Licensing an apart hotel in Türkiye: the building, the certificate and the flat owners

An apart hotel in Türkiye is a licensed tourism facility type, not a rented flat. Article 25 of Presidential Decision 1134 requires at least ten apart rooms, a reception lobby and a management office; the operator then needs a municipal workplace license with a building occupancy permit and fire brigade report, plus the consents the building's ownership structure requires.

You have found the building, the flats are already divided, and the numbers work at ten keys. The question that decides the project is not the view from the roof; it is what the title deed and the occupancy permit say the building is for, and who else has a say in it. This article walks through the apart hotel rules in the tourism regulation, the workplace license file, the residential-use problem and the flat owners, so you can read your own documents and know what to ask before you commit.

What counts as an apart hotel under the Turkish rules?#

An apart hotel is a tourism accommodation type defined by regulation, not a marketing label for flats rented by the night. The definition sets a room count, a room layout and two shared spaces, and a project that misses any of them is not an apart hotel on paper.

Article 25 of the Regulation on the Qualifications of Tourism Facilities (Presidential Decision 1134, Resmî Gazete 1 June 2019, No. 30791, consolidated text on mevzuat.gov.tr (opens in a new tab), amended through 31 August 2026) sets four conditions together: the Regulation's minimum qualities for tourism and accommodation facilities, equipment so guests can meet their own food and drink needs, operation as a hotel, and at least ten rooms all arranged as apart rooms. Miss one and the type does not apply, whatever the booking channel calls the property.

An apart room is a suite whose sitting area is given a kitchen with a dining table and chairs, a hob, a hood, a refrigerator, enough cooking and serving equipment and cupboards for them, or a suite with a separate kitchen (Article 18). A room with a kettle and a minibar is not an apart room, so check the kitchen specification against Article 18 before counting keys.

The facility needs a lobby with a reception and waiting area, part of which may be open-air in summer facilities, and a management office. These are the two spaces that make the type a hotel rather than a block of flats. Apart rooms must have uniform furnishings, and an automatic washing machine is required where no laundry and ironing service is offered. The choice between offering the service and installing the machines is a cost decision that follows directly from the text.

Some reliefs apply. Apart hotels with fewer than 30 rooms need no telephone in the rooms, apart hotels need not provide separate women's and men's toilets for public areas, and they need not provide a staff area. A guest lift is needed where guests must go up or down more than three floors.

Two structural rules close the analysis. Apart hotels cannot receive a tourism investment certificate (Article 6(2)), which closes one route early and makes the operation certificate the tourism track for this type. And where apart rooms are operated inside another accommodation facility, their beds may not exceed 25% of that facility's total beds, or 40% in four- and five-star hotels (Article 13(9)). This is the rule that decides mixed projects.

Does an apart hotel have to be a whole building?#

No. The regulation defines a facility, not a building, so a set of apart rooms with the required lobby and office can sit inside a larger building, provided the permits and the ownership structure allow it.

What makes part of a building workable is separability: its own entrance or dedicated lift access, a place for the reception and the management office, and a clear line between the facility and everything else in the building. Where the apart rooms sit inside another accommodation facility, the bed cap in Article 13(9) applies: 25% of the facility's total beds, or 40% in four- and five-star hotels. Run the arithmetic before the design, not after.

The workplace license is issued for a workplace at an address, and each outlet and floor has to match the file. A facility spread over floors that also contain private flats needs a clear answer for every floor. A whole building with one owner gives one consent question and one permit file; part of a building multiplies both, and the multiplication is where schedules slip.

The answer for a specific building belongs to the municipality and the provincial directorate of the Ministry of Culture and Tourism. A pre-application conversation is cheaper than a redesign. Bring three documents to that conversation: the title deed, the building occupancy permit and the management plan. Without them the meeting cannot answer anything.

Residential or commercial: what do the title deed and occupancy permit say?#

They decide whether the project is a paperwork exercise or a change-of-use case. The occupancy permit records what the building was allowed to be, and the license file is built on that document.

Article 5 of the Regulation on Workplace Opening and Operating Licences treats hotels as buildings that need a special structure type, and such buildings need a building occupancy permit (yapı kullanma izin belgesi). Since the amendment in force 11 December 2025 (Official Gazette No. 33104), Annex 1 of the same regulation requires lodging places to hold both a building occupancy permit and a fire brigade report, according to the consolidated regulation text on mevzuat.gov.tr (opens in a new tab). Both documents, not one.

A unit built and registered as a residence and then used for paid nightly stays is being used differently from what the permit describes. What that requires is the municipality's call, and it is the first question to ask, not the last. Zoning status matters in the same way: the plan notes for the plot say whether tourism, commercial or residential use is allowed, and a tourism facility normally sits where the plan allows it.

Check the documents yourself before you commit. Read the use column on the title deed and the use stated on the occupancy permit, not the description in the listing. The fire brigade report is a separate process with its own checklist, and it is easier to pass when the building was designed for it. For that process, start with our guide to fire safety rules for hotels in Türkiye.

Do you need the flat owners' consent?#

Sometimes, and the answer comes from the unit's registered use and the building's management plan rather than from a general rule about hotels. The workplace license form asks for condominium owners' consent where it applies, and the authority decides whether it applies.

Article 24 of the Condominium Law (Law No. 634) (opens in a new tab) lets a unit recorded in the condominium register as a residence house entertainment and meeting places such as cinemas, theatres, coffee houses, bars and clubs, food places such as bakeries, restaurants and patisseries, and places such as workshops, shops, galleries and arcades, only by a unanimous decision of the condominium owners' board. Lodging is not named in that list. The same article bans hospitals, dispensaries, clinics, polyclinics and pharmaceutical laboratories in units recorded as residence, workplace or commercial premises, and says agreements between owners to the contrary are void. Lodging is not in that ban either.

At the request of the manager or any owner, the board's decision is annotated on the register pages of all independent units. That annotation is what a later buyer or a bank will read. Article 18 obliges owners to follow the management plan and the good-faith rules of condominium life, in particular not to disturb one another and to respect each other's rights. These duties also bind tenants and anyone else who uses a unit permanently.

The workplace license application form (Örnek 1) lists the condominium owners' consent among the attachments where it applies, next to the fire brigade report and the distance sketch. Read the management plan before you sign anything. A plan that restricts commercial use or short letting is the obstacle that no license application can remove. For the wider sequence of permits, see which permits come in which order when opening a hotel.

Which license and certificate do you file?#

Two separate tracks. The workplace opening and operating license comes from the local authority and is the baseline duty for any workplace; the Ministry's tourism operation certificate is a separate track, issued by the Ministry of Culture and Tourism. Confirm your facility's own position with the Ministry's provincial directorate.

Article 6 of the Regulation on Workplace Opening and Operating Licences is blunt: no workplace may open or operate without a workplace opening and operating licence from the competent authority, and permits or registrations from other public bodies do not remove that duty. The municipality grants the license inside municipal and adjacent-area boundaries; the special provincial administration grants it outside them (Article 32).

The applicant files the application and declaration form (Örnek 1). The authority first asks the police or gendarmerie for their view on public security, which arrives through the district or provincial governor within seven days, and the application must be concluded within one month. Under Additional Article 1 the authority checks identity, tax and trade registry details itself and may not ask the applicant for documents proving them; the one exception is an applicant whose trade registry records were published before 1 October 2003, who is asked for the trade registry gazette. Under Article 45/A, if no license has been issued two months after an application made in line with the regulation, the provincial directorate of the Ministry of Environment, Urbanisation and Climate Change may issue it on its own authority, for a fee.

The tourism track is the operation certificate from the Ministry of Culture and Tourism. Apart hotels cannot receive an investment certificate, and smaller places may fit the simple accommodation certificate instead. For scale: 454 facilities held an operation certificate as an apart hotel at 31 December 2025 (Source: Ministry of Culture and Tourism, annual accommodation bulletin 2025). Public data. No endorsement implied. For the mechanics of the municipal permit, read our guide to the hotel workplace licence; for the Ministry's track, how a hotel applies for a tourism operation certificate.

What changes once you sell nights instead of leases?#

The building becomes a lodging business, and every stay then carries four duties: a payment, a fiscal document, a guest identity notification and personal data. The workplace license is the entry ticket, not the operating system.

In Türkiye every stay involves a payment, a fiscal document (an invoice or e-document), a guest identity notification (KBS, misafir kimlik bildirimi) and personal data (KVKK, kişisel verilerin korunması kanunu). None of these appears in the license file, and all of them start with the first guest. Who receives KBS notifications and what technical setup is required is set by the authority, so confirm your own case rather than copying another property.

Fiscal documents: e-Fatura and e-Arşiv are issued through a licensed integrator, and whether they are mandatory for you depends on your taxpayer scope. Ask your accountant to confirm your position in writing. A stay also carries tax duties; confirm your own position with your accountant in writing, and our article on accommodation tax in Türkiye is further reading.

Personal data duties begin with the first guest record: what you collect, why, how long you keep it and how you export it are design decisions, and retrofitting them is expensive. Contracts with a management company or a letting operator should say in one place who files KBS, who issues the invoice and who remits the accommodation tax. Ambiguity here is discovered at an inspection.

What to do next#

Take the title deed, the building occupancy permit and the management plan to the municipality and the provincial directorate before you commit to the building, and ask in writing whether the use you intend is the use the permit describes. Everything else in this article follows from that answer: the room count and layout come from the regulation, the consent question comes from the building's ownership, and the four duties of every stay come after the doors open.