Why is health insurance required for a residence permit?
Almost every foreigner applying for or extending a residence permit in Antalya adds a health insurance policy to the file. The requirement is not an administrative habit; it rests on Law no. 6458 on Foreigners and International Protection and its implementing regulation.
The Law expressly requires the sponsor of a family residence permit to hold health insurance covering all family members (art. 35/1-b) and requires valid health insurance for a long-term residence permit (art. 43/1-ç). For visas, applicants without valid health insurance covering the period of stay are refused (art. 15/1-e).
Article 22/13 of the Implementing Regulation turns this into a general condition for every type of residence permit: the applicant must hold valid health insurance covering the period of residence requested. Persons covered by the public general health insurance scheme are deemed to satisfy the condition. Under article 22/14, applicants outside the public scheme who request one year or more must present a one-year private policy, to be renewed at the end of each year.
The products sold as "foreigner health insurance" or "residence permit insurance" are private health insurance policies designed to meet this condition. For the permit types and the application steps see our article on residence permit types, and for our work in this field the foreigners' law page.
Minimum policy content: Circular 2016/16
For a policy to be accepted in a residence permit application it must carry the minimum cover structure set out in the Circular on Health Insurance Required for Visa and Residence Permit Applications (2016/16) of the Insurance and Private Pension Regulation and Supervision Authority (SEDDK). The minimum limits were last updated by amending Circular 2024/34 and have applied since 1 April 2025.
Under the current structure the annual minimum limit for outpatient treatment is 15,000 TL, with a 20 per cent co-payment at contracted providers and 40 per cent at non-contracted providers. Inpatient treatment is unlimited with no co-payment at contracted providers; at non-contracted providers the limit is 150,000 TL with a 20 per cent co-payment, and at the public hospitals listed in the annex to the circular the limit is 250,000 TL with no co-payment. Treatment of sudden illnesses and conditions may not be excluded from cover.
Article 2 of the circular requires the policy to carry a statement, in Turkish, confirming that it covers the minimum cover structure set by Circular 16 of 10 May 2016 on health insurance required for visa and residence permit applications. Without that statement a policy may cause problems in the application even if its limits are adequate.
Three further rules matter. The policy must be issued by an insurer licensed in the relevant branch in Turkey; for applications made from abroad, a foreign insurer's policy is accepted provided it delivers the minimum cover in Turkey (art. 4). Policies are issued online in real time and can be verified by the Migration Authority through the Insurance Information and Monitoring Centre (arts. 10-12). Since Circular 2024/34 premiums are paid up front.
What changed on 1 January 2026?
The minimum structure did not change. What changed is the general framework the policy is subject to. SEDDK rewrote the Private Health Insurance Regulation comprehensively; the amendment was published in the Official Gazette of 20 October 2025, issue 33053, and entered into force on 1 January 2026. Implementation Circular 2025/28, in force on the same day, sets out how the rules are to be applied.
The scope article of the Regulation excludes only travel health insurance and sickness insurance. Policies taken out for a residence permit are private health insurance contracts, so the new rules apply to them as well. The one significant exception concerns the lifetime renewal guarantee and is dealt with separately below.
Four headings have practical consequences for foreign policyholders: waiting periods, the preservation of acquired rights on renewal, the transfer of data through the Centre when switching insurer, and information duties.
Waiting periods: at most six months, and only in the first policy
A waiting period is the time that must pass before conditions expressly listed in the policy come within cover. For years residence permit policies carried waiting periods of up to nine months for inpatient treatment, which meant that cover was effectively suspended for a large part of a one-year policy.
Article 6 of the new Regulation and article 7 of Circular 2025/28 now limit this: for all cover other than maternity the waiting period may not exceed six months; for maternity cover the ceiling is twelve months. The periods and the conditions subject to them must be stated expressly in the contract.
More importantly, a waiting period may be applied only in the first insurance period. Where the policy is renewed under the same plan, no waiting period runs in later periods. According to the circular, a waiting period cannot be applied to a policy renewed with the same insurer; only where a plan change adds a new type of cover may a waiting period be set, and then only for that cover.
For a foreigner who extends the residence permit and renews the policy every year, this means full cover from the second year onwards.
Switching insurer no longer restarts the waiting period
Many foreigners in Antalya move to an insurer with a lower premium at renewal. Under the old regime that move carried the risk of waiting periods starting again from zero. New article 9/A of the Regulation introduces the "transfer": the policyholder may ask for acquired rights and obligations to be carried over to another insurer and for the contract to continue there. The transfer takes place on the new insurer's terms and subject to its acceptance.
On waiting periods the rule is clear: the new insurer may not apply a waiting period for cover whose waiting period was completed at the previous insurer; where the period was not completed, the time spent at the previous insurer is deducted from the period the new insurer applies. The circular gives an example: if a policy sets a two-month waiting period for inpatient treatment and the insured moves to another insurer after one month, the new insurer may apply at most one month for the same cover.
The information on which a transfer is based is not exchanged directly between insurers; it is obtained through the Insurance Information and Monitoring Centre. The existing insurer must send the data to the Centre within five business days of receiving the request, and the new insurer may not ask the insured for documents beyond those specified by the Authority.
Lifetime renewal guarantee: residence permit policies are outside the obligation
The most discussed provision of the new Regulation is the duty to offer a contract with a lifetime renewal guarantee to anyone under 60 (art. 7). The guarantee may not be made subject to conditions stricter than three years of uninterrupted insurance under the same plan and a claims-to-premium ratio below 80 per cent over that period.
However, article 8/3 of Circular 2025/28 places health insurance taken out for residence permits, together with travel health insurance for visa applications, emergency health insurance and sickness insurance, outside the scope of this obligation. In other words, for a standard foreigner health insurance policy issued only to satisfy the residence condition, the insurer is not obliged to offer a lifetime-guarantee option.
The exception does not prevent the insured from choosing a broader product. Article 2 of Circular 2016/16 allows contracts of wider scope that include the minimum plan. A foreigner under 60 who plans to settle in Antalya for the long term and takes out a standard private health insurance policy carrying the minimum-cover statement must, under the general rules of the Regulation, also be offered the guaranteed option. Which product was chosen must be stated clearly in the policy and in the information form.
Renewal notice and information duties
Under article 7/9 of the Regulation the insurer must inform the policyholder of the expiry date and the renewal no later than fifteen days before the contract ends, and must notify both the policyholder and the insured, in writing or through a durable medium, whether the contract has been renewed. The circular requires that notice to describe the rights preserved on renewal and lost on non-renewal.
Because the policy term and the residence permit term are linked, this notice is not merely an insurance matter for a foreign policyholder. A gap between the policy's expiry date and the extension application may result in a missing document in the extension file.
On language, article 9 of Circular 2016/16 strikes a balance: the English versions of the documents that must be given to the policyholder are delivered in addition to the Turkish originals, but in a dispute the Turkish text prevails, and this is explained in the information form. An insured who reads only the English summary should check the exclusions against the Turkish text as well.
Cancelling the policy and notice to the Migration Authority
A residence permit policy cannot be cancelled at the insured's request at any time. Under article 3 of Circular 2016/16 the contract may be terminated at the insured's request only in three cases: presentation to the insurer of a new health insurance contract covering the residence permit term, cancellation of the residence permit, or presentation of a document showing that the insured has come within the public general health insurance scheme under Law no. 5510. On termination the premium for the remaining days is refunded pro rata.
Whatever the reason the insurance ends, the insurer notifies the Migration Authority within five business days. That notice means that one of the conditions on which the residence permit rests has fallen away. Non-payment of premium, or cancelling the old policy before a new one is in place, can in practice open the question of cancellation of the residence permit.
The insurer keeps its rights of termination under the Turkish Commercial Code, but if it has accepted payment of the premium in instalments it is deemed to have waived termination for default (art. 8). For the court route where a residence permit is cancelled, not extended or refused, see our article on routes of challenge in foreigners' law.
Points to watch in practice in Antalya
Term: the policy must cover the whole of the residence period requested; for requests of one year or more a one-year policy renewed annually is required. No gap should be left between the expiry date and the extension application.
Statement and limits: the policy must carry the Circular 2016/16 statement and the minimum limits in force since 1 April 2025. A policy that looks cheaper should be checked for issuance under the old limits.
Loss of rights on renewal: from 1 January 2026 a policy renewed under the same plan may not carry a new waiting period, and completed periods are preserved when switching insurer. A renewal offer that reintroduces a waiting period is contrary to the Regulation and can be challenged.
Public health insurance: foreigners insured through a work permit, or otherwise within the public scheme, are not asked for a separate private policy; an existing policy may then be terminated on presentation of the document, with the remaining premium refunded.
Disputes: disputes over refused cover, waiting periods or cancellation begin with a written application to the insurer, followed by the Insurance Arbitration Commission or the consumer court route. The policy, the information form and the Centre's records are assessed together; our office in Kepez follows such files in the manner described on the Kepez lawyer page.
Resources
- Regulation Amending the Private Health Insurance Regulation — Official Gazette of 20 October 2025, issue 33053 (in force 1 January 2026)
- Private Health Insurance Regulation — Official Gazette of 23 October 2013, issue 28800
- SEDDK Circular 2025/28 on the Implementation of the Private Health Insurance Regulation, 10 December 2025 — arts. 6, 7, 8/3, 16
- SEDDK Circular 2016/16 on Health Insurance Required for Visa and Residence Permit Applications, and amending Circular 2024/34 (in force 1 April 2025)
- Law no. 6458 on Foreigners and International Protection, arts. 15/1-e, 35/1-b, 43/1-ç — mevzuat.gov.tr
- Regulation on the Implementation of Law no. 6458, arts. 22/13-14, 40/6 — Official Gazette of 17 March 2016, issue 29656
You can access the current versions of legal texts via mevzuat.gov.tr.