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

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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}
Offentligt
KOM (2022) 0528 - SWD-dokument
Europaudvalget 2022
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
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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.
4
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
6
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
7
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
8
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
9
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
10
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
11
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
12
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
13
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.
14
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
15
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.
16
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
17
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.
18
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
19
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
20
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
21
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
22
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.
23
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.
24
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 impartially, respecting European standards; strengthen 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;
25
 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.
26
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
27
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
28
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.
29
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
30
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
31
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.
32
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
33
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
34
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
35
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
36
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
37
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
38
(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,
39
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.
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 in Istanbul, International Women’s Day, as well as 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
40
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
41
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’.
42
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
43
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
44
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 Istanbul governorate. In April 2022, a court case began in relation to 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.
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
45
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.
46
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.
47
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.
48
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
49
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.
50
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.
51
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
52
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
53
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
54
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.
55
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
56
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
57
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, implementation of 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.
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
58
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
59
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: 2013-18
average
2019 2020 2021
Türkiye - Key economic figures
GDP per capita (% of EU-27 in PPS)1)
65 59 61 64
Real GDP growth 5.6 0.9 1.8 11.0
Economic activity rate of the population aged 15+ (%),
total1)
51.1 52.9 49.1 51.4
female 31.5 34.3 30.8 32.9
male 71.2 71.9 67.8 70.3
Unemployment rate of the population aged 15+ (%),
total1)
10.3 13.7 13.1 12.0
female 12.8 16.4 14.8 14.7
male 9.2 12.4 12.4 10.7
60
Employment of the population aged 15+ (annual growth
%) 3.2 -2.3 -4.8 7.9
Nominal wages (annual growth
%) 13.9 26.2 18.0 19.3
Consumer price index (annual growth %) 9.9 15.2 12.3 19.6
Exchange rate against EUR 3.60 6.35 8.03 10.45
Current account balance (% of GDP) -4.0 0.7 -5.0 -1.7
Net foreign direct investment, FDI (% of GDP) 1.1 0.9 0.6 0.9
General government balance (% of GDP)1)
-1.5 -3.2 -2.9 -2.3
General government debt (% of GDP) 28.8 32.6 39.7 422)
Notes:
1) Eurostat
2) State government
Source: national sources
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
61
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
62
time since the 2018 currency crisis.
Net exports had a sizeable positive
contribution to growth as the strong
export performance continued
unabated, while imports were
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
share of non-core foreign
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.
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
63
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
0
10
20
30
40
50
-4
-2
0
2
2016 2017 2018 2019 2020 2021
Graph 5.3: Türkiye - Fiscal developments
Primary balance (lhs) Interest (lhs)
GG balance (lhs) Public Debt (rhs)
Source: National sources
% of GDP
64
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
65
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.
66
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
67
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 underemployment and
potential labour force. Despite the
economic rebound, the gap between
male and female employment
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.
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;
68
→ 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
69
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
of the Turkish economy. Although its share in GDP remains low at 2.8 % in 2021, the sector
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
70
schemes, mostly targeting SMEs. The SME Development Organisation KOSGEB provides
support to companies on R&D, innovation, product development, 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.
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:
0
10
20
30
40
2014 2015 2016 2017 2018 2019 2020 2021
Graph 5.5a: Türkiye - Exports of goods
EU CEFTA Other
Source: WiiW
% of GDP
0
10
20
30
40
2014 2015 2016 2017 2018 2019 2020 2021
Graph 5.5b: Türkiye - Imports of goods
EU CEFTA Other
Source: WiiW
% of GDP
71
 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
72
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.
73
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
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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
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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
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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
77
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
78
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
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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).
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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.
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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
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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.
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 Standardisation (CEN) and 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.
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
83
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
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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
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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
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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
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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
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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 the insufficient legal framework for microfinance.
Recommendations of last year’s report were addressed in a limited way by assessments carried
out on some SME programmes.
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
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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,
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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 inclusion, in addition to economic development and
competitiveness, while ensuring definition of long-term priorities, regional specialisation
strategies and partnerships.
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
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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.
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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.
STATISTICAL DATA (as of 01.09.2022)
Türkiye
Basic data Note 2009 2016 2017 2018 2019 2020
Population (thousand) 71 517 s 78 741 s 79 815 s 80 811 s 82 004 bs 83 155 s
Total area of the country (km²) 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) 48.5 65.7 66.0 63.3 59.0 61.5
Real GDP growth rate: change on previous year of GDP volume (%) - 4.8 3.3 7.5 3.0 0.9 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 (%) 9.0 7.0 6.8 6.4 7.1 7.5
Industry (%) 20.6 22.2 23.3 24.9 24.2 25.6
Construction (%) 6.3 9.6 9.6 7.9 6.0 5.9
Services (%) 64.0 s 61.2 s 60.3 s 60.7 s 62.8 s 60.9 s
Final consumption expenditure, as a share of GDP (%) 77.2 74.1 73.0 70.8 72.4 :
Gross fixed capital formation, as a share of GDP (%) 22.2 29.1 29.9 29.7 25.9 27.4
Changes in inventories, as a share of GDP (%) 0.6 - 1.1 0.8 - 0.3 - 0.8 4.5
Exports of goods and services, relative to GDP (%) 23.4 23.1 26.0 31.2 32.6 28.7
Imports of goods and services, relative to GDP (%) 23.4 25.2 29.7 31.4 30.0 32.5
Gross fixed capital formation by the general government sector, as a percentage of GDP (%) : : : : : :
Business Note 2009 2016 2017 2018 2019 2020
Industrial production volume index (2015 = 100) 61.4 103.4 112.7 114.2 113.6 115.4
Number of active enterprises (number) 2 631 085 w 2 981 381 w 3 100 412 w 3 160 371 w 3 228 421 w 3 304 054
pw
Birth rate: number of enterprise births in the reference period (t) divided by the number of
enterprises active in t (%)
: 13.0 14.1 13.3 12.9 14.7 w
Death rate: number of enterprise deaths in the reference period (t) divided by the number of
enterprises active in t (%)
13.0 11.2 12.1 : : :
People employed in SMEs as a share of all persons employed (within the non-financial
business economy) (%)
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 Note 2009 2016 2017 2018 2019 2020
Consumer price index (CPI), change relative to the previous year (%) 6.3 d 7.7 d 11.1 d 16.3 d 15.2 d 12.3 d
**Annual change in the deflated house price index (2015 = 100) : : : : : :
Balance of payments Note 2009 2016 2017 2018 2019 2020
Balance of payments: current account total (million euro) : - 24 218.4 - 35 995.3 - 17 585.8 4 777.2 - 31 325.4
Balance of payments current account: trade balance (million euro) : - 36 013.9 - 51 370.2 - 33 861.9 - 15 027.1 - 33 188.9
Balance of payments current account: net services (million euro) : 18 511.9 22 968.3 25 772.7 30 537.6 10 007.4
Balance of payments current account: net balance for primary income (million euro) : - 8 289.2 - 9 811.8 - 10 144.2 - 11 466.5 - 8 268.2
Balance of payments current account: net balance for secondary income (million euro) : 1 572.8 2 218.4 651.9 745.8 136.4
Net balance for primary and secondary income: of which government transfers (million euro) : 1 009.3 1 644.7 223.5 547.5 90.9
**3 year backward moving average of the current account balance relative to GDP (%) : - 3.8 - 3.8 - 3.5 - 2.2 - 2.3
**Five year change in share of world exports of goods and services (%) : 16.6 6.9 5.7 7.0 - 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 (%) : 28.0 w 28.0 w 30.2 w 32.7 w 39.8 w
Total government revenues, as a percentage of GDP (%) 31.6 w 32.5 w 31.2 w 31.8 w 31.0 w 31.2 w
Total government expenditure, as a percentage of GDP (%) 37.7 w 33.8 w 34.0 w 34.7 w 35.4 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 (%) : 17.0 20.8 17.6 18.9 38.0
**Private credit flow, consolidated, relative to GDP (%) 6) : 7.1 w 9.1 w 2.3 w 3.3 w 10.3 w
**Private debt, consolidated, relative to GDP (%) : 84 84 82 80 89
Interest rates: day-to-day money rate, per annum (%) 9.22 9.32 11.58 17.76 20.52 10.85
Lending interest rate (one year), per annum (%) 15.63 w 15.79 w 18.12 w 28.97 w 15.84 w 16.46 w
Deposit interest rate (one year), per annum (%) 7) 10.31 w 10.33 w 13.53 w 22.31 w 14.56 w 13.51 w
Euro exchange rates: average of period (1 euro = … national currency) 2.163 3.343 4.121 5.708 6.358 8.055
Trade-weighted effective exchange rate index, 42 countries (2015 = 100) 146.89 92.59 75.92 55.79 49.69 40.22
**3 year change (T/T-3) in the trade-weighted effective exchange rate index, 42 countries
(2015 = 100)
-0.11 s -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) 100 764 179 468 207 000 188 337 181 038 182 328
Value of exports: all goods, all partners (million euro) 73 284 128 792 139 229 142 290 153 201 140 035
Trade balance: all goods, all partners (million euro) - 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 (%) 40.3 s 39.7 s 40.9 s 43.3 s 42.2 s 41.1 s
Share of imports from EU-27 countries in value of total imports (%) 37.7 s 36.3 s 33.6 s 32.9 s 31.6 s 33.1 s
Demography Note 2009 2016 2017 2018 2019 2020
Crude rate of natural change of population (natural growth rate): number of births minus
deaths (per thousand inhabitants)
12.1 11.2 10.8 10.1 be 9.1 be :
Infant mortality rate deaths of children under one year of age (per thousand live births) 13.7 10.0 9.2 9.3 9.1 :
Life expectancy at birth: male (years) 73.3 75.4 75.7 76.2 76.4 :
Life expectancy at birth: female (years) 78.8 81.0 81.3 81.6 81.8 :
Labour market Note 2009 2016 2017 2018 2019 2020
Economic activity rate for persons aged 20–64: proportion of the population aged 20–64 that
is economically active (%)
54.5 60.9 61.9 62.3 62.2 58.7
*Employment rate for persons aged 20–64: proportion of the population aged 20–64 that are
in employment (%)
47.8 54.4 55.3 55.6 53.8 51.0
Male employment rate for persons aged 20–64 (%) 70.4 75.5 76.1 76.0 73.2 70.1
Female employment rate for persons aged 20–64 (%) 25.8 33.2 34.5 35.2 34.4 32.0
Employment rate for persons aged 55–64: proportion of the population aged 55–64 that are
in employment (%)
28.2 33.4 34.4 35.3 33.6 31.1
Employment by main sectors
Agriculture, forestry and fisheries (%) 22.9 s 19.5 s 19.4 s 18.4 s 18.1 s 17.6 s
Industry (%) 19.2 s 19.5 s 19.1 s 19.7 s 19.8 s 20.5 s
Construction (%) 6.1 s 7.3 s 7.4 s 6.9 s 5.5 s 5.7 s
Services (%) 51.7 s 53.7 s 54.1 s 54.9 s 56.6 s 56.2 s
People employed in the public sector as a share of total employment, persons aged 20–64
(%)
13.7 w 13.8 w 13.3 w 15.4 w 16.8 w 17.7 w
People employed in the private sector as a share of total employment, persons aged 20–64
(%)
86.3 w 86.2 w 86.7 w 84.6 w 83.2 w 82.3 w
Unemployment rate: proportion of the labour force that is unemployed (%) 12.6 10.9 10.9 10.9 13.7 13.2
Male unemployment rate (%) 12.6 9.6 9.4 9.6 12.4 12.4
Female unemployment rate (%) 12.7 13.7 13.9 13.8 16.5 14.9
Youth unemployment rate: proportion of the labour force aged 15–24 that is unemployed (%) 22.8 19.5 20.5 20.2 25.2 25.1
Long-term unemployment rate: proportion of the labour force that has been unemployed for
12 months or more (%)
2.9 2.2 2.4 2.4 3.2 3.3
Unemployment rate for persons (aged 25–64) having completed at most lower secondary
education (ISCED levels 0-2) (%)
11.1 9.1 8.9 9.1 12.3 11.8
Unemployment rate for persons (aged 25–64) having completed tertiary education (ISCED
levels 5-8) (%)
8.1 9.3 9.4 9.8 10.6 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 44 43 43 43 42 43
Poverty gap 32.1 26.6 26.4 25.8 27.4 27.5
*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 (%)
44.3 34.3 32.5 31.0 28.7 26.7
Standard of living Note 2009 2016 2017 2018 2019 2020
Number of passenger cars relative to population size (number per thousand population) 98.0 142.0 149.0 151.0 150.0 157.0
Number of mobile phone subscriptions relative to population size (number per thousand
population)
865.0 w 940.4 w 964.0 w 977.0 w 972.0 w 982.0 w
Mobile broadband penetration (per 100 inhabitants) 3.4 w 64.8 w 70.5 w 74.5 w 75.0 w 78.5 w
Fixed broadband penetration (per 100 inhabitants) 9 w 13 w 15 w 16 w 17 w 20 w
Infrastructure Note 2009 2016 2017 2018 2019 2020
Density of railway network (lines in operation per thousand km²) 10) 11.6 sw 13.0 s 13.1 s 13.2 s 13.3 s 13.3 s
Length of motorways (kilometres) 2 036 2 542 2 657 2 842 3 060 3 523
Innovation and research Note 2009 2016 2017 2018 2019 2020
Public expenditure on education relative to GDP (%) : 4.7 4.4 4.3 4.4 4.0 sw
*Gross domestic expenditure on R&D relative to GDP (%) 0.80 0.94 0.95 1.03 1.06 1.09
Government budget appropriations or outlays on R&D (GBAORD), as a percentage of GDP
(%)
0.39 0.35 0.34 0.35 0.35 0.28
Percentage of households who have internet access at home (%) 30.0 76.0 81.0 84.0 88.0 91.0
Environment Note 2009 2016 2017 2018 2019 2020
*Index of greenhouse gas emissions, CO2 equivalent (1990 = 100) 198.9 252.5 267.2 268.5 266.3 287.4
Energy intensity of the economy (kg of oil equivalent per 1 000 euro GDP at 2015 constant
prices)
196.4 175.0 175.3 167.7 168.4 162.8
Electricity generated from renewable sources relative to gross electricity consumption (%) 19.7 w 32.3 w 29.4 w 32.2 w 43.6 w 41.9 w
Road share of inland freight transport (based on tonne-km) (%) 94.5 w 95.6 w 95.4 w 94.8 w 94.8 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) 2 373 2 721 2 695 3 010 3 102 3 274
Primary production of solid fuels (thousand TOE) 16 738 15 498 15 682 16 547 17 429 15 006
Primary production of gas (thousand TOE) 564 302 292 351 390 363
Net imports of all energy products (thousand TOE) 70 371 s 106 071 s 116 755 s 109 980 s 105 649 s 104 983 s
Gross inland energy consumption (thousand TOE) 99 721 139 634 150 445 148 120 150 123 148 064
Gross electricity generation (GWh) 194 736 273 694 296 429 303 852 302 796 305 426
Agriculture Note 2009 2016 2017 2018 2019 2020
Agricultural production volume index of goods and services (at producer prices) (2010 = 100) : : : : : :
Utilised agricultural area (thousand hectares) : 38 328.0 38 120.0 38 239.0 37 712.0 37 747.0
Livestock numbers: live bovine animals (thousand heads, end of period) : 14 222.2 p 16 105.0 p 17 220.9 p 17 872.3 18 158.0
Livestock numbers: live swine (thousand heads, end of period) : : : : : :
Livestock numbers: live sheep and live goats (thousand heads, end of period) : 41 329.2 ps 44 312.3 s 46 117.4 s 48 481.5 s 54 112.6 s
Raw milk available on farms (thousand tonnes) : 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.