  among  children  of 
migrant origin. The apprenticeship system needs to be improved in a way to ensure that it does 
not abuse children’s rights. 

In the field of health and safety at work, awareness-raising efforts were stepped up in 2021 in 
high-risk  sectors,  the  mining  sector  in  particular.  Türkiye  lacks  a  dedicated  policy  framework 
and a national social dialogue mechanism for the occupational health and safety matters. Official 
sources indicated that in 2020, 1 240 people have lost their lives at work, up from 1 147 a year 
ago.  

There  was  no  progress  in  social  dialogue.  Türkiye  does  not  use  tripartite  social  dialogue 
mechanisms,  other  than  a  few  legally  defined  exceptions  such  as  the  minimum  wage  setting 
committee. 14.32 % of registered private sector  employees and 64.66 %  of the public servants 
allowed to unionise are trade union members. Restrictions on the freedom of association and the 
right  to  organise  remained.  Criminal  prosecution  of  several  trade  union  managers  and  the 
disproportionate  use  of  force  against  trade  union  action  continued.  Türkiye  needs  to  establish 
effective safeguards against discrimination based on trade union affiliation, especially in (but not 
limited to) the public sector and including the work of the Inquiry Commission on the State of 
Emergency. In order to promote the right to collective bargaining in the private sector, existing 
double thresholds for trade unions need to be reconsidered. In the public sector, a wider range of 
public  servants  are  not  able  to  organise  in  unions,  including  the  prison  staff,  contrary  to  ILO 
recommendations.  The  right  to  strike  for  public  servants  needs  to  be  recognised,  and  the 
collective  agreements  need  to  have  wider  material  scope,  not  limited  to  social  and  financial 
rights. 

On  employment  policy,  the  labour  market  situation  slightly  improved.  The  employment  rate 
(15+) increased to 45.2 % in 2021 from 42.7 % in 2020. The rate increased for men to 62.8 % 
from 59.4 %, for women to 28 % from 26.2 %. Unemployment rate (15+) decreased from 13.1 % 
to 12 % in 2021. The unemployment rate for women remained almost at the same level with 14.7 
%.  Composite  measure  of  labour  underutilisation  decreased  to  24.4  %  in  2021  (for  men  from 
22.1  %  to  20.6  %,  for  women  from  31.7  %  to  31.6  %).  Women  labour  force  participation 
remained low at 32.8 % albeit a slight increase on previous years. 

The  youth unemployment rate (15-24) decreased from 24.9 % in 2020 to 22.6 % in 2021. The 
rate  of  young  people  neither  in  employment  nor  in  education  or  training  (NEET)  aged  15-24 
decreased from 28.4 % in 2020 to 24.7 % in 2021; however, the rate is still high, particularly for 
women  (32.4  %).  Türkiye  adopted  the  first  National  Youth  Employment  Strategy  and  Action 
Plan (2021-2023) in October 2021. The Strategy lacks well-developed result indicators. 

The  number  of  job  and  vocational  counsellors  in  the  Turkish  Employment  Agency  (ISKUR) 
remained around the same level (4 755 against 4 781 in 2020). The number of people benefiting 
from  active  labour  market  programmes  increased  by  9  %,  however,  it  remains  still  below  pre-
pandemic levels and its coverage was insufficient. While the information on the effectiveness of 
the programmes and employment subsidies was limited, three programmes were terminated by 
the end of 2021. The number of NEETs reached out under the new counselling model initiated 
by ISKUR in 2020 observed a substantial decrease of 54 % (from 177 002 NEETs in 2020 to 80 

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730 in 2021). Türkiye ended the “Social Protection Shield” programme initiated to alleviate the 
negative impact of the COVID-19 pandemic on the labour market. 

Informality continued to undermine the social security system and social welfare in Türkiye in 
2021. Efforts continued to give Syrian refugees access to the formal labour market, but only less 
than 63 000 work permits were granted for Syrians in 2020.  

Concerning the preparations for using the European Social Fund, Türkiye has a good level of 
preparation.  The  Ministry  of  Labour  and  Social  Security  continues  to  retain  its  capacity  and 
manages an operational programme under IPA II, covering areas of employment, education and 
social  inclusion.  (Concerning  the  effectiveness  of  management  of  IPA  funds,  see  chapter  22  - 
Regional policy and coordination of structural instruments). 

Concerning  social  inclusion  and  social  protection,  Türkiye  still  needs  a  specific  policy 
framework for poverty reduction. The very high and accelerating inflation levels pose risks for 
the most vulnerable segments of the population. In 2021, survey persistent poverty rate reached 
13.8  %  (2020:13.7  %).  The  severe-material-deprivation  rate  fell  to  27.2  %  (2020:  27.4  %).  In 
2021, social assistance payments amounted to TRY 97.8 billion or 1.74 % of GDP. Community-
based care services for elderly people and for children need to be expanded. In the absence of a 
minimum  income  scheme  in  place,  the  risk  of  material  deprivation  vulnerable  groups, 
particularly for children, remained high. 

Türkiye  actively  pursues  a  de-institutionalisation  policy  for  persons  in  need  of  protection  or 
care. Preparations were ongoing to end the practices of seclusion and restraint in mental health 
hospitals and social care institutions. The National Mental Health Action Plan 2021-2023 aims at 
expanding community mental health care centres. For children in need of protection, foster care 
and adoption services were strengthened. 

Türkiye  still  needs  an  integrated  strategy  and  concrete  action  plan  for  non-discrimination  in 
employment  and  social  policy.  Data  on  applications  to  human  rights  institutions  is  available; 
however,  further  efforts  are  needed  to  have  data  on  discrimination  in  the  field  of  employment 
and social policy. Discrimination on the grounds of sexual orientation and gender identity is not 
prohibited  by  law.  The  role  of  Human  Rights  and  Equality  Institution  (HREI)  and  the 
Ombudsman  remained  limited  in  combating  discrimination  in  employment.  Further  efforts  are 
needed  to  remove  discriminatory  legislation  and  practices  against  persons  with  disabilities  to 
access employment in certain occupations. The number of public servants with disabilities was 
62 356 in  2021, below the rate of 3 %. Employment of persons with  disabilities in  the private 
sector  is  much  more  challenging,  partly  due  to  limited  physical  accessibility,  prejudices  and 
skills  mismatch.  Türkiye  needs  to  improve  its  evidence  base  on  the  situation  of  persons  with 
disabilities  in  the  labour  market,  including  the  implementation  of  reasonable  accommodation 
principle. Discrimination towards Roma in employment are not tackled through targeted policy 
measures.  Efforts  are  needed  to  prevent  discrimination  for  LGBTIQ  in  employment  and  social 
policy. (See Chapter 23 - Judiciary and fundamental rights). 

On equality between women and men in employment and social policy, the gender gap in the 
labour  market  remained  very  high.  The  legislation  needs  to  be  improved for  a  better  work-life 
balance.  The  implementation  regulation  was  still  not  in  place  in  relation  to  part-time  work  for 
working  parents  in  the  public  sector.  To  support  work-life  balance,  half-time  work  allowances 
were paid to 4 841 beneficiaries in 2021. The employment rate for women (18-64 age group) in 
case there are children in household remained well below the EU average. Insufficient access to 

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quality and affordable formal care services continued to hinder women’s employment, due to a 
gender bias in caring responsibilities and discriminatory stereotypes. The enrolment rate in early 
childhood education (children aged 3-5) was still low at 28.95 %. The implementation of some 
programmes  supporting  employment  of  mothers  with  children  was  terminated  by  the  end  of 
2021. There was still no official data for sexual harassment in the workplace. The gender pay gap 
is  high.  Representation  of  women  in  decision-making  positions  remained  very  limited.  (See 
Chapter 23 - Judiciary and fundamental rights). 

Chapter 20: Enterprise and industrial policy 

EU  enterprise  and  industrial  policy  strengthens  competitiveness,  facilitates  structural  change  and 
encourages a business-friendly environment that stimulates small and medium-sized firms. 

Türkiye  is  moderately  prepared  in  the  area  of  enterprise  and  industrial  policy.  There  was 
limited progress in the reporting period while measures incompatible with EU industrial policy 
principles  remained  in  place.  Major  challenges  concern  the  compatibility  of  localisation  and 
public procurement practices with the EU industrial policy principles, the lack of transparency in 
State aid for large investments, the large informal economy, long-term financing needs of small 
and  medium-sized  enterprises  and 
legal  framework  for  microfinance. 
Recommendations of last year’s report were addressed in a limited way by assessments carried 
out on some SME programmes. 

insufficient 

the 

In the coming year, Türkiye should in particular: 

  remove  schemes,  such  as  local  content  requirements  and  public  procurement  price 
premiums  that  are  incompatible  with  industrial  policy  principles  and  substitute  them  with 
measures that encourage innovation effectively; 

  publish the results of the implementation of the industry strategy from 2019 to 2021 as well 

as the amounts distributed under the Industry Support Programme; 

   continue  conducting  assessments  on  the  SME  support  framework  for  impact  and 

identification of gaps and overlaps. 

On  enterprise  and  industrial  policy  principles,  Türkiye  maintained  the  scope  of  the  15  % 
domestic  price  advantage  in  public  procurement  with  compulsory  use  for  medium  and  high-
technology  industrial  products.  The  percentage  of  international  tenders  where  domestic  price 
advantage applied increased further in 2021 (see also Chapter 5). Localisation schemes remained 
in place or are planned in a number of sectors like medical devices, biotechnological products, 
and  agricultural  and  forestry  tractors.  Following  the  WTO  appeal  ruling,  Türkiye  must  now 
remove its inconsistent  localisation and prioritisation measures in  the pharmaceutical  sector.  A 
stronger research and innovation policy (see Chapter 25) under a more predictable innovation-
friendly  regulatory  environment  can  constitute  a  more  effective  and  EU-compatible  strategic 
alternative. 

The  results  of  performance  indicators  of  the  Industrial  Strategy  adopted  in  2019  were  not 
published.  A  strategy  and  roadmap  on  mobility  tools  and  technologies  as  well  a  roadmap  on 
smart  life  and  health  products  and  technologies  were  published  in  June  2022  within  the 
framework of the Industrial Strategy. Türkiye changed the definition of small and medium-sized 
enterprises  in  March  2022  by  increasing  the  financial  threshold  for  turnover  or  balance  sheet 
total  from  125  million  TRY  to  250  million  TRY.  The  threshold  for  micro  enterprises  was 

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increased from 3 million TRY to 5 million TRY and for small enterprises from 25 million TRY 
to  50  million  TRY,  while  the  criteria  on  number  of  employees  remained  the  same  and  in  line 
with the EU definition. Türkiye took some positive steps in improving the business environment 
by  setting-up  specialised  courts,  ratification  of  the  Singapore  Convention  for  international 
commercial disputes, bringing changes in the concordatum regime and providing online access 
to court decisions. Türkiye successfully implements the Small Business Act framework. 

On  enterprise  and  industrial  policy  instruments,  Turkish  legislation  is  not  yet  fully 
harmonised  with  the  Late  Payment  Directive.  The  11th  Development  Plan  and  the  Industrial 
Strategy  focus  on  technological  transformation  of  manufacturing.  Türkiye  intends  to  support 
investments  in  strategically  chosen  sectors  such  as  machinery,  computer,  electronic,  optics, 
electrical  hardware,  pharmaceuticals,  chemistry,  and  transport  vehicles  under  a  technology-
focused  Industry  Support  Programme.  The  ‘Machinery  call’  supported  20  projects.  The 
repartition  of  State  aid  for  these  investments  was  not  disclosed,  contrary  to  the  commitments 
under  the  EU-Turkey  Customs  Union.  The  results  of  other  calls  opened  in  2021  were  not 
announced. Türkiye continued to implement various schemes supporting companies, particularly 
small and medium firms. New support schemes were created on internationalisation of the ICT 
sector, export of services and logistics distribution networks abroad. Support for innovation eco-
systems  is  fragmented  across  numerous  programmes.  Smart  specialisation  strategies  were 
formulated in some regions, but there is limited information about their implementation. 

The SME support administration (KOSGEB) ran a variety of technical assistance and financing 
schemes.  As  a  positive  development,  KOSGEB  conducted  and  published  evaluations  on  five 
support programmes  under its mandate. As of August  2022, 94 technology development  zones 
were  in  place,  81  of  them  operational.  1  511  patents  were  obtained  from  47  456  completed 
projects in these zones (in comparison to 1 277 patents obtained from 39 940 completed projects 
in  the  previous  reporting  period).  Türkiye  remained  active  in  the  COSME  programme,  the 
Erasmus  for  Young  Entrepreneurs  and  the  Enterprise  Europe  Networks.  Türkiye  expressed 
interest  to  participate  in  the  Single  Market  Programme  (SMP).  Formal  negotiations  for  an 
Association Agreement started in March 2022.  

Chapter 25: Science and research 

The EU provides significant support for research and innovation. All Member States can benefit 
from  the  EU’s  research  programmes,  especially  where  there  is  scientific  excellence  and  solid 
investment in research. 

Overall, Türkiye’s preparations in the area of science and research are well advanced. Türkiye 
made  good  progress  during  the  reporting  period.  Notably,  Türkiye  signed  the  association 
agreement for Horizon Europe for the 2021-2027 period. Türkiye intensified its efforts to raise 
awareness on Horizon Europe to further increase its participation. Türkiye well addressed the 
recommendations  made  in  the  previous  report.  In  the  coming  year,  Türkiye  should  in 
particular: 

–  continue  its  efforts  towards  aligning  its  national  research  area  (TARAL)  with  the  new 

European Research Area (ERA); 

–  step  up  efforts  to  increase  innovation  activities,  particularly  in  the  field  of  environment 
related technologies, to make up for the decline in the Innovation Scoreboard of 2021; 

–  expand cooperation in the fields of Innovation and EU Missions through full utilisation of 

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Horizon Europe. 

On  research  and  innovation  policy,  the  share  of  the  R&D  expenditure  to  GDP  slightly 
increased  to  1.09  %  in  2020  compared  with  1.06  %  in  2019.  Figures  still  remain  far  from  the 
commitments made by Türkiye in its Industry and Technology Strategy to increase its national 
expenditure  to  1.8  %  in  2023.  This  slow  progress  keeps  the  gap  between  R&D  expenditure  in 
Türkiye and the EU27 average (2.32 % in 2020) at a significant level. The total number of full-
time equivalent R&D personnel increased by 9 % to 199 371 in 2020 from 182 847 in 2019 and 
the  share  of  female  personnel  in  research  remains  at  32  %;  although  this  is  a  positive  value, 
efforts should continue to further spur gender equality in research.  

The  implementation  of  Türkiye’s  action  plan  to  boost  the  national  research  and  innovation 
capacity  contributed  very  positively  to  increase  Türkiye’s  performance  in  the  last  period  of 
Horizon 2020. However, the overall performance has been somewhat below expectations. No in-
depth  assessment  on  the  programme’s  results  has  been  made  so  far,  despite  continuous 
recommendations from the Commission in order to seek lessons learnt that might help to obtain 
better results from Horizon Europe. In October 2021, the Commission and Türkiye signed the 
association agreement allowing Türkiye to participate in the Horizon Europe programme for the 
2021-2027 period. Türkiye has made efforts to raise awareness and increasing dissemination of 
the programme in order to expand its participation. The first Horizon Europe results indicated the 
continuation of the strong and positive trend of Türkiye’s performance.  

On  the  policy  side,  Türkiye  continued  its  alignment  towards  the  ERA  through  a  national 
roadmap which includes several initiatives  contributing to this objective. Further efforts should 
be sought to align with the last update of the ERA, particularly its new set of ERA actions.  

On  Innovation  Union,  as  reported  in  the  European  Innovation  Scoreboard  2022,  the 
performance  relative  to  the  EU  has  not  changed  since  the  previous  reporting  period,  and  the 
country  remains  an  ‘emerging  innovator’.  To  counteract  this  adverse  trend  and  re-boost  the 
innovation sector, Türkiye is encouraged to advance on all aspects of the digital transition.  

Chapter 26: Education and culture 

The  EU  supports  cooperation  in  education  and  culture  through  funding  programmes  and  the 
coordination of Member State policy through the open method of coordination. 

Türkiye  is  moderately  prepared  on  education  and  culture.  There  was  some  progress  on  this 
chapter, notably regarding the vocational education, national qualifications systems and in terms 
of  Türkiye’s  participation  in  the  EU  programmes.  Türkiye  recognises  the  value  of  culture  in 
national  development  policies  and  encourages  the  promotion  and  protection  of  its  cultural 
heritage. 

In the coming year, Türkiye should in particular: 

  further  improve  inclusive  education,  with  a  particular  focus  on  girls  and  children  from 
disadvantaged  groups,  and  closely  monitor  and  continue  work  to  reduce  the  proportion  of 
school drop-outs; 

  ensure  the  good  functioning  of  the  Turkish  Qualifications  Framework  and  Turkish  Higher 

Education Quality Council; 

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take  concrete  steps  to  implement  the  2005  UNESCO  Convention  on  the  Protection  and 

Promotion of the Diversity of Cultural Expressions. 

In  the  area  of  education,  training  and  youth,  Türkiye  has  been  participating  in  the  EU 
programmes as a candidate country since 2004. In 2021 Türkiye formally re-joined the Erasmus+ 
and European Solidarity Corps programmes, as an associated country for the period 2021-2027. 
Under  the  2021  call  for  proposals,  over  1  100  projects,  including  200  in  the  youth  field  were 
awarded  by  the  Turkish  National  Agency  managing  decentralised  projects.  Awarded  grants 
under the 2021 envelopes for the two programmes amount to EUR 103.5 million. It is planned 
that close to 40 000 participants, including over 3 370 participants with fewer opportunities will 
take part in the 2021 awarded projects.   

A  certain  decrease  in  the  number  of  submitted  applications  and  awarded  projects  for  both 
programmes  can  be  observed  compared  with  2020.  Submitted  applications  for  the  Erasmus+ 
programme  decreased  from  13  079  in  2020  to  6  754  in  2021.  Likewise,  applications  for  the 
European Solidarity Corps programme decreased from 896 in 2020 to 519 in 2021. The decrease 
in  submitted applications is  a result of the new  accreditation-based application process  of both 
programmes. In addition, the COVID-19 pandemic negatively affected the ongoing and planned 
activities under both programmes. It is also linked to the budget profile of the programme over 
the 2014-2027 period.  

In  the  area  of  education,  in  Early  Childhood  Education  (ECE)  in  Türkiye,  the  net  enrolment 
rate (NER) for preschool education (age 5) decreased quite dramatically from 71.22 % in 2019-
2020 to 56.89 % in 2020-2021 and the combined NER for Turkish children between 3 to 5 years 
old decreased from 41.78 % to 28.35 %. Among the reasons was a reluctance of families to send 
children  to  pre-school  during  the  COVID-19  pandemic.  Türkiye  needs  to  expand  flexible  and 
community-based ECE models, determine targets  and strategies to  include vulnerable children, 
and improve the quality of ECE services. 

The net enrolment rates in primary school (first 4 years) slightly decreased from 93.62 % in 2020 
to 93.23 % in 2021 and considerably decreased in lower secondary school (second 4 years) from 
95.90  %  to  88.85  %  over  the  same  period.  In  secondary  education  (third  4  years)  the  net 
enrolment rate increased from 85.01 % to 87.93 %. There was also an increase in the enrolment 
rates  of  the  higher  education,  from  43.37  %  to  44.41  %.  The  number  of  students  in  special 
education increased from 425 774 in 2020 to 425 816 in 2021. For persons with special needs, 
Türkiye  continued  to  invest  in  transition  towards  inclusive  education  instead  of  segregated 
settings, yet the school closures due to COVID-19 have highly reduced access of such students to 
education. 

Türkiye  is  at  an  advanced  stage  of  implementing  the  measures  under  the  Bologna  process, 
although  significant  quality  differences  persist  between  Türkiye's  207  higher  education 
institutions.  The  reorganisation  of  the  Turkish  Higher  Education  Quality  Council  (THEQC)  in 
2015 led to greater administrative and financial independence of the organisation, however, the 
operational independence of the Council is currently not sufficient. This is due to the presence of 
non-independent  third  parties  (academic  staff  assigned  from  higher  education  institutions  to 
substitute for THEQC staff) in  the day-to-day  operations of the Council.  To further strengthen 
the  Bologna  process,  accreditation  of  higher  education  institutions  with  the  government 
authorities should be stronger incentivised. 

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In the area of technical and vocational education and training (TVET), the operationalisation 
of  the  National  Vocational  Qualifications  System  is  ongoing  under  the  leadership  of  the 
Vocational  Qualifications  Authority  (VQA).  As  of  June  2022,  the  number  of  national 
occupational  standards  increased  to  893  (from  859  in  April  2021)  and  the  number  of 
occupational qualifications approved to 586 (from 574 in April 2021). Since 2021, the number of 
authorized certification bodies increased to 272 from 255, and the number of VQA Vocational 
Qualifications  Certificates  issued  to  individuals  increased  to  2 253  424  from  1  602  000.  The 
number  of  recognised  occupations  involving  heavy  and  dangerous  works  -  for  which  VQA 
Vocational Certificates is mandatory - reached 204.  

Monitoring  of  the  implementation  of  the  Turkish  Qualifications  Framework  (TQF)  continued 
under  the  coordination  of  the  VQA.  The  vocational  training  is  not  in  line  with  the  needs  of 
national qualification candidates. Modular vocational training programmes should be offered for 
concerned  occupations  which  should  be  oriented  at  the  expected  learning  outcomes  of  the 
candidates. 

For dangerous and very dangerous occupations, VQA vocational qualification certificates were 
made  compulsory.  The  costs  were  covered  until  end  of  2021  by  the  Unemployment  Insurance 
Fund.  Since  then,  however,  there  is  no  financial  support  to  individuals  seeking  certificates  on 
dangerous and very dangerous occupations. Renewed governmental support, especially for these 
occupations remains crucial. Furthermore, the number of occupations for which VQA vocational 
qualification certificates are required should be further increased in line with the requirements of 
the National Vocational Qualification System (NVQS) in Türkiye. 

An  amendment  to  the  vocational  training  law  of  December  2021  introduced  a  stipend  paid  to 
students  at  the vocational  training centres.  Besides the stipend-scheme a  new flexible structure 
allows  students,  who  are  employed,  a  combination  of  corporate  work  and  study,  substituted 
financially.  This  made  the  vocational  training  centres  attractive  and  the  number  of  students 
increased.  

In  the  area  of  youth,  Türkiye  has  declared  2022  as  the  Year  of  Youth  Participation.  Youth 
services provided by the Ministry of Youth and Sports are expanded. Türkiye participates in the 
European Year of Youth 2022. Turkish youth organisations continued to show very high level of 
interest in the Erasmus+ and European Solidarity Corps programmes, which both continue to be 
the  major  source  of  funding  for  international  youth  exchange  activities  in  Türkiye.  However, 
Türkiye  has  no  youth  strategy  in  place  and  does  not  prioritise  civic  engagement  and 
empowerment of youth in line with the European Youth Strategy.  

As regards culture, in the post-pandemic era, Türkiye’s cultural sector continued to suffer from 
inadequate  and  unsustainable  funding.  In  addition,  insufficient  cultural  infrastructure,  lack  of 
professionalism  and 
limited  management  capacities  remain  major  obstacles  for  non-
governmental cultural actors to mobilise their full potential. In February 2022, Türkiye stopped 
procuring  the  services  of  opera,  ballet,  theatre  and  symphony  workers  older  than  sixty-five  in 
state-sponsored  art  institutions,  in  line  with  Türkiye’s  official  retirement  age.  Local  authorities 
continued  to  cancel  artistic  and  cultural  events  on  arguments  of  public  morality,  or  without  a 
reason  given.  Cultural  organisations  often  face  obstacles  related  to  permits  or  rent  of  cultural 
facilities. Against this background, concrete action for the implementation of the 2005 UNESCO 
Convention on the Protection and Promotion of the Diversity of Cultural Expressions needs to be 
taken. 

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The number of books with a warning “harmful for minors/ +18” has increased. Six publications 
were  declared  “obscene”  in  2021.  Concerned  are  mostly  books  on  gender-based  rights,  gender 
identity or with LGBTQI characters, posing a threat to freedom of publication.  

Chapter 29: Customs union 

All  Member  States  are  part  of  the  EU  customs  union  and  follow  the  same  customs  rules  and 
procedures.  This  requires  legislative  alignment,  adequate  implementation  and  enforcement 
capacity, and access to the common computerised customs systems. 

Türkiye  maintains  a  good  level  of  preparation  for  the  customs  union.  There  was  limited 
progress in the reporting period. Türkiye removed some additional duties applied on imports of 
products originating in third countries, which are in free circulation in the EU, or imported from 
third countries. However, a large volume of Türkiye’s total imports still remains subject to the 
additional  duties,  in  violation  of  the  basic  provisions  of  the  EU-Turkey  Customs  Union.  Duty 
relief, free zones and surveillance measures remain not fully aligned with the EU acquis, again in 
clear contradiction with Türkiye’s obligations under the Customs Union. The recommendations 
from last year were implemented to a limited extent. 

In the coming year, Türkiye should in particular:  

 step up efforts to fully align new legislation with the EU Customs Code; 

 bring risk-based controls and simplified procedures in line with the EU acquis; 

  fully  eliminate  import  and  export  restrictions  as  well  as  additional  duties  on  goods  in  free 

circulation in the EU-Turkey Customs Union. 

There was limited progress in the area of customs legislation. Türkiye removed some additional 
duties applied on imports of a large number of products originating in third countries, which are 
in free circulation in the EU or imported from third countries. Although a certificate of origin for 
goods  in  free  circulation  in  the  EU  exported  to  Türkiye  is  no  longer  legally  required  by  the 
Turkish  customs  authorities,  except  for  trade  defence  cases,  many  economic  operators  kept 
requesting them. The Turkish authorities took steps to remedy the situation by issuing successive 
clarifications  and  guidelines.  They  also  informed  the  Commission  that  only  37  certificate  of 
origin  documents  were  requested  by  Turkish  customs  out  of  almost  4  million  units  of  goods 
coming from the EU in 2021. 

Turkish Customs Law is yet to be harmonised with the EU Customs Code and more efforts are 
needed  to  improve  risk-based  controls  and  simplified  procedures  to  facilitate  legitimate  trade, 
while ensuring security and safety. The designation of specialised customs offices is contrary to 
the provisions of the Customs Union. Rules on surveillance, free zones and duty relief are yet to 
be aligned with the EU acquis.  

In  addition,  Türkiye  amended  a  provision  of  the  Customs  Law,  forestalling  the  possibility  of 
obtaining court decisions to recover overpaid amounts in conjunction with implementation of the 
surveillance regime. Türkiye not  only  failed to  remove export restrictions on copper scrap  and 
certain leather products, but introduced new restrictions on a range of goods. These measures are 
in  breach  of  the  Customs  Union  rules,  as  reported  over  the  past  years.  Türkiye  continued  to 
unilaterally  apply  disproportionally  high  duties  on  imports  of  sweet  corn  in  contradiction  with 
Customs Union rules. 

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On administrative and operational capacity, efforts to improve customs enforcement capacity 
for border controls continued. Further alignment and strengthened efforts are required to improve 
customs  enforcement  of  intellectual  property  rights.  Risk-based  controls  to  enforce  safety  and 
security  measures  need  to  be  significantly  improved.  Türkiye  implements  the  computerised 
transit  system  as  part  of  its  membership  in  the  Convention  on  a  Common  Transit  Procedure. 
However, tariff IT systems are not yet in place. The IT strategy in line with business initiatives 
still  needs  to  be  implemented  and  the  documented  customs  business  processes  aligned  to  the 
legal basis need to be updated. 

CLUSTER 4: THE GREEN AGENDA AND SUSTAINABLE CONNECTIVITY  

This  cluster  covers:  transport  policy  (Chapter  14),  energy  (Chapter  15),  trans-European 
networks (Chapter 21) and environment and climate change (Chapter 27).  

Türkiye is moderately prepared in transport policy. It made limited progress during the reporting 
period,  mainly  linked  to  the  adoption  of  a  plan  to  increase  significantly  the  use  of  railway 
transport.  Türkiye  is  moderately  prepared  in  the  area  of  energy,  and  made  limited  progress 
overall.  Progress  continued  on  renewable  energy  deployment,  on  reforms  in  the  natural  gas 
sector  and  in  legislative  alignment  on  nuclear  safety.  Türkiye  is  well  advanced  on  trans-
European networks and made some progress, mainly on energy networks, thanks to the smooth 
operation of the trans-Anatolian pipeline. The construction of the Halkali-Kapikule railway line 
connecting the Bulgarian border to Istanbul continued.  

Türkiye has some level of preparation in the area of environment and climate change but made 
no progress overall during the reporting period. Türkiye faces critical environmental and climate 
challenges, both in relation to mitigation and adaptation. More ambitious and better coordinated 
environment and climate policies need to be drawn up and implemented. Türkiye still needs to 
increase and implement its contribution to the Paris Agreement on climate change, and complete 
its alignment with the acquis on climate action.   

Chapter 14: Transport Policy 

The  EU  has  common  rules  for  technical  and  safety  standards,  security,  social  standards,  and 
market  liberalisation  in  road  transport,  railways,  inland  waterways,  combined  transport, 
aviation and maritime transport. 

Türkiye  is  moderately  prepared  in  transport  policy.  Limited  progress  was  made  during  the 
reporting  period.  Last  year’s  recommendations  were  addressed  partially.  Türkiye  adopted  the 
Transport and Logistics Master Plan 2053 to increase significantly the use of railway transport. 

Türkiye should in particular: 

→  consider  establishing  concrete  plans  and  targets  for  decarbonisation  of  transport  sector 

emissions until 2050; 

→  finalise  its  preparation  of  the  new  railway  framework  law  and  accelerate  the  remaining 

regulatory aspects of the railways reform in line with the fourth railway package; 

→  increase  the  number  of  Turkish  cities  preparing  Sustainable  Urban  Mobility  Plans  and 

continue implementation of the vision zero approach to road safety.  

Regarding  the  EU  acquis  on  general  transport,  Türkiye  is  preparing  an  online  electronic 
legislation  inventory  tool  (ELIT)  to  digitally  take  stock  of  the  Turkish  transport  legislation  in 

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English and setting up a monitoring system for continuous gap assessment and gap plugging with 
the  EU  acquis.  Despite  significant  policy  developments  at  the  local  level  and  an  increasing 
interest from the municipalities for sustainable urban mobility planning, the policy guidance and 
institutional coordination between local and central authorities regarding urban mobility remains 
to be further developed. 

On  road  transport,  the  legal  framework  is  at  a  good  level  of  preparation  regarding  the 
alignment with the EU acquis. No progress was made during the reporting period regarding the 
First  Mobility  Package.  Türkiye  did  not  take  any  further  steps  for  adapting  to  the  technical 
specifications  on  the  smart  tachograph.  The  intelligent  transport  system  (ITS)  architecture 
especially  in  the  urban  areas  needs  to  be  further  developed.  Türkiye  should  assess  and 
synchronise its targets with that of the EU’s strategy for sustainable and smart mobility adopted 
in December 2020. Türkiye is still not aligned with the clean power for transport package.  

Türkiye is moderately prepared in the field of rail transport. Limited progress was made during 
the reporting period. The reform of the incumbent railway operator, focusing on institutional and 
organisational efficiency and effectiveness around a new operational model, was finalised but its 
adoption  is  pending.  The  new  comprehensive  railway  framework  is  being  prepared  and  the 
regulations  on  capacity  allocation,  safety,  vehicle  registration  and  type  approval  are  being 
updated under an EU financed technical study to comply with the EU’s fourth railway package. 
The  regulation  on  railway  interoperability  is  still  under  the  final  stage  of  preparation.  The 
continuing blanket subsidies to the incumbent railway operator prevent the railway liberalisation 
process to take its full potential. The transport branch of the incumbent railway operator (TCDD 
transport)  depends  completely  on  the  infrastructure  manager  (TCDD  infrastructure)  for  its 
budgetary  resources  and  transfers.  The  railway  regulatory  body  was  re-instituted  as  a  deputy 
directorate  under  the  Ministry  of  Transport  and  Infrastructure  with  fewer  financial  and  human 
resources. The new railway framework law and the legislative updates are expected to  address 
these fundamental deficiencies. 

Türkiye  achieved  a  good  level  of  preparation  in  aligning  with  the  EU  acquis  in  the  field  of 
maritime transport. Some progress was made during the reporting period. The status of harbour 
masters  was  reorganised  in  April  2022  in  order  to  increase  managerial  efficiency.  Türkiye 
upgraded  its  financial  support  mechanism  to  renew  the  Turkish  maritime  fleet  with  energy 
efficient and environmentally friendly ships. The mechanism allows the ship owners to receive 
grants up to two and half times the ship’s scrap value, if the new ship uses alternative fuels for its 
propulsion  system.  A  Revised  Regulation  on  Transport  of  Dangerous  Goods  by  Sea  and  Safe 
Loading  entered  into  force  in  April  2022.  Türkiye  substantially  increased  the  capacity  of  its 
Maritime  Safety  Centre  by  adding  a  maritime  simulator  centre  in  December  2021.  Türkiye 
continued its intensive training programme on oil pollution and marine aids. The training at the 
National  Emergency  Response  Centre  in  Tekirdag  are  also  open  to  Türkiye’s  neighbouring 
countries. 

Türkiye has to align with the relevant EU legislation on inland waterway. Türkiye has limited 
inland waterways and it has not signed the main international agreements on this issue. 

Türkiye is  moderately prepared in  the field  of  aviation. There was limited progress  during the 
reporting period. Türkiye implemented some regulatory revisions on balloon operations and air 
navigation.  The  Directorate  General  for  Civil  Aviation  (DGCA)  became  the  responsible 
authority for air transport of dangerous goods in March 2022. Turkish operators started domestic 

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flights  in  certain  routes  using  sustainable  aviation  fuel  content.  DGCA  issued  a  regulation  on 
monitoring,  reporting  and  verification  of  emissions  from  aviation  activities  in  March  2022. 
DGCA took  measures  in its constituent  law to  increase the number of staff and their technical 
capacity. The civil aviation training centre, which was established with EU funding, will be able 
to  take  an  exclusive  institutional  profile  with  these  changes.  Renewal  of  the  working 
arrangements  between  the  DGCA  and  EASA  is  still  pending.  The  lack  of  adequate 
communication  between  air  traffic  control  centres  in  Türkiye  and  Cyprus  continued  to 
compromise air safety in the Nicosia flight information region, requiring an operational solution. 

There was no progress on combined transport. The by-law on Combined Freight Transport has 
not yet been adopted. 

As long as  restrictions remain in  place on vessels  and aircrafts  registered  in  Cyprus, related to 
Cyprus,  or  whose  last  port  of  call  was  Cyprus,  Türkiye  will  not  be  in  a  position  to  fully 
implement the EU acquis relating to this chapter. 

Chapter 15: Energy  

EU  energy  policy  covers  security  of  supply,  the  internal  energy  market,  hydrocarbons, 
renewable energy, energy efficiency, nuclear energy, nuclear safety and radiation protection. 

Türkiye  is  moderately  prepared  in  this  chapter.  There  was  limited  progress  overall.  While 
progress continued on renewable energy deployment, local content requirement practices stayed 
in place. Some progress was made on reforms in the natural gas sector and some progress was 
observed in the ongoing legislative alignment of nuclear safety regulations. 

The 2021 recommendations remained mostly unaddressed. In the coming year, Türkiye should in 
particular: 

 deepen natural gas market reform by setting up a legally binding plan and a timetable for the 
unbundling of activities and by updating the natural gas market law to ensure compatibility 
with the EU's third energy package; 

complete  the  legislative  alignment  on  nuclear  safety  and  stress  tests  on  the  Akkuyu  nuclear 

power plant; 

discontinue  local  content  requirement  practices  in  the  renewable  energy  sector,  as  such 

practices contradict WTO and EU-Turkey Customs Union rules. 

On security of supply, Türkiye continues to  be  a reliable transit country, ensuring the smooth 
operation of the trans-Anatolian pipeline (TANAP) and transmits Azeri natural gas to Europe by 
connecting  to  the  Trans  Adriatic  Pipeline  (TAP).  Türkiye  proceeded  to  expand  its  capacity  to 
import  and  use  Liquified  Natural  Gas.  Türkiye  continued  to  expand  the  capacity  of  its  gas 
storage  facilities.  In  2021,  around  a  quarter  of  Türkiye’s  gas  imports  was  LNG  from  15 
countries.  That  allowed  the  country  to  maintain  sufficient  gas  reserves,  which  helped  face 
increased demand and power shortages at the beginning of 2022. 

Türkiye’s  dependency  on  natural  gas  imports  from  Russia  is  still  significant,  although  it  has 
overall decreased in the last years. The pipeline gas contracts Türkiye has with Russia supplied 
around 44 % (26 bcm) of all Türkiye’s gas imports in 2021. These contracts expire gradually by 
2026.  An  amount  of  5.75  bcm  of  gas,  to  replace  expired  8  bcm  of  gas,  was  renegotiated  by 

111 

 
 
BOTAŞ  and  Gazprom  for  an  additional  four  years  from  January  2022.  Türkiye  renewed  an 
expired gas import deal with Azerbaijan for 11 bcm until the end of 2024. 

Regarding  the  internal  energy  market,  limited  progress  was  made  on  the  natural  gas  market 
reforms,  where the unbundling of the state-owned gas company BOTAȘ was suspended again. 
BOTAȘ  remained  vertically  integrated  comprising  gas  trade,  pipeline  and  LNG  infrastructure 
and  retained  its  dominating  market  position.  That  did  not  contribute  to  transparent,  cost-
reflective  and  non-discriminatory  pricing.  Amendments  were  adopted  to  the  electricity  market 
law, in particular on security of supply.  

On  hydrocarbons,  Türkiye  is  at  an  advanced  stage  of  alignment  with  the  EU  legislation. 
However, it should further align with directive on the safety of offshore oil and gas operations, 
also regarding transit of hydrocarbons. Türkiye continued its exploration work in the Black Sea 
after the reported discovery of around 450 bcm of natural gas in the Sakarya gas field. Türkiye 
planned the first gas production by the end of 2023 and commercially justifiable quantities from 
2025 onward. Türkiye has increased its imports of Russian oil in 2022.  

Throughout  the  reporting  period,  Türkiye  issued  many  NAVTEX  (Navigational  telex)  for 
conducting seismic surveys and scientific research activities in areas encompassing parts of the 
Cypriot Exclusive Economic Zone (EEZ). Türkiye’s military exercises in the maritime zones of 
Cyprus  continued.  There  were  no  unauthorised  drilling  activities  by  Türkiye  in  the  Eastern 
Mediterranean.  However,  in  October  2021  and  January  2022,  Turkish  warships  illegally 
obstructed the survey activity of a vessel in the Cypriot EEZ. A fourth drilling ship was acquired 
by Türkiye and delivered in May 2022 and started conducting drilling activities in August 2022. 

Regarding renewable energy, Türkiye continued implementing its strategy to maximise the use 
of  domestic  and  renewable  sources,  achieving  a  53  %  share  of  renewables  in  the  country’s 
installed capacity and 33 % in the electricity generation. Hydropower at 29 % and wind power at 
10 % of the installed capacity are the leading renewable sources in  Türkiye, followed by solar 
photovoltaic  and  geothermal.  Private  investments  kept  driving  the  growth  in  renewable 
installations, thanks to a preferential feed-in tariff extended by 2030 and payable in Turkish lira 
from July 2021. The uncertainties and risks for investors had since increased due to the Turkish 
lira  volatility.  The  extended  support  scheme  for  renewables  continued  the  additional  financial 
incentive for the use of domestic equipment. Although much reduced, that incentive is a type of 
local  content  requirement  (LCR).  Another  LCR  type  is  applied  primarily  in  the  state-defined 
renewable  energy  zones  (REZ),  where  local  equipment  ratio  requirements  are  determined  per 
tender, vary between 55 % and 75 %, and are legally uncapped. The LCR practices in Türkiye 
continue to raise concerns as they contradict WTO and the EU-Turkey Customs Union rules and 
affect  the  EU’s  and  other  international  companies’  competitiveness  in  the  Turkish  energy 
market. 

There  was  limited  progress  on  energy  efficiency  and  insufficient  clarity  on  policy  planning 
beyond  the  2023  timeline  of  Türkiye’s  Energy  Efficiency  Strategy  and  National  Energy 
Efficiency  Action  Plan  (NEEAP)  adopted  in  2018.  The  national  energy  efficiency  financing 
mechanism, envisaged under the NEEAP, has not been set up despite the EU’s recommendation 
for its timely adoption. Türkiye provided some financial support to energy efficiency projects of 
industrial  enterprises  through  their  Energy  Efficiency  Improvement  Projects  (EEIP)  and 
voluntary agreements mechanisms.  Following recent amendments to the energy efficiency law, 
the  scope  of  the  EEIP  was  extended  to  cover  also  energy  efficiency  projects  in  buildings, 

112 

 
 
agriculture and service sectors. 

On  nuclear  energy,  nuclear  safety  and  radiation  protection,  Türkiye  proceeded  with  its 
regulatory  framework  development  despite  legal  and  staffing  issues  concerning  the  Nuclear 
Regulatory  Authority  (NDK).  In  March  2022,  the  nuclear  regulation  law  was  published.  It 
regulates, among others, the legal basis for establishing the  NDK, which was previously based 
on  a  decree  with  the  force  of  law  held  unconstitutional  by  Türkiye’s  Constitutional  Court  in 
December  2020.  The  internal  organisation  of  the  regulatory  body  was  defined  by  presidential 
decree.  

Works on Türkiye’s first nuclear power plant at Akkuyu, estimated to cost USD 20 billion, are 
financed  by  Russia’s  Rosatom.  The  plant,  operated  by  Rosatom,  is  expected  to  become 
operational  at  the end of 2023,  when the  first  reactor is  scheduled to  be launched. Three more 
reactors are expected to become operational every other year. The Akkuyu nuclear power plant 
comprising  four  reactors  was  designed  to  meet  around  10  %  of  Türkiye’s  power  consumption 
demand. 

Following  Türkiye’s voluntary  commitment to  conduct  stress  tests  on the Akkuyu power plant 
using the EU model, an agreement between the Commission and the Turkish nuclear regulatory 
authority has been reached to move from the previously envisaged two-phase approach to a more 
streamlined single-phase approach. The next step will be the organisation of a transparent peer 
review  of  Türkiye’s  National  Report  by  the  Commission  and  the  European  Nuclear  Safety 
Regulators Group, in which Türkiye participates as an Observer. Türkiye still needs to accede to 
the joint convention on the safety of spent fuel management and the safety of radioactive waste 
management  and  become  a  member  of  the  European  Community  Urgent  Radiological 
Information Exchange system. 

 Chapter 21: Trans-European networks 

The EU promotes  trans-European networks in  the areas  of  transport and energy to  strengthen 
the internal market and contribute to growth and employment. 

Türkiye  is  well  advanced  on  trans-European  networks.  There  was  some  progress,  mainly  on 
energy  networks,  thanks  to  the  smooth  operation  of  the  Trans-Anatolian  Pipeline  (TANAP), 
transmitting gas to the European section of the Southern Gas Corridor (SGC). The construction 
of the Halkali-Kapikule railway line connecting the Bulgarian border to Istanbul continued. The 
construction of the Stage I of the Halkali-Kapikule railway line has reached 57 %. Tendering for 
the  Stage  II  and  Stage  III  is  continuing.  Last  year’s  recommendations  were  only  partially 
addressed. 

In the coming year Türkiye should in particular: 

 establish a transparent, cost-reflective and non-discriminatory gas transit regime in line with 

the EU acquis; 

 accelerate efforts for preparation of the Yavuz Sultan Selim bridge railway connections which 

is a condition in the financing agreement with the EU; 

 accelerate efforts to align with key pieces of the EU acquis to facilitate alignment in TEN-T 

networks. 

The  progress  continued  on  energy  networks,  thanks  to  the  smooth  operation  of  the  trans-

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Anatolian  pipeline  (TANAP)  transmitting  gas  to  the  European  section  of  the  Southern  Gas 
Corridor (SGC). As regards gas networks and Transmission System Operator (TSO) cooperation, 
the  membership  of  Türkiye’s  National  Petroleum  Corporation  (BOTAȘ)  in  the  European 
Network of Transmission System Operators for Gas (ENTSO-G) is still not foreseen. The state-
owned BOTAȘ remains vertically integrated and dominates the market with its trading and grid 
operator functions, which stifles market competition. The natural gas market law update remains 
long overdue. (See Chapter 15 - Energy). Although the Turkish electricity Transmission System 
Operator's  (TEIAȘ)  observer  membership  of  the  European  Network  of  Transmission  System 
Operators  for  Electricity  (ENTSO-E)  was  not  renewed,  TEIAȘ  continued  to  be  present  in 
technical discussions of relevant working groups. 

Concerning  electricity  networks,  the  modernising  and  upgrading  of  the  Turkish  electricity 
network in line with the ENTSO-E standards continued. An important challenge for the Turkish 
electricity  system  remains  to  provide  safe  integration  of  increased  amounts  of  intermittent 
renewable energy, including through the use of energy storage and other new technologies.   

Regarding transport networks, Türkiye continued to regularly encode TEN-T network data to 
the  transport  information  management  systems.  Türkiye  continued  to  progress  on  Halkali-
Kapikule railway line project in all of its three stages. The rate of progress under the EU financed 
contract  reached  57  %.  The  tendering  process  for  Ispartakule-Halkali  section  (Stage  III)  was 
cancelled after a court decision, increasing the risks of the timely completion of projects agreed 
with  the  EU.  Türkiye  concluded  the  tendering  of  the  Ispartakule-Cerkezkoy  (Stage  II)  after 
securing financing from the EBRD and Asian Infrastructure Investment Bank (AIIB). The fourth 
railway monitoring board was held in June 2022. Jaspers technical support is made available for 
Türkiye  to  accelerate  its  preparatory  work  for  the  Yavuz  Sultan  Selim  bridge  connections  by 
involving the international financial institutions. The interfaces of the Canal Istanbul project with 
the  railway  projects  under  development  continue  to  be  a  source  of  concern  in  terms  of 
environmental  degradation,  technical  complications  and  possible  cost  increases  for  planned 
infrastructure. 

The development of the alternative fuels dimension in the planning of road connections between 
the EU and Türkiye needs to be prepared. Moreover, Türkiye should envision the development 
of new motorways of the seas connections between the EU and Turkish Black Sea ports in view 
of the increasing congestion at the land border crossing points and in order to provide additional 
access points for transit transport flows. Finally, a better coordination of the implementation of 
border  infrastructure  would  contribute  to  closing  infrastructure  gaps,  improving  traffic  flows 
between the EU and Türkiye and beyond. 

Chapter 27: Environment and climate change 

The  EU  promotes  strong  climate  action,  sustainable  development  and  protection  of  the 
environment.  EU  law  contains  provisions  addressing  climate  change,  water  and  air  quality, 
waste  management,  nature  protection,  industrial  pollution,  chemicals,  noise  and  civil 
protection. 

Türkiye has some level of preparation in this area, and faces critical environmental and climate 
challenges, in relation to both mitigation and adaptation. There was no progress overall. In the 
field  of  climate,  Türkiye  still  needs  to  follow  up  with  an  increased  nationally  determined 
contribution under the Paris Agreement, long-term strategic decarbonisation and adaptation plans 
and  appropriate  legislation  reflecting  them  domestically.  Positive  developments  were  noted  on 

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increasing  capacity  in  waste  management  and  wastewater  treatment,  as  well  as  legislative 
alignment,  but  enforcement  and  implementation  remain  weak.  More  ambitious  and  better 
coordinated environment and climate policies need to be established and implemented. Strategic 
planning, substantial investment and stronger administrative capacity are required as well. 

Last  year’s recommendations were implemented  only partially  and remain mostly valid.  In the 
coming year, Türkiye should in particular: 

→ complete alignment  with  the directives on waste, water and industrial  pollution, and ensure 

that the Environmental Impact Assessment Directive is correctly implemented; 

→ ensure alignment with the EU acquis and actual implementation on public participation and 

the right to access environmental information; 

→  enhance  and  implement  its  contribution  to  the  Paris  Agreement  on  climate  change,  and 

complete its alignment with the EU acquis on climate action. 

Environment  

Türkiye  has  achieved  some  level  of  preparation  in  the  area  of  horizontal  legislation.  Türkiye 
has  an  Environmental  Impact  Assessment  (EIA)  legislation,  which  is  mostly  aligned  with  the 
EU  EIA  Directive.  However,  procedures  for  transboundary  consultations  are  not  aligned  with 
the  EIA  and  the  Strategic  Environmental  Assessments  (SEA)  Directives.  Regarding  the 
implementation  of  the  EIA  legislation,  concerns  remain  about  the  non-application  or 
politicisation  of court decisions in  controversial  projects  with  high environmental  impacts  and 
the  respect  of  the  right  to  environmental  information.  The  strong  domestic  opposition, 
environmental  and  social  concerns,  and  unclear  financing  and  economic  returns,  on  the  Canal 
Istanbul  Project  -  an  artificial  sea-level  waterway  connecting  the  Black  Sea  and  the  Sea  of 
Marmara – have not been addressed in a transparent and comprehensive manner. Türkiye is still 
not party to the Aarhus and Espoo Conventions. Türkiye is aligned with the SEA Directive in 
some  sectors,  while  gradual  implementation  for  different  sectors  was  ongoing.  Alignment  on 
environmental  liability  remains  limited.  The  National  Environment  Agency  established  in 
December 2020 did not become operational.  

On  air  quality,  national  legislation  still  needs  to  be  adopted  in  line  with  EU  directives  on 
ambient  air  quality  and  national  emissions  ceilings.  Severe  air  pollution  in  some  cities  is 
reported  on  an  annual  basis.  A  national  strategy  for  air  quality  monitoring  is  in  place  and  all 
eight planned regional networks are established and operational. 

The  legal  framework  on  waste  management  is  partially  aligned  with  the  EU  acquis.  Türkiye 
ratified the Basel Convention 2019 Amendment in February 2022. The legislation on zero waste 
adopted  in  July  2019  continued  to  be  implemented.  Preparations  for  the  introduction  of  the 
deposit system started in 2022 and it is expected to be fully functional in mid-2023. Alignment 
and  capacity  for  sorting,  recycling  and  medical  waste  treatment  continued.  Significant  efforts 
are necessary to implement waste management plans at local and regional level. Legislation on 
ship recycling which would mirror the requirements of the EU Ship Recycling Regulation was 
not adopted. There are concerns regarding safety, sound waste management and environmental 
hazards in the ship recycling facilities registered in the EU list of ship recycling facilities. In the 
meantime, the current notification procedure practices are in line with the Basel Convention. 

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In  the  area  of  water  quality,  the  legislative  alignment  is  advanced  but  implementation  and 
enforcement  should  be  improved.  Transboundary  consultations  on  water  issues  are  still  at  an 
early stage. Türkiye did not align with the revised EU Directive on Drinking Water. Wastewater 
treatment capacity increased as a result of continuous investments and with the establishment of 
1 176 waste water treatment plants in the country, reached a coverage of 89 % of the municipal 
population.  Türkiye  aims  to  reach  100  %  by  2023.  Türkiye  still  needs  to  align  with  the  EU 
Marine Strategy. Türkiye is part of the EU sea basin strategy and Common Maritime Agenda for 
the Black Sea (CMA) endorsed by Ministerial declaration in May 2019. The CMA is a regional 
cooperation framework to support sustainable blue economy in the Black Sea with the goal to 
focus  on  healthy  marine  and  coastal  ecosystems.  Türkiye  is  one  of  the  42  Union  for 
Mediterranean (UfM) countries which adopted the Ministerial Declaration on Sustainable Blue 
Economy in February, reconfirming their commitments to address joint challenges in key blue 
economy sectors. 

Türkiye has some level of preparation on nature protection. No progress was made on adopting 
the  framework  legislation,  the  national  biodiversity  strategy  and  an  action  plan.  Planning  and 
construction in  wetlands,  forests and natural  sites are still not in  line with the EU  acquis. The 
institutional  framework  for  managing  future  Natura  2000  sites  needs  to  be  streamlined  and 
adequately resourced. The review of the status of protected areas continued over 2020 in a non-
transparent and non-participatory manner resulting in the changes in status and boundaries of a 
number of potential Natura 2000 areas. In March 2022, the mining regulation was amended to 
allow  mining  activities  to  be  carried  out  in  olive  orchards,  which  caused  significant  protests 
from farmers, political parties, NGOs and the general public. In April, the Council of State of 
Türkiye ordered a temporary stay of execution of mining operations in these areas. 

In  industrial  pollution  and  risk  management,  alignment  with  the  EU  acquis  is  at  an  early 
stage. The European Pollutant Release and Transfer Register (E-PRTR) legislation was adopted 
in  December  2021  with  a  phased  approach.  Türkiye  still  needs  to  align  with  the  Industrial 
Emissions Directive, the eco-management and audit scheme (EMAS) and the Directive on the 
limitation of emissions of volatile organic compounds (VOC) due to the use of organic solvents 
in certain paints and varnishes and vehicle refinishing products. 

On  chemicals,  the  overall  level  of  legislative  alignment  is  advanced  but  implementation  and 
enforcement remained weak. Türkiye is  almost fully aligned with the European Regulation on 
Registration,  Evaluation,  Authorisation  and  Restriction  of  Chemicals  (REACH).  Registration 
process started in January 2021 via the Chemicals Registration System (CRS) with a transitional 
period  of  enforcement  from  2021  until  2023.  Türkiye  adopted  legislation  aiming  at  the 
alignment with the latest EU Directive on Persistent Organic Pollutants in March 2021. 

Alignment with legislation on noise is well advanced but implementation and enforcement need 
to be improved. A few noise mapping and local noise action plans were not finalised. 

On civil protection, Türkiye’s collaboration under the EU Civil Protection Mechanism (UCPM) 
continued  to  increase.  An  EU  Civil  Protection  Modules  and  other  Response  Capacities 
(MODEX) exercise was successfully conducted in Tekirdağ, in November 2021 and became a 
milestone  for  the  cooperation.  Türkiye  activated  the  mechanism  and  received  support  for  the 
major forest fires in summer 2021. Furthermore, the Ministry of Health registered an Emergency 
Medical Team capacity to the European Civil Protection Pool. Türkiye, as a participating State 
of  UCPM,  submitted  the  country’s  summary  of  the  risk  assessment  and  risk  management 

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capability and information on priority prevention and preparedness measures for certain types of 
disaster risks, as required by the revised EU civil protection legislation. Türkiye is encouraged 
to install the Secure Trans European Services for Telematics between Administrators (sTESTA) 
system to be able to connect through the Common Emergency Communication and Information 
System (CECIS) with  the Emergency Response Coordination Centre (ERCC) of the European 
Commission. 

Climate change 

Türkiye made no progress on climate change over the reporting period, contrary to expectations 
following the ratification of the Paris Agreement in October 2021 and the announcement that the 
country  would  aim  at  reaching  net-zero  emissions  by  2053.  A  climate  law  and  the  Emissions 
Trading System legislation are yet to be adopted. Türkiye announced its intention to submit an 
enhanced  nationally  determined  contribution  before  the  COP27.  Mainstreaming  of  climate 
action  into  other  sector  policies  remained  limited.  Regarding  its  other  commitments  under  the 
UN Framework Convention on Climate Change, Türkiye submitted the latest national inventory 
on  greenhouse  gasses  in  April  2021.  Türkiye’s  legislation  is  currently  not  aligned  with  the 
Emission  Trading  Directive  and  with  the  EU’s  economy-wide  greenhouse  gas  monitoring 
mechanism. Türkiye still does not fully implement the Fuel Quality Directive. It also does not 
align  with  emissions  standards  for  new  cars.  An  alignment  plan  for  the  Carbon  Capture  and 
Storage Directive needs to be established. 

CLUSTER 5: RESOURCES, AGRICULTURE AND COHESION  

This cluster covers: agriculture and rural development (Chapter 11), food safety, veterinary and 
phytosanitary  policy  (Chapter  12),  fisheries  (Chapter  13),  regional  policy  and  coordination  of 
structural instruments (Chapter 22), and financial and budgetary provisions (Chapter 33).  

Türkiye  reached  some  level  of  preparation  in  the  area  of  agriculture  and  rural  development. 
Backsliding continued during the reporting period, as its agricultural policy keeps moving away  
from the main principles of the EU common agricultural policy and Türkiye continued to restrict 
imports of agricultural products from the EU. Türkiye is a major exporter of food products to the 
EU, and made limited progress in the area of food safety, veterinary and phytosanitary policy. 
Full implementation of the EU acquis in this area requires significant further work. Türkiye is 
moderately  prepared  in  the  area  of  fisheries  and  continued  to  make  good  progress,  notably  as 
regards  the  implementation  of  the  new  fisheries  law,  resources  and  fleet  management,  and 
inspection and control.  

Türkiye is moderately prepared in the area of regional policy and the coordination of structural 
instruments,  and  continued  to  make  some  progress  on  accelerating  the  absorption  of  IPA  II 
funds. Türkiye has some level of preparation in the area of financial and budgetary provisions 
but made no progress during the reporting period. 

Chapter 11: Agriculture and rural development 

The common agricultural policy supports farmers  and rural development. This requires strong 
management  and  control  systems.  There  are  also  common  EU  rules  for  quality  policy  and 
organic farming. 

Türkiye  reached  some  level  of  preparation  in  the  area  of  agriculture  and  rural  development. 
Backsliding  continued  with  respect  to  the  recommendations  of  last  year:  There  is  still  no 

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strategy for producing agricultural statistics. Türkiye’s agricultural support policy keeps moving 
away from the common agricultural policy’s principles and Türkiye continued to restrict imports 
of agricultural products from the EU. 

In the coming year, Türkiye should in particular: 

adopt and start to implement a strategy for producing agricultural statistics; 

 develop and start to implement a strategy to align its agricultural support policy with the EU 

acquis, including the definition of cross-compliance standards; 

  with  regard  to  the  EU  instrument  for  pre-accession  assistance  for  rural  development 
programme (IPARD), ensure the smooth roll-over of entrusted IPARD measures to the 2021-
2027 period and prepare new measures for entrustment under the IPARD III programme. 

On horizontal issues, the Ministry of Agriculture and Forestry continued efforts to minimise the 
negative impact of the COVID-19 pandemic. Preparatory works concerning the targets set out in 
the Turkish Green Deal Action Plan started as regards sustainable agriculture actions. 

Türkiye continued to move away from the principles governing agricultural direct support under 
the  common  agricultural  policy,  notably  by  increasing  the  support  coupled  to  production  and 
aiming at shifting to a region or basin-based management model. 

Türkiye needs to take further steps for the implementation of the integrated administration and 
control system (IACS). The farm accountancy data network (FADN) covers all 81 provinces and 
is integrated into the agricultural production and registration system. The agricultural census is 
not  yet  complete  and  the  strategy  for  agricultural  statistics  remains  to  be  adopted.  Further 
alignment  with  EU  policies  requires  the  decoupling  of  payments  from  production  and  linking 
area-based payments to well-defined cross-compliance standards. 

No progress has been observed on  common market organisation. Sharp decline in imports of 
live cattle, beef and derivate products from the EU continued in the reporting period. Türkiye is 
yet  to  fully  implement  its  obligations  under  the  EU-Türkiye  trade  agreement  for  agricultural 
products, by opening quotas for beef and live animals on a lasting basis. Proper and transparent 
management of import quotas needs to be implemented. 

On  rural  development,  the  third  programming  framework  of  the  EU  instrument  for  pre-
accession  assistance  for  rural  development  programme  (IPARD  III)  covering  the  period  2021-
2027 with a budget of EUR 430 million has been adopted by the Commission. Meanwhile, the 
implementation of IPARD II continued steadily.  

On quality policy, Türkiye continued to implement legislation on the protection of Geographical 
Indications, which is largely aligned to the EU acquis.  

On  organic  farming,  alignment  with  the  EU  acquis  on  principles  and  implementation  is  well 
advanced.  There  is  potential  for  further  developing  the  sector  and  for  utilising  the  support 
opportunities  under  the  IPARD  III  programme.  The  Turkish  Accreditation  Agency  accredits 
organic agriculture control bodies. 

Chapter 12: Food safety, veterinary and phytosanitary policy 

EU hygiene rules for foodstuff production ensure a high level of food safety. Animal health and 
welfare  and  the  safety  of  food  of  animal  origin  are  safeguarded  together  with  the  quality  of 
seeds,  the  plant  protection  material,  the  protection  against  harmful  organisms  and  animal 

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nutrition. 

Türkiye  reached  some  level  of  preparation  in  the  area  of  food  safety,  veterinary  and 
phytosanitary  policy.  There  was  limited  progress  concerning  the  implementation  of  animal 
identification and registration. Last  year’s recommendations were only partially taken up. Food 
establishments are yet to be upgraded to meet relevant EU standards. Full implementation of the 
EU acquis in this area requires significant further work. 

In the coming year, Türkiye should in particular: 

 upgrade food establishments to meet EU standards; 

  meet  EU  maximum  limits  for  pesticide  residues,  and  effectively  address  recurrent 

deficiencies;  

make further progress in addressing zoonoses. 

There was limited progress in aligning and implementing the EU acquis on general food safety. 
The  number  of  RASFF-notifications  (Rapid  Alert  System  for  Food  and  Feed)  on  findings  of 
pesticide  residues  in  fruits  and  vegetables  imported  from  Türkiye  into  the  EU  have  remained 
unacceptably  high  since  2020  when  new  standards  on  chlorpyrifos  and  chlorpyrifos-methyl 
became  applicable.  Implementation  of  specific  hygiene  rules  for  food  of  animal  origin, 
particularly for raw milk, was once more postponed. 

Türkiye  is  yet  to  fully  align  its  veterinary  policy  with  the  EU  acquis.  The  identification  and 
registration of bovines and small ruminants continued. The electronic identification system also 
covers cattle. Identification and registration of cats, dogs and ferrets started.  

Türkiye continued its fight against animal diseases. Foot and mouth disease outbreaks decreased 
as  a  result  of  mass  vaccination.  The  disease-free  zone  ensured  by  vaccination  in  the  area  of 
western  Türkiye  bordering  Bulgaria  and  Greece  was  maintained  by  strict  movement  controls. 
Vaccination  against  lumpy  skin  disease  continued.  Significant  efforts  are  still  needed  to  fully 
align  with  the  EU  acquis  on  transmissible  spongiform  encephalopathies  and  surveillance 
systems,  including  full  compliance  with  the  February  1998  Decision  of  the  EU-Türkiye 
Association  Council  on  the  trade  regime  for  agricultural  products.  Implementation  of  the 
legislation concerning animal welfare during transport was postponed and further structural and 
administrative work is necessary to fully implement the EU acquis in this area. There was some 
progress on zoonoses, with the implementation of the Salmonella control programme. 

Türkiye  continued  implementing  training,  inspection  and  monitoring  programmes  for  the 
placing of food, feed and animal by-products on the market. The administrative capacity for 
official  controls  was  improved.  No  progress  was  made  on  developing  the  national  plan  for 
upgrading  agri-food  establishments.  Significant  work  is  still  needed  to  apply  the  new  rules  on 
registering and approving food establishments. Substantial work is also required on animal by-
products. Provisions for funding inspections are not yet aligned with the EU system. 

Alignment  of  food  safety  rules  with  the  EU  acquis  advanced  on  issues  such  as  labelling, 
additives  and  purity  criteria,  flavourings,  food  supplements  and  enzymes.  Progress  on  specific 
rules  for  feed  remained  limited.  Progress  on  the  phytosanitary  policy  remained  limited. 
Alignment is yet to be ensured for novel food and for genetically modified organisms. 

Chapter 13: Fisheries 

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The common fisheries policy lays down rules on fisheries management, protects living resources 
of  the  sea  and  limits  the  environmental  impact  of  fisheries.  This  includes  setting  catch  quotas, 
managing fleet capacity, rules on markets and aquaculture and support for fisheries and coastal 
communities. 

Türkiye is  moderately  prepared  in  the area of  fisheries.  Good progress  continued as regards 
fisheries  governance  with  the  implementation  of  the  new  fisheries  law.  Last  year’s 
recommendations were largely taken up, notably on multilateral cooperation within the General 
Fisheries Commission for the Mediterranean (GFCM). 

In the coming year, Türkiye should in particular: 

  strengthen  efforts  to  align  the  fisheries  management,  including  fisheries  data  collection  and 

data sharing for scientific stock assessments; 

  strengthen efforts to align the market policy for fisheries and aquaculture products; 

  enhance further the fisheries control and inspection at sea in view of improving compliance at 
both  the  Mediterranean  and  Black  Seas,  and  of  effectively  fighting  illegal,  unreported  and 
unregulated fishing activities (IUU), including catch documentation schemes (CDS). 

Some  progress  was  made  on  resources  and  fleet  management.  Alignment  of  implementing 
legislation and technical regulations on fisheries and aquaculture with the amended fisheries law 
continued  in  the  reporting  period,  including  on  the  fisheries  vessels  monitoring  system, 
commercial  fishing,  traditional  artisanal  fishing,  and  aquaculture.  The  information  systems 
established  to  manage  fisheries  and  fishing  fleet  became  functional  and  contributed  to 
monitoring,  control  and  surveillance.  The  institutional  capacity  and  infrastructure  for  data 
collection and stock assessment were further improved. Support programmes were implemented 
for the exploitation of pufferfish (invasive species) to protect marine biodiversity. New fisheries 
protected areas were designated. The 2019 amendment of the fisheries law had also provided for 
some  structural  action,  such  as  a  strengthened  conservation  regime.  However  no  further 
progress has been made in this regard since. Structural actions are in place to support traditional 
coastal fisheries. 

On  inspections  and  control,  good  progress  continued  in  legislative  alignment  and  on 
implementation  of the recommendations  for control measures by the  International  Commission 
for the Conservation of Atlantic Tunas (ICCAT) and the General Fisheries Commission for the 
Mediterranean  (GFCM).  The  August  2021  amendment  regarding  commercial  fishing  regulates 
the  obligations,  restrictions  and  bans  on  fisheries  in  order  to  ensure  protection  and  sustainable 
operation  of  fisheries  resources,  taking  into  account  scientific,  environmental,  economic  and 
social  issues.  Sanctions  were  further  improved  with  implementation  of  the  amended  fisheries 
law. The number of inspections increased and nearly 400 fisheries vessels were confiscated due 
to  illegal,  unreported  and  unregulated  fishing  (IUU)  in  the  last  three  years.  New  technologies 
such as drones are used in fisheries inspections. 

On  market  policy,  Türkiye  improved  the  institutional  capacity  of  the  ministry  as  well  as 
fisheries  producer  organisations,  with  IT  tools  developed  to  facilitate  data  flow  from  the 
producer  organisations.  State  aid  is  provided  for  aquaculture  and  to  improve  data  quality  on 
marine and inland artisanal fishing vessels for sustainable management of fisheries.  

Regarding  international  agreements,  Türkiye  continued  cooperating  with  the  EU  in  the 

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regional  and  international  platforms.  As  the  EU  implements  provisions  of  the  United  Nations 
Convention  on  the  Law  of  the  Sea,  inter  alia  in  the  common  fisheries  policy,  Türkiye’s 
ratification of the Convention would improve cooperation with the EU on fisheries and maritime 
policy. 

Chapter 22: Regional policy and the coordination of structural instruments 

Regional  policy  is  the  EU’s  main  investment  policy  for  sustainable  and  inclusive  economic 
growth.  Member  States  bear  responsibility  for  its  implementation,  requiring  adequate 
administrative capacity and sound financial management of project design and execution. 

Türkiye is moderately prepared in the area of regional policy and the coordination of structural 
instruments. Overall, some progress was made on accelerating the absorption of IPA II funds.  

The recommendations from 2021 remain valid. In the coming year, Türkiye should in particular: 

 address structural weaknesses in the regional policy implementation; 

  accelerate  implementation  of  the  ongoing  operations  under  IPA  II,  in  order  to  deliver  high 

quality results by the set deadlines and avoid de-commitments; 

 strengthen its prioritisation capacities for EU funding under IPA III. 

Limited  progress  was  made  in  the  legislative  framework.  Mechanisms  for  evidence-based 
policymaking, policy and programme evaluations, and impact assessment are not yet in place. 

Formulation  of  a  general  framework  and  appropriate  statistical  tools  for  monitoring  and 
evaluation  of  the  National  Strategy  for  Regional  Development  (NSRD)  and  Regional 
Development Agencies' (RDAs) performance needs to be improved. The implementation of the 
NSRD has limited impact on national policy-making, and regional level considerations continue 
not to be fully reflected at central level. The limited involvement of relevant stakeholders in the 
RDAs and limited budget still affect the role RDAs play in contributing to policy-making and to 
the  regional  development.  Central  level  involvement  in  local  planning  and  considerable 
dependency on the state budget limits the financial autonomy of the local authorities. Regional 
development  programmes  should  enable  improved  economic  coordination,  structural  changes, 
territorial  cohesion  and  social 
to  economic  development  and 
competitiveness,  while  ensuring  definition  of  long-term  priorities,  regional  specialisation 
strategies and partnerships. 

in  addition 

inclusion, 

On  the  institutional  framework,  the  functioning  of  the  IMBC  authorities  continued  to  be 
monitored  by  the  National  IPA  Coordinator  office  (NIPAC)  in  coordination  with  the  National 
Authorising Officer (NAO) under the regular oversight of the Presidential Office. The Financial 
Cooperation  Committee,  which  groups  all  IMBC  authorities,  met  regularly.  The  role  of  the 
NIPAC  needs  to  be  further  strengthened  to  ensure  effective  coordination  amongst  ministries, 
prioritisation of interventions under IPA III and monitoring of impacts.  The institutional set up 
and  the  system  for  management  of  IPA  funds  in  IMBC  needs  to  be  adapted  to  the  IPA  III 
requirements  ensuring  alignment  with  the  relevant  articles  of  the  Financial  Framework 
Partnership Agreement between the Republic of Türkiye and the Commission. 

There continued to be some progress concerning administrative capacities of IPA structures. 
The implementation of the action plan established by the NIPAC and NAO continued to deliver 
results.  Efforts  continued  to  strengthen  capacities  for  programming,  and  monitoring  and 

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evaluation  activities,  as  well  as  to  strengthen  the  Audit  Authority.  However,  there  is  no  clear 
staff retention  policy and strategy,  and the re-focussing of  IMBC on specific sectors and some 
political developments have not positively contributed to staff motivation in some structures. The 
capacities of the IMBC structures need to be further strengthened in order to ensure efficient and 
timely  contracting  and  implementation  of  IPA  programmes,  and  be  able  to  operate  in  ex-post 
controls environment. 

With regards to programming, project pipelines were established by  all IPA structures for the 
IPA II period 2014-2020 under multi-annual operational programmes (MAAPs) and a number of 
project proposals were submitted for 2021 and 2022 programming. Structures should strengthen 
their prioritisation capacities on the investment needs to be financed under IPA III, while fully 
taking benefit of the new financial instruments available in the context of the European Fund for 
Sustainable  Development  Plus  (EFSD+).  Coordination  and  complementarity  amongst  the 
instruments should be strengthened.  

On  monitoring  and  evaluation,  the  NIPAC  establishes  joint  on  the  spot  check  plans  in 
coordination  with  the  NAO  and  the  managing  authorities  since  2019.  In  addition,  the  NAO 
follows  up  on  the  execution  of  the  plans  of  the  managing  authorities  and  their  findings.  All 
managing  authorities  and  the  NIPAC  have  their  own  information/management  information 
systems and a technical assistance for result oriented monitoring has been supporting the NIPAC 
office  to  monitor  the  implementation.  Some  progress  was  observed  in  terms  of  reporting  at 
indicator and sector priorities level. However, progress is needed on reporting at outcome level 
and progress/achievements against the set targets. 

Concerning  financial  management,  control  and  audit,  no  de-commitments  took  place  at  the 
end  of  2021,  but  implementation  and  disbursement  rates  still  need  to  further  progress  at  full 
speed.  The  Audit  Authority  strengthened  its  capacities,  improved  the  quality  of  the  annual 
reporting and followed Commission guidance and recommendations. There is a need to further 
develop  the  methodology  for  auditing  infrastructure  projects  and  expand  experience  in 
verification  of  performance  aspects,  including  compliance  with  sound  financial  management 
rules  and  outcome  achievement.  Constant  attention  to  the  quality  of  audit  evidence  should 
contribute to strengthening audit conclusions. (See Chapter 32). 

Chapter 33: Financial and budgetary provisions 

This chapter covers the rules governing the funding of the EU budget (‘own resources'). These 
resources  mainly  consist  of:  (i)  contributions  based  on  the  gross  national  income  of  each 
Member  State;  (ii)  customs  duties;  (iii)  the  non-recycled  plastic  resource  and  (iv)  a  resource 
based on value-added tax. Member States must have the appropriate administrative capacity to 
adequately  coordinate  and  ensure  the  correct  calculation,  collection,  payment  and  control  of 
own resources. 

Türkiye  has  some  level  of  preparation  in  the  area  of  financial  and  budgetary  provisions.  No 
progress  was  made  during  the  reporting  period.  Solid  coordination  structures,  administrative 
capacity  and  implementing  rules  for  the  correct  application  of  the  own  resources  system  will 
need to be set up in due course. 

Last year’s recommendation was not addressed. In the coming year, Türkiye should in particular 
further align the GNI Inventory with Eurostat’s GNI Inventory Guide. 

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Basic  principles  and  institutions  in  the  underlying  policy  areas  linked  to  the  application  of  the 
own  resources  system  are  already  in  place  (see  Chapters  16  -  Taxation,  18  -  Statistics,  29  - 
Customs  union  and  32  -  Financial  control).  The  Customs  Union  with  the  EU  on  processed 
agricultural goods and industrial goods (with the exception of coal and steel products) continues 
to  ensure  considerable  alignment  of  Türkiye’s  customs  legislation  with  the  EU  acquis  on 
customs while a draft customs law aligned with the Union Customs Code is  yet to be adopted. 
This will facilitate preparation in traditional own resources, i.e. mainly customs duties. 

For the value added tax-based resource, preparation is needed to correctly calculate the VAT 
base  and  the  weighted  average  rate.  Sound  measures  are  needed  to  combat  VAT  and  customs 
duties fraud and resolute actions are needed to tackle the non-observed economy. Türkiye needs 
to  further  align  the  legislation  on  structure,  exemptions,  special  schemes  and  the  scope  of 
reduced rates with the EU acquis. 

Concerning the gross national income-based resource, Türkiye needs to continue its efforts to 
bring  its  national  accounts  and  GNI  calculations  fully  in  line  with  the  European  system  of 
accounts  (ESA  2010)  and  to  improve  exhaustiveness  of  the  estimates,  ensuring  that  they  take 
account of the non-observed economy. There is a need to further align the GNI inventory with 
the Eurostat’s Inventory Guide and improve the timely transmission of data. 

As  concerns  the  administrative  infrastructure,  Türkiye  needs  to  set  up  a  fully  operational 
coordination  structure,  with  appropriate  administrative  capacity  and  implementing  rules,  to 
ensure that it will be able to  correctly calculate,  forecast,  account  for, collect,  pay,  control and 
report own resources to the EU in line with the EU acquis. 

CLUSTER 6: EXTERNAL RELATIONS  

There are two chapters in this cluster: external relations (Chapter 30), and foreign, security and 
defence policy (Chapter 31). Türkiye is moderately prepared in the area of external relations and 
made limited progress during the reporting period. Large deviation from the Common Customs 
Tariff was still in place. Divergence from the EU Generalised Scheme of Preferences persisted, 
in  violation  of  the  EU-Turkey  Customs  Union.  Türkiye’s  official  development  assistance  was 
largely directed towards humanitarian support for the Syria-related activities on Türkiye’s own 
territory. 

Türkiye  has  some  level  of  preparation  in  the  area  of  foreign,  security  and  defence  policy. 
Overall,  Türkiye’s  foreign  policy  continued  to  be  at  odds  with  the  EU  priorities  under  the 
common foreign and security policy (CFSP).  

Chapter 30: External relations 

The  EU  has  a  common  trade  and  commercial  policy  towards  third  countries,  based  on 
multilateral and bilateral agreements, and autonomous measures. There are also EU rules in the 
field of humanitarian aid and development policy. 

Türkiye is moderately prepared in the area of external relations. There was limited progress in 
the  reporting  period.  Türkiye  lifted  some  additional  customs  duties,  thus  partly  re-aligning  its 
customs  tariff  with  the  Common  Customs  Tariff.  However,  large  deviation  from  the  Common 
Customs  Tariff  due  to  the  wide  scope  of  additional  customs  duties  was  still  in  place,  and  the 
divergence  from  the  EU  Generalised  Scheme  of  Preferences  persisted,  contravening  the  EU-
Turkey  Customs  Union.  Türkiye’s  official  development  assistance  remained  above  the  0.7  % 

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target  enshrined  in  the  Sustainable  Development  Goal  17  and  was  largely  directed  towards 
humanitarian support for the Syria-related activities on Türkiye’s own territory. 

The recommendations from last year were only partially implemented and remain valid. 

In the coming year, Türkiye should in particular: 

 re-align the customs tariff completely with the Common Customs Tariff; 

  complete  the  alignment  with  the  EU’s  Generalised  Scheme  of  Preferences  and  dual-use 

export control regime; 

 provide increasing development and humanitarian aid outside its territory. 

There was limited progress on the  common commercial policy. Some of the additional duties 
were  removed.  The  number  and  wide  scope  of  the  remaining  additional  duties  are  yet  to  be 
significantly narrowed down to restore the once good level of alignment with the EU common 
commercial policy. In addition, Türkiye has not fully converged to the EU’s Generalised Scheme 
of  Preferences  in  terms  of  either  countries  or  products.  New  investigations  initiated  based  on 
weak  evidence,  and  the  use  of  safeguards  instead  of  more  targeted  and  more  appropriate  trade 
defence measures (such as the anti-dumping instrument) remained a cause of concern. There is a 
need for closer coordination between the EU and Türkiye within the World Trade Organisation, 
in particular on the Doha Development Agenda, in the OECD and the G-20. 

On  export  controls  on  dual-use  goods,  Türkiye  did  not  align  with  the  EU  position  on  certain 
multilateral  export  control  arrangements,  such  as  the  Wassenaar  Arrangement  on  Export 
Controls  for  Conventional  Arms  and  Dual-Use  Goods  and  Technologies,  and  the  Missile 
Technology Control Regime. Türkiye is still not aligned with the EU position on medium- and 
long-term export credits. 

Regarding  bilateral  agreements  with  third  countries,  Türkiye  concluded  a  free  trade 
agreement with Ukraine, completing the negotiations initiated a decade ago. Türkiye continued 
to implement the free trade agreement concluded with the United Kingdom following the entry 
into  force  of  the  EU-UK  Trade  and  Cooperation  Agreement.  Türkiye  also  continued  to 
implement its free trade agreement with Malaysia, even though the EU has no such agreement 
with that country. In addition, Türkiye continued to implement agreements with Venezuela and 
with Azerbaijan. 

As to the Pan-euro-Mediterranean (PEM) Convention on rules of origin, two EU-Türkiye trade 
agreements  are  not  yet  linked  to  the  PEM  Convention's  current  rules:  the  1998  regime  for 
agricultural  products,  and  the  1996  Agreement  on  trade  in  products  covered  by  the  European 
Coal  and  Steel  Community.  There  are  ongoing  EU-Türkiye  discussions  on  the  (revised)  PEM 
Convention  transitional  rules  of  origin.  An  agreement  has  yet  to  be  reached  on  all  issues 
including full cumulation and duty drawback. 

As  for  development  policy  and  humanitarian  aid,  official  development  assistance  (ODA) 
granted by Türkiye in 2021 amounted to EUR 6.46 billion, which is equivalent to 0.95 % of its 
gross national income (GNI). It decreased compared to previous  years,  yet remained above the 
0.7  %  target  enshrined  in  the  Sustainable  Development  Goal  17.  This  assistance  was  largely 
directed towards humanitarian support for the Syria-related activities on Türkiye’s own territory. 

Chapter 31: Foreign, security and defence policy  

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Member  States  must  be  able  to  conduct  political  dialogue  under  EU  foreign,  security  and 
defence  policy,  to  align  with  EU  statements,  to  take  part  in  EU  actions,  and  to  apply  agreed 
sanctions and restrictive measures.  

Türkiye  has  some  level  of  preparation  in  the  area  of  foreign,  security  and  defence  policy. 
Backsliding  continued  due  to  Türkiye’s  unilateral  foreign  policy  being  at  odds  with  the  EU 
priorities under the common foreign and security policy (CFSP), notably due to its support for 
military actions in surrounding conflicts such as in Syria and Iraq, and lack of alignment with EU 
restrictive  measures  against  Russia.  While  the  institutional  framework  enabling  Türkiye's 
participation  in  CFSP and, respectively, the common  security and defence policy (CSDP) is  in 
place, Türkiye maintained a very low alignment rate of 7 %.  

Türkiye’s military support to Libya, including the deployment of foreign fighters on the ground, 
and its persistent criticism of, and lack of cooperation with Operation IRINI, are detrimental to 
the  EU’s  effective  contribution  to  the  UN  arms  embargo  implementation,  and  have  led  to 
conflicting approaches on Libya. Türkiye remains a critically important actor in the Syrian crisis 
and shares with the EU the objective of a stable and prosperous Syria. Nevertheless, Türkiye’s 
troops  maintained  their  significant  presence  in  parts  of  northern  Syria.  The  recommendations 
from last year still hold as they were addressed only to a very limited extent. 

In the coming year, Türkiye should in particular:  

  take  decisive  steps  to  significantly  improve  alignment  with  EU  declarations  and  Council 

Decisions on the common foreign and security policy;  

 further enhance the political dialogue on foreign and security policy with the EU.  

Foreign policy consultations at senior officials’ level took place in May 2022. Türkiye attended 
the Brussels VI Syria Conference in May 2022. The institutional framework enabling Türkiye’s 
participation  in  the  common  foreign  and  security  policy  (CFSP)  and,  respectively,  the 
common security and defence policy (CSDP) remains in place at both the Ministry of Foreign 
Affairs and  at  the Ministry of Defence. Türkiye  continued to  participate  in  Operation EUFOR 
ALTHEA as the biggest non-EU troop contributor.   

As of August 2022, Türkiye’s CFSP alignment rate slipped to an all-time low of 7 %, compared 
to  11  %  in  2021.  As  a  general  policy,  Türkiye  does  not  support  sanctions  outside  the  UN 
framework and hence continued not to align with EU restrictive measures, including economic 
sanctions.  Türkiye  continues  to  obstruct  the  accession  of  EU  Member  States  to  international 
organisations. 

Türkiye  continued  to  seek  its  involvement  in  EU  defence  initiatives  such  as  the  Permanent 
Structured  Cooperation  (PESCO)  and  the  European  Defence  Fund  (EDF).  Türkiye’s  narrow 
interpretation of the EU-NATO cooperation framework continued to pose an obstacle to building 
a  genuine  organisation-to-organisation  relationship,  in  particular  by  limiting  the  exchange  of 
information and blocking the inclusive participation of all Member States in joint activities of the 
two organisations. After a prolonged objection to Finland’s and Sweden’s NATO membership 
bids, Türkiye lifted its objection on 28 June 2022 under certain conditions. Its Parliament has not 
yet ratified the act of accession of the two EU Member States to NATO. 

At the UN General Assembly in September 2021, Türkiye voiced its support to the reform of the 
UN Security Council, making a plea for multilateralism. Türkiye participated in the virtual G20 

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Rome  Summit  in  October  2021  and  the  28th  OSCE  Ministerial  Council  in  December  2021.  In 
many  international  organisations,  Türkiye  opposed  the  participation  of  international  and 
European  NGOs,  which  it  accused,  without  providing  evidence,  of  links  with  terrorist 
organisations. 

Türkiye  participates  in,  and  complies  with,  the  different  international  regimes/instruments 
concerning  the  non-proliferation  of  weapons  of  mass  destruction.  However,  it  continues  to 
prevent the participation of the Republic of Cyprus in the Conference on Disarmament. 

With regard to hybrid threats, in the context of international conflicts and crises, the circulation 
of false information and propaganda on social and mainstream media was observed also in the 
Turkish  information  environment.  Türkiye  did  not  restrict  the  operations  of  Russian  media 
outlets in the context of the Russian aggression against Ukraine. In addressing disinformation, it 
is crucial that Türkiye does not restrict further the freedom of media, but that it implements, in an 
objective and proportionate manner, any legal framework aimed at preventing the spread of false 
information. 

Türkiye’s  global  diplomatic  network  ranks  fifth  in  the  world  and  continues  to  further  expand. 
During  the  past  year,  Türkiye  undertook  significant  efforts  to  mend  ties  with  its  estranged 
neighbours,  a  policy  defined  as  ‘regional  normalisation’.  This  noticeable  recalibration  of 
Türkiye’s foreign policy focuses primarily on financial, trade and defence industry cooperation. 

The Russian war of aggression against Ukraine was recognised by Türkiye as a state of war 
and  Türkiye  condemned  the  Russian  aggression.  Türkiye  enforced  the  Montreux  Convention’s 
clause  whereby  the  passage  of  warships  was  limited  to  those  returning  to  their  bases.  Turkish 
companies  continued  to  sell  military  ordnance  to  Ukraine.  In  February  2022,  Türkiye  and 
Ukraine  deepened  their  strategic  partnership  by  signing  a  range  of  bilateral  agreements, 
including a new free trade agreement and a defence sector deal.  At the same time, Türkiye has 
aimed at facilitating talks between Ukraine and Russia, as illustrated by talks held between the 
parties in Antalya and in Istanbul. It undertook a diplomatic initiative to facilitate the export of 
Ukrainian grain.  In this  context, Türkiye together with the United Nations facilitated the Black 
Sea  Grain  Initiative  of  22  July  between  Ukraine  and  Russia  and  a  Joint  Coordination  Center 
(JCC) was established in Istanbul to monitor the safe passage of commercial vessels through the 
humanitarian  maritime  corridor.  On  5  August,  the  Turkish  President  met  in  Sochi  with  his 
Russian  counterpart  and  signed  a  Memorandum  of  Understanding  to  expand  economic 
cooperation. On 18 August, the Turkish President made his first visit to Ukraine since the start of 
the war where he met with the Ukrainian President together with the United Nations Secretary 
General.  Türkiye  refrained  from  aligning  with  EU  sanctions  against  Russia.  In  the  same  vein, 
Türkiye  did  not  close  its  airspace  to  Russian  planes  although  it  closed  its  airspace  for  Russian 
flights from and to Syria. Türkiye openly welcomed Russian oligarchs to invest in Türkiye.  

Türkiye remains an important but also challenging partner and NATO ally for the United States 
(US).  Türkiye  and  the  US  engage  on  regional  issues,  including  Ukraine,  Afghanistan, 
humanitarian  access  to  Syria,  and  counter-terrorism  activities.  Key  points  of  friction  include 
Türkiye’s refusal to part with its investment in Russian S-400 air defence missiles despite falling 
foul of the US  Countering America’s Adversaries Through Sanctions Act  (CAATSA), Turkish 
criticism  of  US  support  for  the  YPG  forces  in  northern  Syria,  tensions  between  Türkiye  and 
Greece, Türkiye’s continuing non ratification of the accession of Finland and Sweden to NATO, 
and  the  respect  of  human  rights  in  Türkiye.  In  April  2022  the  two  countries  launched  the  US-

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Türkiye Strategic Mechanism as a structured platform in which all matters can be discussed, with 
an emphasis on advancing practical bilateral cooperation. Türkiye and Canada, as NATO allies, 
maintain  open  channels  of  communication  at  high  level,  reiterating  and  reaffirming  their 
commitment for strong bilateral cooperation. 

Türkiye’s  efforts  for  rapprochement  in  the  region  started  in  2021  with  Egypt  which  was 
followed  by  the  rapprochement  with  the  United  Arab  Emirates  (UAE),  the  signature  of 
economic  agreements  and  a  widely-publicised  visit  of  the  President  to  the  UAE  in  February 
2022. Relations with Bahrain also improved and the Turkish Foreign Minister paid an official 
visit  to  this  country  in  January  2022.  Finally,  the  normalisation  policy  culminated  in  the 
President’s visit to Saudi Arabia in April 2022. In the run-up to the visit, the Minister of Justice 
decided  to  transfer  the  legal  proceedings  for  the  killing  in  Istanbul  of  Mr  Kashoggi  to  Saudi 
Courts.  Relations  with  Israel  were  also  re-launched  with  a  meeting  between  the  Turkish 
President  and  his  Israeli  counterpart  in  March  2022,  the  first  visit  of  the  Israeli  President  to 
Türkiye since 2007.  In  August  2022, Türkiye and  Israel  decided to  re-establish full diplomatic 
ties. Türkiye and Armenia initiated the normalisation process and appointed special envoys who 
held four rounds of talks, while the Foreign Ministers of the two countries met in March 2022, 
for the first time since 2009, while the leaders of the two countries held their first ever phone call 
in July 2022. Direct flights between the two countries have started in February and an agreement 
was made in July to start direct cargo flights and allow third-country citizens to cross their shared 
borders at the earliest possible date.  

Türkiye  and  Qatar  continued  their  cooperation  in  various  fields  and  maintained  close 
coordination  on  regional  and  international  issues.  Türkiye  maintains  a  pragmatic  approach  on 
Afghanistan,  engaging  regularly  in  talks  with  the  Taliban  de  facto  government  but  stopping 
short  of  recognition.  Türkiye  sent  humanitarian  aid  to  Afghanistan,  provided  a  USD  3  million 
contribution to the UNDP Trust Fund and announced and additional USD 5 million contribution 
in humanitarian aid at the Afghanistan pledging conference in March 2022. 

Türkiye  remained  committed  to  the  political  process  in  Syria  and  does  not  plan  to  normalise 
relations with the Syrian regime as long as there is no credible political process in place. Türkiye 
also engaged with Russia and Iran in the framework of the Astana Process, complementing the 
Geneva  Process.  Türkiye  actively  supported  the  work  of  the  Constitutional  Committee  and 
continued to lend support and assistance to the opposition. Two years after the Syrian regime’s 
latest large-scale offensive on Idlib, the cease-fire agreed in March 2020 between Türkiye and 
Russia  held  during  the  reporting  period,  although  cease-fire  violations  and  military  flare-ups 
took place. The Turkish troops maintained their significant presence in the region and in other 
parts of northern Syria.  

Clashes between, on the one hand, Turkish forces and units of the opposition’s Syrian National 
Army  and,  on  the  other  hand,  the  Syrian  Democratic  Forces  (SDF)  have  markedly  intensified 
from  north-west  Syria  until  north-east  Syria.  Türkiye  developed  housing  and  infrastructure  in 
regions  in  northern Syria, linking them  to  those  of Türkiye and provided basic services to  the 
local  population. However, the human rights  situation in  northern Syria,  where Turkish forces 
and  Türkiye-affiliated  armed  groups  are  present,  remained  a  matter  of  concern.  The  Turkish 
authorities  supported  activities  conducted  by  the  Syrian  Interim  Government  to  bring  back 
stability and create administrative structures on the ground. Under the mandatory provisions of 
international law, Türkiye needs to continue to address the human rights issue.  

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Regarding  relations  with  Libya,  Türkiye  advocated  for  an  agreement  in  the  framework  of  the 
Libyan-led and Libyan-owned political process and considered the prevailing political situation 
in the country unsustainable. In line with the United Nations and key actors of the P3+2 (United 
States, United Kingdom, Germany, France and Italy), Ankara advocated for holding elections to 
overcome  the  crises.  Türkiye  continued  to  assert  the  validity  of  the  Turkish-Libyan  maritime 
delimitation  agreement  of  2019,  which  the  EU  considers  an  infringement  upon  the  sovereign 
rights of third states, not complying with the Law of the Sea and having no legal consequences 
for  third  states.  In  June  2022,  the  Turkish  Parliament  granted  an  18-month  extension  to 
Türkiye’s military mission in Libya. Ankara continued to claim that the UN embargo provisions, 
the  articles  on  the  withdrawal  of  all  mercenaries,  foreign  fighters  and  foreign  forces  from  the 
Libyan  territory  and  the  suspension  of  military  training  in  the  cease-fire  agreement  had  no 
bearing  on  the  legitimate  government.  Türkiye’s  lack  of  cooperation  continued  to  hamper  the 
EU contribution to the effective implementation of the UN embargo. In July 2022, Türkiye, as a 
flag state, did not give its consent to Operation IRINI’s request to inspect a vessel, eighth such 
incident since Operation IRINI started.  

Türkiye  supported  the  safeguarding  of  the  Joint  Comprehensive  Plan  of  Action  on  Iran  and 
acknowledged  the  EU  initiatives  on  the  matter.  Türkiye  maintained  a  high-level  dialogue  with 
Iran.  Some  tensions  with  Iran  were  noticeable  in  the  contexts  of  the  Syrian  and  north-Iraqi 
theatres, the provision  of energy  from  Iran to  Türkiye or the  alleged  Iranian attempts to  attack 
Israeli citizens in Türkiye. 

Türkiye  continued  its  anti-terrorism  operations  in  Iraq  and  the  semiautonomous  Kurdistan 
Region of Iraq against PKK groups and affiliates. The last operation launched in April 2022  – 
“Operation Claw-Lock” – was strongly condemned and labelled as a security threat by the Iraqi 
government. Türkiye was accused by Iraqi state media of killing civilians in Dohuk, following 
an artillery operation in the area. Türkiye maintains close relations with the federal government 
of  Iraq  as  well  as  the  Kurdistan  Regional  Government  (KRG)  to  promote  positive  trade  and 
energy relations. The Iraqi President paid a visit to Türkiye in March 2022. 

In Central Asia, EU and Türkiye policies have converged to an extent. Türkiye presented itself 
as  an  alternative  to  Russia  and  China.  Türkiye  attaches  great  importance  to  connectivity  and 
maintains  close  relations  with  the  countries  in  the  region.  Regarding  Kazakhstan,  the  Joint 
Declaration  of  10  May  2022  raised  the  level  of  bilateral  relations  to  an  “enhanced  strategic 
partnership”  with  the  aim  to  strengthen  ties  and  enhance  cooperation  across  the  board. 
Commercial agreements of a combined value of USD 1.1 billion were also signed. 

In  March  2022,  the  President  visited  Uzbekistan  and  a  number  of  agreements  were  signed 
including  on  defence  cooperation.  In  November  2021,  upon  Türkiye’s  proposal,  the  “Turkic 
Council” was renamed to “Organisation of Turkic States” (OTS), aiming to compete with the 
Shanghai  Cooperation  Organisation  and  the  Eurasian  Economic  Union.  Türkiye  further 
enhanced its  relations with  Azerbaijan with  which it coordinates on its  normalisation process 
with  Armenia.  Türkiye  supports  the  construction  of  a  transport  corridor  to  Azerbaijan  via 
Armenia  and  emphasises  energy  and  trade  cooperation.  Türkiye  supports  the  3+3  regional 
cooperation platform and participated in the meeting held in December 2021.  

Türkiye  systematically  focuses  on  development  opportunities  in  Asia  and  becoming  the  axis 
towards  Europe.  Türkiye  is  part  of  the  multilateral  Middle  Corridor  Initiative,  aiming  at 
developing  connectivity  initiatives  with  China  via  Türkiye,  the  Caucasus  and  Central  Asia. 

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Türkiye continued to strengthen its trade ties with China, its second biggest trading partner. The 
Turkish  Foreign Minister paid  a visit  to China in January 2022. Türkiye continued to  voice its 
views,  expectations  and  sensitivities  regarding  the  treatment  of  the  Uyghurs,  a  Turkic  ethnic 
group in China.  

The  Turkish  Foreign  Minister  paid  an  official  visit  to  Sri  Lanka  in  January  2022,  agreeing  to 
boost cooperation on defence industry and combatting terrorism. He also paid an official visit to 
South  Korea,  and  a  technical  working  group  was  established  to  deepen  the  bilateral  relations. 
Türkiye  and  Indonesia  agreed  to  further  enhance  their  bilateral  relations.  Türkiye’s  relations 
with Pakistan remain strong, with regular high-level communications and exchanges. Pakistan’s 
Prime Minister visited Türkiye in May 2022. 

Türkiye  paid  a  lot  of  attention  to  the  African  continent  in  2021.  The  third  Türkiye-Africa 
Partnership  Summit  took  place  in  December  2021  in  Istanbul.  In  total,  38  African  countries 
attended  the  Summit,  of  which  16  on  the  level  of  Head  of  State  or  Government.  A  joint 
declaration, an action plan and an implementation report were adopted during the Summit. In the 
course of 2021 and 2022, the Turkish President paid visits to Angola, Togo, Nigeria, Senegal, 
Guinea-Bissau  and  the  Democratic  Republic  of  Congo,  during  which  numerous  bilateral 
agreements were signed.   

Türkiye  maintained  its  contacts  with  the  countries  of  Latin  America.  In  April  2022,  Turkish 
Foreign  Minister  paid  a  visit  to  the  region  and  Venezuela’s  President  visited  Türkiye  in  June 
2022. 

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ANNEX I – RELATIONS BETWEEN THE EU AND TÜRKIYE 

Within the framework of accession negotiations, 16 chapters have been opened so far and one 
of these was provisionally closed. In December 2021, the General Affairs Council reiterated the 
Council’s position of June 2018 that Türkiye has been moving further away from the European 
Union.  Türkiye's  accession  negotiations  have  therefore  effectively  come  to  a  standstill  and  no 
further  chapters  can  be  considered  for  opening  or  closing.  The  EU  Leaders  confirmed  that 
dialogue  on  rule  of  law  and  fundamental  rights  remains  an  integral  part  of  the  EU-Türkiye 
relationship. 

The Council conclusions of July 2019, adopted in response to Türkiye’s provocative actions in 
the  Eastern  Mediterranean,  remain  valid.  The  Council  decided  to  suspend  negotiations  with 
Türkiye on the Comprehensive Air Transport Agreement, not to hold for the time being the EU-
Türkiye Association Council as well as further meetings of the EU-Türkiye high-level dialogues, 
to  endorse  the  Commission’s  proposal  to  reduce  the  pre-accession  assistance  to  Türkiye  for 
2020,  and  to  invite  the  European  Investment  Bank  to  review  its  lending  activities  in  Türkiye, 
notably  with  regard  to  sovereign-backed  lending.  The  EU  further  extended  the  existing 
framework for restrictive measures in response to Türkiye’s unauthorised drilling activities in the 
Eastern  Mediterranean.  Two  Turkish  individuals  remain  on  the  list  of  designations  under  this 
sanctions framework. A Turkish shipping company is also listed in the framework of violations 
of the Libya weapons embargo.  

The European Council repeatedly stated that the EU has a strategic interest in a stable and secure 
environment in the Eastern Mediterranean and in the development of a cooperative and mutually 
beneficial  relationship  with  Türkiye.  The  EU  is  ready  to  engage  with  Türkiye  in  a  phased, 
proportionate  and  reversible  manner  to  enhance  cooperation  in  a  number  of  areas  of  common 
interest,  subject  to  the  established  conditionalities  set  out  in  European  Council  conclusions.  In 
case of renewed unilateral actions or provocations in breach of international law, the EU will use 
all the instruments and the options at its disposal, including in accordance with Article 29 TEU 
and  Article  215  TFEU,  in  order  to  defend  its  interests  and  those  of  its  Member  States.  In  its 
conclusions of June 2022, the European Council expressed deep concern about recent repeated 
actions and statements by Türkiye. Türkiye must respect the sovereignty and territorial integrity 
of  all  EU  Member  States.  Recalling  its  previous  conclusions  and  the  statement  of  25  March 
2021,  the  European  Council  expected  Türkiye  to  fully  respect  international  law,  to  de-escalate 
tensions in the interest of regional stability in the Eastern Mediterranean, and to promote good 
neighbourly relations in a sustainable way.  

Reforms and developments in Türkiye continued to be monitored by the bodies set up under the 
Association  Agreement,  with  subcommittees  kept  being  held  throughout  the  reporting  period. 
The  Commission,  jointly  with  the  European  External  Action  Service,  has  maintained  EU-
Türkiye  relations  in  all  key  areas  of  joint  interest  based  on  a  broad  engagement.  Intensified 
high-level engagement continued in the areas of joint interest. The political dialogue took place 
at senior officials’ level. 

Türkiye remains the EU’s sixth largest trading partner, while the EU is Türkiye’s largest. Two 
out of five goods traded by Türkiye come from or go to the EU and a significant part of foreign 
direct investment in Türkiye originates in the EU. As part of the Economic Reform Programme 
exercise,  Türkiye  participated  in  the  multilateral  economic  dialogue  with  the  Commission  and 
Member  States  held  in  May  2022  to  prepare  the  country  for  participation  in  multilateral 

130 

 
 
surveillance  and  economic  policy  coordination  as  part  of  the  EU’s  Economic  and  Monetary 
Union. The EU and Türkiye also continue to coordinate in the framework of the G-20.  

Regarding  the  Customs  Union,  the  Commission  adopted  a  recommendation  for  opening  of 
negotiations with Türkiye on the modernisation of the Customs Union in December 2016. This 
recommendation  has  been  forwarded  to  the  Council  where  it  has  been  under  consideration, 
without  prejudice  to  Member  States'  position.  In  March  2021,  the  EU  Leaders  invited  the 
Commission to intensify talks with Türkiye to address current difficulties in the implementation 
of  the  Customs  Union,  ensuring  its  effective  application  to  all  Member  States,  and  invited  in 
parallel the Council to work on a mandate for the modernisation of the Customs Union. Such a 
mandate may be adopted by the Council subject to additional guidance by the European Council. 
The Commission continued intensified engagement with Türkiye to discuss issues hampering the 
smooth functioning of the Customs Union. The European Commission and Türkiye continue an 
intensified engagement on the EU Green Deal. 

In the area of visa, migration and asylum, the implementation of the March 2016 EU-Turkey 
Statement has continued to deliver concrete results in reducing irregular and dangerous crossings 
on  the  Eastern  Mediterranean  route  to  Europe  and  in  saving  lives  at  sea.  Türkiye  sustained  its 
considerable  efforts  to  provide  significant  support  to  close  to  4  million  refugees,  of  which  3.6 
million  Syrians.  In  the  context  of  the  EU-Türkiye  visa  liberalisation  dialogue,  no  outstanding 
visa  liberalisation  benchmarks  were  fulfilled.  An  international  agreement  on  the  exchange  of 
personal data between Europol and the Turkish authorities competent for fighting serious crime 
and terrorism is yet to be concluded. The European Council of October 2021 called on Türkiye 
to ensure the full and non-discriminatory implementation of the EU-Turkey Statement of 2016, 
including vis-à-vis the Republic of Cyprus. 

Türkiye  and  the  EU  continued  to  have  fruitful  cooperation  under  the  Facility  for  Refugees  in 
Turkey. The Facility manages a total of EUR 6 billion. The full operational budget of the Facility 
was  contracted  by  the  end  of  2020;  disbursements  have  reached  over  EUR  4.7  billion  in  June 
2022,  with  the  balance  to  be  disbursed  in  the  course  of  implementation  of  Facility  projects. 
Facility  funding  continued  to  support  projects  focused  on  humanitarian  assistance,  education, 
migration management, health, municipal infrastructure, and socio-economic support. More than 
100  projects  have  been  rolled  out.  1.9  million  refugees,  including  those  most  vulnerable, 
continue  to  receive  basic  needs  support  and  close  to  740  000  refugee  children  are  enrolled  in 
school with Facility support. Other achievements of the Facility include the ongoing building of 
405  schools,  and  delivering  over  22.8  million  primary  health  care  consultations.  The 
Commission allocated an additional package of EUR 3.5 billion covering the 2020-2023 period. 
This additional finding aims to ensure the continuation of support provided to date, in particular 
in key areas such as basic needs, health care and education, and protection and socio-economic 
support. 

Regarding  bilateral  financial  assistance,  projects  under  the  Instrument  for  Pre-accession 
Assistance  (IPA)  for  Türkiye  continued  to  be  implemented,  in  compliance  with  the  political 
guidance  of  the  EU  Budgetary  Authority.  Financial  assistance  under  the  IPA  III  focuses  on 
priorities  linked  to  the  fundamental  pillars  of  the  enlargement  strategy  as  well  as  on  building 
more resilient and more sustainable economies and societies after the impact of the COVID-19 
pandemic. 

131 

 
 
Türkiye  has  expressed  interest  to  participate  in  a  number  of  EU  programmes  in  the  period 
2021-2027, and has signed the association agreements for the participation in Erasmus+, Horizon 
2020,  and  the  European  Solidarity  Corps  programme.  Negotiations  on  the  association 
agreements  for  the  participation  in  further  programmes  continue.  Türkiye  participates  in  the 
European  Environmental  Agency,  the  European  Monitoring  Centre  for  Drugs  and  Drug 
Addiction  and  the  Civil  Protection  Mechanism.  The  Commission  established  the  Türkiye 
Investment Platform (TIP) to enable stronger EU support to investments in the three overarching 
policy  priorities  of  the  European  Fund  for  Sustainable  Development  +  (EFSD+),  namely  the 
Green Deal, global gateways as well as jobs and growth. 

132 

 
 
 
 
 
 
 
 
STATISTICAL DATA (as of 01.09.2022) 

Türkiye 

Basic data 

Population (thousand) 

Total area of the country (km²) 

Note 

2009 

2016 

2017 

2018 

2019 

2020 

71 517 s 

78 741 s 

79 815 s 

80 811 s 

82 004 bs 

83 155 s 

1) 

785 347 w 

780 270 sw 

780 270 sw 

779 972 w 

779 972 w 

779 972 w 

National accounts 

Note 

2009 

2016 

2017 

2018 

2019 

2020 

Gross domestic product (GDP) (million national currency) 

1 006 373 

2 626 560 

3 133 704 

3 758 774 

4 317 787 

5 046 883 

Gross domestic product (GDP) (million euro) 

465 246 

785 619 

760 497 

658 544 

679 132 

626 576 

GDP (euro per capita) 

6 460 

9 910 

9 470 

8 090 

8 220 

7 510 

GDP per capita (in purchasing power standards (PPS)) 

11 660 

18 536 

19 360 

19 181 

18 466 

18 406 

GDP per capita (in PPS), relative to the EU average (EU-27 = 100) 

Real GDP growth rate: change on previous year of GDP volume (%) 

48.5 

-  4.8 

65.7 

3.3 

66.0 

7.5 

63.3 

3.0 

59.0 

0.9 

61.5 

1.8 

Employment growth (national accounts data), relative to the previous year (%) 

Labour productivity growth: growth in GDP (in volume) per person employed, relative to the 
previous year (%) 

Unit labour cost growth, relative to the previous year (%) 

**3 year change (T/T-3) in the nominal unit labour cost growth index (2015 = 100) 

Labour productivity per person employed: GDP (in PPS) per person employed relative to EU 
average (EU-27 = 100) 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

Gross value added by main sectors 

Agriculture, forestry and fisheries (%) 

Industry (%) 

Construction (%) 

Services (%) 

Final consumption expenditure, as a share of GDP (%) 

Gross fixed capital formation, as a share of GDP (%) 

Changes in inventories, as a share of GDP (%) 

Exports of goods and services, relative to GDP (%) 

Imports of goods and services, relative to GDP (%) 

9.0 

20.6 

6.3 

7.0 

22.2 

9.6 

6.8 

23.3 

9.6 

6.4 

24.9 

7.9 

7.1 

24.2 

6.0 

7.5 

25.6 

5.9 

64.0 s 

61.2 s 

60.3 s 

60.7 s 

62.8 s 

60.9 s 

77.2 

22.2 

0.6 

23.4 

23.4 

74.1 

29.1 

-  1.1 

23.1 

25.2 

73.0 

29.9 

0.8 

26.0 

29.7 

70.8 

29.7 

-  0.3 

31.2 

31.4 

72.4 

25.9 

-  0.8 

32.6 

30.0 

: 

27.4 

4.5 

28.7 

32.5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Gross fixed capital formation by the general government sector, as a percentage of GDP (%) 

: 

: 

: 

: 

: 

: 

Business 

Industrial production volume index (2015 = 100) 

Number of active enterprises (number) 

Birth rate: number of enterprise births in the reference period (t) divided by the number of 
enterprises active in t (%) 

Death rate: number of enterprise deaths in the reference period (t) divided by the number of 
enterprises active in t (%) 

People employed in SMEs as a share of all persons employed (within the non-financial 
business economy) (%) 

Note 

2009 

61.4 

2016 

103.4 

2017 

112.7 

2018 

114.2 

2019 

113.6 

2 631 085 w 

2 981 381 w 

3 100 412 w 

3 160 371 w 

3 228 421 w 

2020 

115.4 

3 304 054 
pw 

: 

13.0 

13.0 

11.2 

14.1 

12.1 

13.3 

12.9 

14.7 w 

: 

: 

: 

78.3 sw 

74.6 sw 

74.2 sw 

74.4 sw 

73.8 sw 

73.9 psw 

Value added by SMEs (in the non-financial business economy) (EUR million) 

68 674 sw 

130 934 sw 

127 683 sw 

106 199 sw 

110 591 sw 

95 591 psw 

Total value added (in the non-financial business economy) (EUR million) 

125 443 w 

241 711 w 

236 088 w 

202 005 w 

208 171 w 

181 255 pw 

Inflation rate and house prices 

Consumer price index (CPI), change relative to the previous year (%) 

**Annual change in the deflated house price index (2015 = 100) 

Note 

2009 

6.3 d 

: 

2016 

7.7 d 

: 

2017 

11.1 d 

: 

2018 

16.3 d 

: 

2019 

15.2 d 

: 

2020 

12.3 d 

: 

Balance of payments 

Note 

2009 

2016 

2017 

2018 

2019 

2020 

Balance of payments: current account total (million euro) 

Balance of payments current account: trade balance (million euro) 

Balance of payments current account: net services (million euro) 

Balance of payments current account: net balance for primary income (million euro) 

Balance of payments current account: net balance for secondary income (million euro) 

Net balance for primary and secondary income: of which government transfers (million euro) 

**3 year backward moving average of the current account balance relative to GDP (%) 

**Five year change in share of world exports of goods and services (%) 

: 

: 

: 

: 

: 

: 

: 

: 

- 24 218.4 

- 35 995.3 

- 17 585.8 

4 777.2 

- 31 325.4 

- 36 013.9 

- 51 370.2 

- 33 861.9 

- 15 027.1 

- 33 188.9 

18 511.9 

22 968.3 

25 772.7 

30 537.6 

10 007.4 

- 8 289.2 

- 9 811.8 

- 10 144.2 

- 11 466.5 

- 8 268.2 

1 572.8 

2 218.4 

1 009.3 

1 644.7 

-  3.8 

16.6 

-  3.8 

6.9 

651.9 

223.5 

-  3.5 

5.7 

745.8 

547.5 

-  2.2 

7.0 

136.4 

90.9 

-  2.3 

-  3.1 

Net balance (inward - outward) of foreign direct investment (FDI) (million euro) 

2) 3) 

5 041.6 w 

9 257.0 s 

7 444.8 s 

7 805.3 s 

5 639.8 s 

4 009.8 s 

Foreign direct investment (FDI) abroad (million euro) 

2) 3) 

1 113.4 w 

2 517.4 

2 321.7 

3 049.7 

2 653.8 

2 839.2 

of which FDI of the reporting economy in the EU-27 countries (million euro) 

2) 3) 

: 

972.9 w 

713.8 

1 716.7 

1 268.6 

1 075.4 w 

Foreign direct investment (FDI) in the reporting economy (million euro) 

2) 3) 

6 155.0 w 

11 774.4 

9 766.5 

10 855.0 

8 293.6 

6 849.0 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
of which FDI of the EU-27 countries in the reporting economy (million euro) 

2) 3) 

: 

3 855.0 w 

2 555.0 

3 094.7 

979.4 

1 063.1 w 

**Net international investment position, relative to GDP (%) 

-  41.5 w 

-  39.7 w 

-  51.5 w 

-  42.2 w 

-  41.4 w 

-  54.5 w 

Year on year rate of change in gross inflow of remittances (in national currency) from migrant 
workers (%) 

4) 

0.2 sw 

0.1 sw 

0.1 sw 

0.1 sw 

0.0 sw 

0.0 sw 

Public finance 

Note 

2009 

2016 

2017 

2018 

2019 

2020 

General government deficit / surplus, relative to GDP (%) 

-  6.1 w 

-  1.3 w 

-  2.8 w 

-  2.9 w 

-  4.4 w 

-  4.7 w 

General government gross debt relative to GDP (%) 

Total  government revenues, as a percentage of GDP (%) 

Total government expenditure, as a percentage of GDP (%) 

: 

31.6 w 

37.7 w 

28.0 w 

32.5 w 

33.8 w 

28.0 w 

31.2 w 

34.0 w 

30.2 w 

31.8 w 

34.7 w 

32.7 w 

31.0 w 

35.4 w 

39.8 w 

31.2 w 

35.9 w 

Financial indicators 

Note 

2009 

2016 

2017 

2018 

2019 

2020 

Gross external debt of the whole economy, relative to GDP (%) 

2) 

42.6 sw 

46.7 sw 

52.6 sw 

55.0 sw 

54.8 sw 

60.5 sw 

Gross external debt of the whole economy, relative to total exports (%) 

190.2 w 

204.2 w 

202.7 w 

179.9 w 

170.0 w 

212.5 w 

Money supply: M1 (banknotes, coins, overnight deposits, million euro) 

49 690.6 w 

103 610.0 w 

99 085.3 w 

84 551.1 w 

108 082.9 w 

135 351.0 w 

Money supply: M2 (M1 plus deposits with maturity up to two years, million euro) 

228 237.3 w 

380 863.3 w 

357 979.4 w 

321 665.1 w 

367 703.2 w 

369 270.6 w 

Money supply: M3 (M2 plus marketable instruments, million euro) 

240 245.6 w 

393 176.4 w 

370 812.2 w 

330 904.3 w 

384 031.8 w 

379 829.6 w 

Total credit by monetary financial institutions to residents (consolidated) (million euro) 

5) 

145 332.7 w 

410 574.0 

377 902.8 

349 175.5 

406 046.7 

406 615.2 

**Annual change in financial sector liabilities (%) 

**Private credit flow, consolidated, relative to GDP (%) 

6) 

**Private debt, consolidated, relative to GDP (%) 

Interest rates: day-to-day money rate, per annum (%) 

Lending interest rate (one year), per annum (%) 

Deposit interest rate (one year), per annum (%) 

Euro exchange rates: average of period (1 euro = … national currency) 

Trade-weighted effective exchange rate index, 42 countries (2015 = 100) 

**3 year change (T/T-3) in the trade-weighted effective exchange rate index, 42 countries 
(2015 = 100) 

: 

: 

: 

9.22 

17.0 

7.1 w 

84 

9.32 

20.8 

9.1 w 

84 

11.58 

17.6 

2.3 w 

82 

17.76 

18.9 

3.3 w 

80 

20.52 

38.0 

10.3 w 

89 

10.85 

15.63 w 

15.79 w 

18.12 w 

28.97 w 

15.84 w 

16.46 w 

7) 

10.31 w 

10.33 w 

13.53 w 

22.31 w 

14.56 w 

13.51 w 

2.163 

146.89 

-0.11 s 

3.343 

92.59 

4.121 

75.92 

5.708 

55.79 

6.358 

49.69 

8.055 

40.22 

-0.23 s 

-0.29 s 

-0.44 s 

-0.46 s 

-0.47 s 

Value of reserve assets (including gold) (million euro) 

2) 

53 648.5 w 

95 863.5 w 

95 361.6 w 

78 770.5 w 

94 413.6 w 

81 664.3 w 

External trade in goods 

Note 

2009 

2016 

2017 

2018 

2019 

2020 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Value of imports: all goods, all partners (million euro) 

Value of exports: all goods, all partners (million euro) 

Trade balance: all goods, all partners (million euro) 

100 764 

179 468 

207 000 

188 337 

181 038 

182 328 

73 284 

128 792 

139 229 

142 290 

153 201 

140 035 

- 27 480 

- 50 676 

- 67 771 

- 46 047 

- 27 836 

- 42 293 

Terms of trade (export price index / import price index * 100) (number) 

8) 

: 

103.6 sw 

98.1 sw 

94.4 sw 

94.5 sw 

98.5 sw 

Share of exports to EU-27 countries in value of total exports (%) 

Share of imports from EU-27 countries in value of total imports (%) 

40.3 s 

37.7 s 

39.7 s 

36.3 s 

40.9 s 

33.6 s 

43.3 s 

32.9 s 

Demography 

Crude rate of natural change of population (natural growth rate): number of births minus 
deaths (per thousand inhabitants) 

Infant mortality rate deaths of children under one year of age (per thousand live births) 

Life expectancy at birth: male (years) 

Life expectancy at birth: female (years) 

Labour market 

Economic activity rate for persons aged 20–64: proportion of the population aged 20–64 that 
is economically active (%) 

*Employment rate for persons aged 20–64: proportion of the population aged 20–64 that are 
in employment (%) 

Male employment rate for persons aged 20–64 (%) 

Female employment rate for persons aged 20–64 (%) 

Employment rate for persons aged 55–64: proportion of the population aged 55–64 that are 
in employment (%) 

Employment by main sectors 

Agriculture, forestry and fisheries (%) 

Industry (%) 

Construction (%) 

Services (%) 

People employed in the public sector as a share of total employment, persons aged 20–64 
(%) 

People employed in the private sector as a share of total employment, persons aged 20–64 
(%) 

Note 

Note 

2009 

12.1 

13.7 

73.3 

78.8 

2009 

54.5 

47.8 

70.4 

25.8 

28.2 

22.9 s 

19.2 s 

6.1 s 

51.7 s 

13.7 w 

2016 

11.2 

10.0 

75.4 

81.0 

2016 

60.9 

54.4 

75.5 

33.2 

33.4 

19.5 s 

19.5 s 

7.3 s 

53.7 s 

13.8 w 

2017 

10.8 

9.2 

75.7 

81.3 

2017 

61.9 

55.3 

76.1 

34.5 

34.4 

19.4 s 

19.1 s 

7.4 s 

54.1 s 

13.3 w 

2018 

10.1 be 

9.3 

76.2 

81.6 

2018 

62.3 

55.6 

76.0 

35.2 

35.3 

18.4 s 

19.7 s 

6.9 s 

54.9 s 

15.4 w 

Unemployment rate: proportion of the labour force that is unemployed (%) 

12.6 

10.9 

10.9 

10.9 

13.7 

13.2 

86.3 w 

86.2 w 

86.7 w 

84.6 w 

83.2 w 

82.3 w 

42.2 s 

31.6 s 

2019 

9.1 be 

9.1 

76.4 

81.8 

2019 

62.2 

53.8 

73.2 

34.4 

33.6 

18.1 s 

19.8 s 

5.5 s 

56.6 s 

16.8 w 

41.1 s 

33.1 s 

2020 

: 

: 

: 

: 

2020 

58.7 

51.0 

70.1 

32.0 

31.1 

17.6 s 

20.5 s 

5.7 s 

56.2 s 

17.7 w 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Male unemployment rate (%) 

Female unemployment rate (%) 

Youth unemployment rate: proportion of the labour force aged 15–24 that is unemployed (%) 

Long-term unemployment rate: proportion of the labour force that has been unemployed for 
12 months or more (%) 

Unemployment rate for persons (aged 25–64) having completed at most lower secondary 
education (ISCED levels 0-2) (%) 

Unemployment rate for persons (aged 25–64) having completed tertiary education (ISCED 
levels 5-8) (%) 

12.6 

12.7 

22.8 

2.9 

11.1 

8.1 

9.6 

13.7 

19.5 

2.2 

9.1 

9.3 

9.4 

13.9 

20.5 

2.4 

8.9 

9.4 

9.6 

13.8 

20.2 

2.4 

9.1 

9.8 

12.4 

16.5 

25.2 

3.2 

12.3 

10.6 

12.4 

14.9 

25.1 

3.3 

11.8 

10.0 

Social cohesion 

Note 

2009 

2016 

2017 

2018 

2019 

2020 

Average nominal monthly wages and salaries (national currency) 

9) 

1 084 w 

2 031 w 

2 287 w 

2 509 w 

2 857 w 

3 501 w 

Index of real wages and salaries (index of nominal wages and salaries divided by the 
inflation index) (2016 = 100) 

GINI coefficient 

Poverty gap 

*Early leavers from education and training: proportion of the population aged 18–24 with at 
most lower secondary education who are not in further education or training (%) 

Standard of living 

Note 

Number of passenger cars relative to population size (number per thousand population) 

Number of mobile phone subscriptions relative to population size (number per thousand 
population) 

: 

44 

32.1 

44.3 

2009 

98.0 

: 

43 

26.6 

34.3 

: 

43 

26.4 

32.5 

: 

43 

25.8 

31.0 

: 

42 

27.4 

28.7 

: 

43 

27.5 

26.7 

2016 

142.0 

2017 

149.0 

2018 

151.0 

2019 

150.0 

2020 

157.0 

865.0 w 

940.4 w 

964.0 w 

977.0 w 

972.0 w 

982.0 w 

Mobile broadband penetration (per 100 inhabitants) 

Fixed broadband penetration (per 100 inhabitants) 

3.4 w 

9 w 

64.8 w 

70.5 w 

74.5 w 

75.0 w 

78.5 w 

13 w 

15 w 

16 w 

17 w 

20 w 

Infrastructure 

Density of railway network (lines in operation per thousand km²) 

Length of motorways (kilometres) 

Innovation and research 

Public expenditure on education relative to GDP (%) 

*Gross domestic expenditure on R&D relative to GDP (%) 

Note 

2009 

10) 

11.6 sw 

2 036 

Note 

2009 

: 

0.80 

2016 

13.0 s 

2 542 

2016 

4.7 

0.94 

2017 

13.1 s 

2 657 

2017 

4.4 

0.95 

2018 

13.2 s 

2 842 

2018 

4.3 

1.03 

2019 

13.3 s 

3 060 

2019 

4.4 

1.06 

2020 

13.3 s 

3 523 

2020 

4.0 sw 

1.09 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Government budget appropriations or outlays on R&D (GBAORD), as a percentage of GDP 
(%) 

Percentage of households who have internet access at home (%) 

0.39 

30.0 

Environment 

Note 

2009 

*Index of greenhouse gas emissions,  CO2 equivalent (1990 = 100) 

Energy intensity of the economy (kg of oil equivalent per 1 000 euro GDP at 2015 constant 
prices) 

Electricity generated from renewable sources relative to gross electricity consumption (%) 

Road share of inland freight transport (based on tonne-km) (%) 

198.9 

196.4 

19.7 w 

94.5 w 

0.35 

76.0 

2016 

252.5 

175.0 

32.3 w 

95.6 w 

0.34 

81.0 

2017 

267.2 

175.3 

29.4 w 

95.4 w 

0.35 

84.0 

2018 

268.5 

167.7 

32.2 w 

94.8 w 

0.35 

88.0 

2019 

266.3 

168.4 

43.6 w 

94.8 w 

0.28 

91.0 

2020 

287.4 

162.8 

41.9 w 

95.1 w 

Energy 

Note 

2009 

2016 

2017 

2018 

2019 

2020 

Primary production of all energy products (thousand TOE) 

29 595 

35 705 

36 466 

39 909 

45 134 

43 636 

Primary production of crude oil (thousand TOE) 

Primary production of solid fuels (thousand TOE) 

Primary production of gas (thousand TOE) 

Net imports of all energy products (thousand TOE) 

Gross inland energy consumption (thousand TOE) 

Gross electricity generation (GWh) 

2 373 

2 721 

2 695 

3 010 

3 102 

3 274 

16 738 

15 498 

15 682 

16 547 

17 429 

15 006 

564 

302 

292 

351 

390 

363 

70 371 s 

106 071 s 

116 755 s 

109 980 s 

105 649 s 

104 983 s 

99 721 

139 634 

150 445 

148 120 

150 123 

148 064 

194 736 

273 694 

296 429 

303 852 

302 796 

305 426 

Agriculture 

Note 

2009 

Agricultural production volume index of goods and services (at producer prices) (2010 = 100) 

Utilised agricultural area (thousand hectares) 

Livestock numbers: live bovine animals (thousand heads, end of period) 

Livestock numbers: live swine (thousand heads, end of period) 

Livestock numbers: live sheep and live goats (thousand heads, end of period) 

Raw milk available on farms (thousand tonnes) 

: 

: 

: 

: 

: 

: 

2016 

: 

2017 

: 

2018 

: 

2019 

: 

2020 

: 

38 328.0 

38 120.0 

38 239.0 

37 712.0 

37 747.0 

14 222.2 p 

16 105.0 p 

17 220.9 p 

17 872.3 

18 158.0 

: 

: 

: 

: 

: 

41 329.2 ps 

44 312.3 s 

46 117.4 s 

48 481.5 s 

54 112.6 s 

18 489.2 w 

20 699.9 w 

22 120.7 w 

22 960.4 w 

: 

Harvested crop production: cereals (including rice) (thousand tonnes) 

33 373.0 

35 724.9 

36 598.8 

34 705.8 

35 202.1 

38 050.8 

Harvested crop production: sugar beet (thousand tonnes) 

16 300.0 

19 465.0 

21 149.0 

18 900.0 

18 055.0 

23 026.0 

Harvested crop production: vegetables (thousand tonnes) 

26 784.0 

30 267.0 

30 826.0 

29 987.0 

31 041.0 

31 120.0 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Source: Eurostat and the statistical authorities in Türkiye 

: = not available 

  b = break in series 

  d =  definition differs 

  e = estimated value 

  p = provisional 

s = Eurostat estimate 

  w= data supplied by and under the responsibility of the national statistical authority and published on an "as is" basis and without any assurance as regards their 

quality and adherence to EU statistical methodology 

* = Europe 2020 indicator 

** = Macroeconomic Imbalance Procedure (MIP) indicator 

  Footnotes: 

1)  Area values are calculated by reference to corine classifications and adapted to LUCAS. Corine data production period is 6 years. 

2)  Average of year exchange rate used to convert to euros. 

3)  Based on BPM6. 

4)  As of Second Quarter of 2021. 

5)  The exchange rate is the Central Bank buying rate at the end of the year.  Data cover loans granted by MFIs to residents. Participation Banks and Investment and 

Development Banks are included. 

6)  Data cover debt securities and loans. 

7)  Average of monthly data. Overnight deposit facility. 

8)  With the January 2021 press release, foreign trade statistics according to the general trade system were used in the calculation of the indices and the base year 
was updated as 2015=100. Data are given as of January 2013. Since the indices based on 2015=100 are not withdrawn annually, the requested data cannot be 
provided. 

Indices are calculated with Fisher index formula and 2015=100. 

9)  Source: Income and Living Conditions Survey. 

10)  Main lines only.