The International Health Tourism Authorisation Certificate in Türkiye: Application, Refusal, Suspension and Revocation

An international health tourism authorisation certificate is compulsory in Türkiye for two entirely different kinds of business, and they apply to two different authorities. Under Article 5(1) of the Regulation on International Health Tourism and Tourist Health, published in the Official Gazette of 26 April 2025 No. 32882, the Ministry of Health issues the certificate to a health facility and USHAŞ to an intermediary organisation — and neither may operate in this field without one. What follows sets out the application route, the service standards behind it, every ground on which the certificate can be suspended or revoked, and the time-limits for challenging those decisions.

The 2025 Regulation replaced the text of 13 July 2017 outright (Article 17) and rests on Article 9(c) and Additional Articles 11 and 19 of Law No. 3359 on the Fundamentals of Health Services, on Additional Article 2 of Decree Law No. 663 and on Presidential Decree No. 1. This is regulatory work rather than patient work: a claim brought by a patient after treatment is covered in the guide to medical tourism in Türkiye, and the liability framework behind it in our health law material.

Who Must Hold a Certificate, and Who Issues It

The Regulation applies to people who come to Türkiye to obtain healthcare and to people already here as tourists when a health need arises, provided they fall outside Law No. 5510 and outside bilateral reciprocity agreements (Article 2(1)). Article 2(2) then removes nine categories from scope — among them nationals of States with social security agreements, student residence permit holders and their dependants, persons under temporary or international protection, and blue card holders under Articles 28 and 44 of Law No. 5901. Article 2(3) is the sentence that is easy to miss: a person in an excluded category may still be treated under this Regulation if they choose to undertake payment as an international health tourist.

The definitions in Article 4 do real work. A health facility is one that already holds a facility licence under its own legislation and has been given an authorisation certificate — so authorisation is a second layer stacked on a licence, never a substitute for it. An intermediary organisation is one operated by legal persons holding a certificate, providing consultancy, facility organisation, accommodation, transport and transfer services to the health tourist and any companions. A sole trader cannot be an intermediary, which is why intermediary projects usually begin as a company formation question before they become a licensing one.

Two features change how a group should be structured. Article 5(4) requires a separate certificate for each additional intermediary organisation or branch opened by the same owning legal person, and prohibits health tourism activity at any office not separately authorised. Article 5(5) states flatly that the certificate cannot be transferred. Together these make the authorisation a per-establishment, non-tradable asset — a point to build into any share purchase, reorganisation or branch rollout at the corporate planning stage rather than discover at completion.

The Application: Two Tracks, Three Clocks

Both tracks run on the same rhythm, with different addressees and different annexes.

The thirty working days matter more than the fifteen. A deficiency notice is not a request; it starts a period after which Article 5 treats the application as refused, with no further decision taken. That deemed refusal is an administrative act, and the sixty-day clock in Article 7 of Law No. 2577 attaches to it in the ordinary way.

Service Standards: What the Certificate Commits You To

Article 6 is where most compliance failures originate, because the certificate carries continuing obligations rather than one-off conditions.

For health facilities, Article 6(1)(b) splits the field: hospitals, medical centres, medical laboratories and dialysis centres must be accredited by TÜSKA, the Turkish Health Services Quality and Accreditation Institute; every other kind of facility must obtain a certificate issued by the Ministry. Article 6(1)(ç) confirms that a facility may accept a health tourist who approaches it directly, and Article 6(1)(d) allows remote health services under the Regulation of 10 February 2022, provided the fact is declared on the HealthTürkiye Portal. Article 6(1)(e) reaches into supply chains: for activities that ought to be performed by an intermediary, the facility may not buy services from unauthorised persons or organisations — which makes the marketing agency, the patient-acquisition partner and the transfer provider a compliance question for the facility itself.

For intermediary organisations, Article 6(2)(a) requires accommodation, transport and transfer to be delivered through travel agencies licensed under Law No. 1618 — with an express exception where the intermediary is itself a licensed agency and may then perform those services directly. Article 6(2)(b) requires call handling in at least two foreign languages on a 24/7 basis, in-house or under a contract with a call centre, and Article 6(2)(c) prohibits health tourism personnel from working at more than two intermediary organisations at once.

Article 6(3) then allocates responsibility: the facility and the intermediary are each responsible, according to the type of service supplied, for what the health tourist receives while in Türkiye, and that responsibility extends to medical malpractice arising afterwards. How that division works in practice, and what the contract between the two has to carry because the Regulation leaves it open, is taken up separately in the note on the legal position of health tourism intermediaries. The words “complication and” in that sentence are currently stayed — see below.

Article 7 requires an international health tourism unit inside the facility, covering admission, treatment, invoicing, discharge, interpreting and coordination with intermediaries; at least one member must hold a documented foreign language qualification, and a named responsible member of staff is assigned to each health tourist and recorded on the Portal. Article 8 adds the data layer: a health information management system registered with the Ministry is compulsory, personal health data is processed in line with Law No. 6698 and Additional Article 19 of Law No. 3359, and both facilities and intermediaries must keep their Portal entries complete, accurate and current — including every service unit they establish, inside Türkiye or abroad.

The transitional dates, and the stay in Article 6(3)

Transitional Article 1(1) gave organisations already certified before 26 April 2025 six months to bring themselves into line, on pain of revocation — a period that expired on 26 October 2025. Transitional Article 1(3) sets 31 December 2026 for the accreditation or certification obligation in Article 6(1)(b); that deadline stands, and the TÜSKA process is not a short one.

Transitional Article 1(2) set 31 December 2025 for the complication insurance obligation in Article 6(1)(c), and that date has passed. The consolidated text published on mevzuat.gov.tr records one stay of execution: the words “complication and” in Article 6(3). Article 6(1)(c) and the transitional paragraph carry no stay note. A stay under Article 27 of Law No. 2577 is interim relief, not annulment: it is granted only where irreparable harm and manifest illegality are both made out, and the substantive case remains to be decided. The stay narrows the shared-responsibility sentence in Article 6(3) to medical malpractice for now; it does not touch the facility’s duty to take out complication insurance under Article 6(1)(c).

Suspension and Revocation: Every Route in the Text

Five distinct mechanisms can take the certificate away, and only some of them involve wrongdoing.

Article 9(1) puts the cycle on an annual footing: USHAŞ assesses both facilities and intermediaries against the Annex 2 criteria at least once a year and notifies the result through the Portal, while inspection runs under the Regulation on the Inspection of Private Health Facilities of 17 November 2023 against the criteria in Annexes 4 and 5 (Article 15(1)). Article 15(2) adds a consequence outside the health system: where activity is stopped or a certificate suspended or revoked, the Ministry notifies the Ministry of Trade and the Ministry of Culture and Tourism — which is how a health regulatory decision becomes a trade and tourism licensing problem as well.

Behind the Regulation stand the fines in Additional Article 11 of Law No. 3359, imposed by governors, with activity suspension of up to ten days reserved to the Ministry. Since the amendment of 21 February 2024 the first paragraph states expressly that ministerial supervision covers the activities of every kind of organisation within international health tourism. Each fine is anchored to a fixed floor and to the previous month’s gross service revenue, and the two are not built the same way: not less than TRY 250,000 and up to half that revenue for opening a facility or specially-permitted unit without Ministry permission or supplying services there; not less than TRY 50,000 and equal to two per cent of that revenue for failing to keep prescribed records or make required notifications — here the percentage is the amount, not a ceiling; not less than TRY 100,000 and up to five per cent for breaching emergency-care, staffing, device or premises standards; and, under a paragraph added on 21 July 2025, not less than TRY 100,000 and up to two per cent for promotion that crosses into advertising. Repetition within a year doubles the fine; a third instance brings the ten-day suspension. Operating without a licence or authorisation is not merely a fine — the second paragraph provides for one to three years’ imprisonment together with a judicial fine. Those floors are the figures as enacted; under Article 17(7) of Law No. 5326 fixed administrative fines are raised each calendar year by the revaluation rate, so the current amount comes from the year in question rather than the statute text.

Promotion: The One Regime That Treats Health Tourism Generously

Article 13(1) of the Regulation refers promotion to the Regulation on Promotion and Information Activities in Health Services — and that reference has moved. The 2023 text it names was repealed by the Regulation of 12 November 2025 No. 33075, whose Article 13(2) deems references to the repealed text made to the new one, and whose Article 2 expressly covers international health tourism intermediary organisations.

Its general position is restrictive: Article 5(1) prohibits open or covert advertising, prohibits posts trading on patient thanks or satisfaction (e), allows search-engine and social-platform registration only where it is not paid or sponsored (i), bars prize draws and gifts (l), and prohibits any mention of price, discount, campaign or promotion (m).

Article 8 then builds a genuinely more permissive regime for authorised health tourism organisations:

• Sponsored promotion is permitted, but only through a separate foreign-facing website or social media account, only in official languages other than Turkish, and only where that channel states openly that the service is health tourism (Article 8(1)(a)).
• The authorisation certificate must be published on that site or account, and the HealthTürkiye logo used across all channels (Article 8(1)(b) and (e)).
• Activity aimed at creating demand among people living in Türkiye is prohibited; the domestic audience cannot be selected, and automatic audience definitions must be disabled (Article 8(1)(c)).
• Patient stories, comments and expressions of thanks may appear on that outward channel where privacy and patient rights are respected and explicit consent is documented (Article 8(1)(ç)) — an exception to the prohibition in Article 5(1)(e).
• Names, titles and URLs must match the licence, an intermediary’s URL must carry its trade or business name, and an intermediary must not give the impression of being a health facility (Article 8(1)(f), (g) and (h)).
• Article 8(3) permits discount, campaign and competitive price announcements in those outward-facing channels — the clearest instance of the exception sitting one sentence after the prohibition — while Article 8(2) bars promoting any procedure that is prohibited or unpermitted in Türkiye.

Enforcement runs through a seven-member provincial evaluation commission, which must decide a referred file within forty-five days (Article 10); the sanctions in Article 12(1)(a) are then applied on the basis of the fifth paragraph of Additional Article 11 of Law No. 3359, closing the loop back to the fines above.

Challenging a Refusal, a Suspension or a Revocation

Three separate points decide whether a challenge is even heard.

Which court. A refusal, suspension or revocation by the Ministry is an administrative act reviewable by the administrative courts. An administrative fine is not: Article 27(1) of Law No. 5326 sends it to the criminal judgeship of the peace within fifteen days of notification, and a fine not challenged in that period becomes final. The reconciling provision is Article 27(8): where administrative-court decisions have also been taken about the same person in the same proceeding, the illegality arguments against the fine are heard in the administrative court together with the annulment claim. Since an inspection frequently produces both a fine and a suspension, the package often travels together — but that must be checked in each file, because getting it wrong costs the fifteen-day period. Where the decision is USHAŞ’s rather than the Ministry’s, the forum is not settled by the Regulation itself and should be confirmed before either clock expires.

When. Article 7(1) of Law No. 2577 gives sixty days before the administrative courts, running under Article 7(2)(a) from written notification. Article 11 allows an application within that period to the higher authority — or, where there is none, to the authority that took the decision — and that application suspends the running of the litigation period. Article 11(2) treats silence for thirty days as refusal; Article 11(3) then restarts the period counting the time already elapsed. It is suspended, not reset, which is why an Article 11 application filed on day fifty-five leaves five days and not sixty.

Whether anything is stopped meanwhile. Article 27(1) states that bringing an action does not stay the act. A stay must be applied for and granted, and Article 27(2) requires irreparable or seriously difficult harm and manifest illegality together, in a reasoned decision, ordinarily after the administration’s defence has been taken. For a suspended certificate this is usually the decisive application: six months without authorisation is not restored by a favourable judgment two years later.

One route is often overlooked. Article 7(4) lets a person to whom a regulatory instrument has been applied sue the instrument, the applying act, or both — and the instrument’s survival does not prevent annulment of the act founded on it.

What Falls Outside This Framework

Two boundaries are worth stating. First, tourist health is not health tourism. Article 10(1) allows foreigners staying temporarily in Türkiye to use public, university or private health services for illnesses arising while they are here — but the sentence that follows provides that continuing treatment after the acute or emergency episode cannot be given at a facility without an authorisation certificate. Emergency admission itself is unconditional: Article 10(3) requires the patient to be accepted and treated without condition or delay, collection coming afterwards. For road traffic accidents, Article 10(4) sends the cost to the Social Security Institution regardless of nationality and prohibits demanding it from the patient — subject to the exception that an optional supplementary travel insurer is invoiced within its policy.

Second, pricing is not commercial. Article 11 provides that the price of health services supplied under international health tourism is determined by the Ministry, and obliges the facility to follow the procedures and principles in the Ministry’s health tourism tariff. Article 12 then requires a sales receipt or invoice with an itemised statement of services and unit prices, and a further set of documents — medicines and consumables charged, test and imaging results, prescriptions for items bought outside, and the intermediary’s own itemised accommodation, transport, transfer, interpreting and consultancy charges — to be supplied free of charge on request. Because the tariff is administrative and changes, the figure to work from is the one in force on the date of service.

Our work on this framework is described under health tourism regulatory compliance.