Expenses for Foreign Nationals Working Without a Permit to Be Recovered from Employers

Published in the Official Gazette dated July 23, 2025, and numbered 32502, the "Regulation on the Recovery of Various Expenses from Employers of Foreign Nationals Who Are Subject to Deportation Due to Unauthorized Employment" introduces a new legal obligation directly affecting employers.

According to this Regulation, any public expenses arising during the deportation process of foreign nationals working without a permit in Türkiye shall be recovered from the employer or the employer's representative who engaged these individuals.

The Regulation sets out the procedures and principles for collecting the following public expenditures made for foreign nationals found to be working without authorization and reported to the Provincial Directorate of Migration Management for deportation, along with their spouses and children (if any):

• Accommodation expenses,
• Repatriation costs,
• Medical expenses incurred when necessary.

These expenses, if covered by the public budget, will be subject to reimbursement by the relevant employer.

Who Is Covered?

This Regulation applies to:

• Foreign nationals who are found to be working without a valid permit and are subject to a deportation order,
• Employers or employer representatives who employ such individuals without authorization,
• The spouses and children of such foreign nationals,
• Expenses paid from the budget of the Presidency of Migration Management that cannot be directly collected from the foreign national.

Collection Procedure and Legal Basis

In cases where the Presidency of Migration Management is unable to recover the relevant expenses directly from the foreign national, these amounts shall be collected from the employer or employer's representative in accordance with the provisions of Law No. 6183 on the Procedure for the Collection of Public Receivables.

An official notification will be sent to the employer, requesting payment of the specified amount within one month. If the payment is not made within this period, enforcement actions, including collection proceedings and asset seizures, may be initiated through the relevant tax office.

Conclusion and Recommendation

The Regulation will enter into force six months after its publication and introduces significant risks, particularly for employers who engage undocumented foreign workers.

In addition to administrative fines, the Regulation authorizes the direct recovery of actual public expenditures from employers.

For this reason, it is of critical importance that employers take timely precautions and ensure that work permit processes are conducted in full compliance with legal requirements in order to avoid potential financial sanctions in the future.

You can access the relevant regulation here. (In Turkish)