Recent Developments in Turkish Employment Law: Key Updates for Foreign Employers

The headline change for foreign employers in Türkiye: since 1 January 2025, every workplace in the less-hazardous class with fewer than 50 employees must have a compliant occupational health and safety (OHS) arrangement in place, and non-compliance now carries an administrative fine. Alongside that, İŞKUR training thresholds have been eased, the 2026 minimum wage and severance ceiling have risen, and the Court of Cassation has reaffirmed that a missed amendment-fee deadline can overturn an otherwise sound labour judgment. This guide explains each update and what it means for your workforce in 2026.

Why these updates matter to foreign employers in Türkiye

Turkish employment law is governed mainly by the Labour Law No. 4857, with occupational safety set out in the Occupational Health and Safety Law No. 6331 and a steady flow of secondary regulations published in the Official Gazette. For foreign-owned companies, branches, and liaison offices, the practical risk is rarely the headline statute. It is the frequent amendments and Court of Cassation (Yargıtay) rulings that quietly shift day-to-day compliance duties and create fines you did not budget for.

The changes below touch four areas at once: how small workplaces must organise OHS (now a hard obligation, not a choice); the updated 2026 wage and severance figures that feed almost every payroll calculation; how state-supported training thresholds have eased; and how procedural deadlines decide labour litigation. Each carries direct cost and liability consequences. If you are establishing a presence here, our team can also help with setting up a company or branch in Türkiye and structuring compliant employment from day one.

OHS for workplaces under 50 employees is now mandatory

This is the single most decision-relevant update for a small foreign employer. After years of postponement, Articles 6 and 7 of Law No. 6331 took full effect on 1 January 2025 for public bodies and for less-hazardous workplaces with fewer than 50 employees. From that date, these workplaces must have an occupational safety specialist (iş güvenliği uzmanı) and a workplace physician (işyeri hekimi) arrangement in place. The duty is no longer optional.

Your two compliant routes

A qualifying workplace can satisfy the duty in one of two ways:

• Outsource it. Employ a safety specialist and physician directly, or buy the service from a Joint Health and Safety Unit (OSGB) or a workplace-health centre (ÇASMER). This is the simplest route for most foreign-owned small offices.
• Self-service. Under amendments brought by Law No. 7538 (January 2025), an employer or employer representative in a less-hazardous workplace with fewer than 50 employees may personally perform OHS services after completing the Ministry-approved training, except for initial and periodic medical examinations, which still require a physician.

How the self-service route works

• Training certificate validity: once the employer or representative completes the designated OHS training, the certificate is valid indefinitely. There is no expiry or renewal requirement.
• Employer representative: a person acting on the employer's behalf with a managerial role over the workplace. That person needs a full-time employment contract to bind the company in OHS matters. We can help with the underlying employment contracts and workplace agreements.
• No academic prerequisite: the OHS training is open to all; a university degree is not required.
• Registration: the employer or representative must register through the İSG-KATİP system run by the Directorate General of Occupational Health and Safety. The service is valid from İSG-KATİP approval. (This is separate from registering the worker with the Social Security Institution, the SGK.)
• Multiple sites: an employer may cover several workplaces in the same province, provided the combined workforce stays under 50. An employer representative is limited to a single workplace.
• Existing specialists: holders of an occupational safety specialist certificate may provide OHS services (other than the medical examinations reserved to a physician) without further training.

A practical example

A technology firm with 40 employees, classified as less hazardous, can either buy a package from an OSGB or have its owner complete the OHS training and register via İSG-KATİP to run OHS internally, excluding periodic health checks. Either way, doing nothing is no longer an option from 2025 onward.

2026 minimum wage and severance ceiling: the figures that drive payroll

For a query about recent employment-law developments, the updates foreign employers most often need are the annual money figures, because they feed nearly every calculation, from overtime to notice pay to severance.

Minimum wage

The statutory minimum wage (asgari ücret) was raised by 27% for 2026. Effective 1 January 2026, it is approximately 33,029.59 TL gross per month (about 28,075.14 TL net). The minimum wage indirectly resets social-security premium floors and ceilings, so a wage rise ripples through your entire payroll cost.

Severance ceiling

Severance pay (kıdem tazminatı) is capped per year of service, and the cap is updated twice a year. For the first half of 2026 (1 January to 30 June 2026) the severance ceiling is 64,948.77 TL per completed year. Only stamp tax is deducted from severance; there is no income tax or social-security premium on it.

For the planning angle on getting separations right under these numbers, see our guide to severance pay in the 2025-2026 transition.

Eased İŞKUR active labour-force and on-the-job training thresholds

The framework for the programmes run by the Turkish Employment Agency (İŞKUR, established under Law No. 4904) was amended on 19 April 2025 (Official Gazette No. 32875), through the Active Labour Force Services regulation and the accompanying İŞKUR circular, to make state-supported training easier to use, particularly in manufacturing.

What changed

• Lower employment obligation: for on-the-job training (işbaşı eğitim) programmes commencing by 31 December 2026, at least 50% of participants must be employed for 1.5 times the programme duration, and not fewer than 60 days. The previous requirement was 60% of participants for twice the programme length.
• Vocational training: the same eased obligation applies to İŞKUR vocational courses in manufacturing, with a 120-day floor at 1.5 times the course length.
• Easier reapplication: a manufacturer reapplying no longer has to show an increase in insured employees. It is enough that headcount has not decreased.

Worked example

A furniture manufacturer enrolling ten participants in a 60-day on-the-job training programme must now retain at least five of them for at least 90 days (1.5 times the 60-day programme). The lower threshold gives foreign-owned manufacturers more room to use subsidised training as a recruitment channel while keeping the commitment manageable.

Mandatory mediation before most labour lawsuits

If you expect a dispute, the procedural gate matters as much as the merits. Under the Labour Courts Law No. 7036, applying to a mediator is a precondition (dava şartı) for most labour claims before you can file in court.

Two points foreign employers should plan around:

• Speed: the mediation process is meant to conclude in about three weeks, extendable by roughly one more week. It is a genuine settlement opportunity, not a formality to rush past.
• Exception: claims for material and moral compensation arising from a workplace accident or occupational disease (and the related determination, objection, and recourse cases) fall outside the mandatory-mediation requirement and can go straight to court.

Because failing to mediate first sinks the case on procedure, the mediation step belongs at the top of any litigation timeline. For how the courts themselves operate after mediation, see our overview of how Turkish labour courts work.

Court of Cassation: a missed amendment-fee deadline can overturn the judgment

A Court of Cassation (Yargıtay) line of decisions is a useful reminder that procedural detail can decide an employment case, even one with strong merits. The principle concerns the amendment (ıslah) mechanism under the Code of Civil Procedure No. 6100 (HMK), Articles 176 to 182, which lets a party correct or increase its claim once during proceedings.

The pattern

• Background: an employee who had resigned for just cause sued for unpaid entitlements. The first-instance court granted one week to file an amendment petition but did not deal with the related amendment fee.
• First-instance judgment: the court partly accepted the claim on the originally stated amounts, without taking the amended (increased) amounts into account.
• Court of Cassation: it held that ruling without giving the plaintiff sufficient time to pay the amendment fee was unlawful, and reversed the judgment to protect procedural fairness.

If you are weighing how to frame the amounts you claim, our note on partial and indeterminate-claim lawsuits in Türkiye explains how the choice interacts with later amendment. For pursuing money owed across the litigation and enforcement stages, our enforcement and labour litigation team can help.

A note for foreign employers: work permits and Turkish-national quotas

Beyond the figures above, the most distinctive issue for a foreign-owned employer is the foreign-workforce regime. Work permits for non-Turkish staff are governed by the International Labour Force Law No. 6735, applied together with Labour Law No. 4857. In practice the rules are tightened and adjusted regularly, and they carry their own compliance traps.

• Permit equals authorisation to work: a valid work permit generally also serves as a residence authorisation for the foreign employee for its duration. Employing a foreign national without the correct permit exposes both the worker and the employer to administrative fines.
• Turkish-national ratio: as a general rule, companies must employ a set number of Turkish nationals for each foreign employee they sponsor, and meet a minimum capital or turnover threshold. The exact ratio and exemptions depend on the role and sector, so confirm them before you plan headcount.

Practical compliance checklist for employers

Whether you run a small office or a manufacturing site, the recent changes translate into concrete action points:

1. Confirm your OHS status now. If you are less hazardous with fewer than 50 employees, you must have an OHS arrangement in place since 1 January 2025, either an OSGB/physician package or a trained employer representative registered via İSG-KATİP. Doing nothing risks an administrative fine.
2. Update your payroll figures. Apply the 2026 minimum wage and the current severance ceiling (64,948.77 TL for the first half of 2026), and re-check both at each minimum-wage cycle.
3. Reassess training programmes. Manufacturers should check whether the eased İŞKUR thresholds now make subsidised on-the-job training worthwhile.
4. Plan for mediation first. In most disputes, build mandatory mediation under Law No. 7036 into your timeline before any court filing.
5. Track litigation deadlines. Calendar every procedural fee and amendment deadline under HMK No. 6100.
6. Check foreign-staff compliance. Confirm work permits under Law No. 6735 and any Turkish-national ratio before you hire.
7. Monitor the Official Gazette. Thresholds and figures change at least annually; watch for amendments from the Ministry of Labour and Social Security.

Termination, severance, and just-cause issues remain the most litigated areas in practice. Severance entitlement itself is still governed by Article 14 of the former Labour Law No. 1475, kept in force for this purpose.

Frequently asked questions