LEGAL BASIS AND SCOPE OF THE REGULATION

We have prepared this information note to help you understand your rights and take appropriate steps in relation to a property whose title deed may have been affected by forest cadastre.

Law No. 7584 on the Amendment of the Law on Soil Conservation and Land Use and Certain Other Laws, adopted on 11 June 2026, entered into force after publication in the Official Gazette dated 20 June 2026 and numbered 33286. Article 14 of this Law added Additional Article 22 to Forestry Law No. 6831.

The regulation covers properties that, prior to its effective date, were partially or wholly demarcated as State forest according to a finalised forest cadastre. Additional Article 22 may apply where the land registry record remains in the name of you or another natural or legal person, or where the property has been registered in the name of the Treasury following a title cancellation process: it introduces the possibility that the title record may be deemed valid or that the property may be returned.

Additional Article 22 is not a general return provision applicable to every forest-related dispute. The current status of the property in the land registry, whether there is a court decision concerning it, whether that decision has been entered in the register, and whether the property falls within one of the statutory exclusions must each be assessed separately. The benefit of the regulation does not arise automatically; it is subject to the statutory conditions being met and to the completion of the administrative examination.

APPLICATION OF THE REGULATION ACCORDING TO THE CURRENT STATUS OF THE PROPERTY

1. Properties whose land registry record remains in the name of a natural or legal person

If the property is not registered in the name of the Treasury and the title has been created under land registry, cadastre or zoning legislation and remains registered in the name of you or another natural or legal person, an application may be made to the administration. If you are a party to a lawsuit brought against the cadastre determination, you are also entitled to apply. If the General Directorate of Forestry finds the application appropriate and, following its examination, determines that the title record is correct, the existing title record will be deemed valid without charge and any forest annotation in the land registry will be removed.

2. Properties where a title cancellation judgment is final but has not yet been implemented in the land registry

Where a judgment cancelling your title has been rendered and has become final but has not yet been implemented in the land registry, an action may still be taken under Additional Article 22. In that case, the scope of the final court judgment, the current status of the registry and the other statutory conditions will be assessed together. The procedure for application and examination will be clarified by the procedures and principles to be determined by the General Directorate of Forestry.

3. Properties registered in the name of the Treasury

If the property has been registered in the name of the Treasury as a result of a final title cancellation judgment being entered in the register or as a result of voluntary relinquishment, you, as the former owner, or your legal successors (heirs or transferees) are entitled to apply. An application must be made to the administration within two years from 20 June 2026. The return does not occur automatically; the administration will assess whether the property falls within the scope of the article and whether the statutory conditions are satisfied.

EFFECT OF THE REGULATION ON PENDING PROCEEDINGS

Until the procedures under Additional Article 22 are concluded, the forest administration or the Treasury will not initiate a new action. If you have an ongoing lawsuit, it will not be stayed; however, it will be treated as a preliminary issue until the administrative process under the article is concluded. In other words, the court will await the administration's decision and assess the case accordingly. The entry into force of the Law does not, by itself, terminate your lawsuit.

If you withdraw from the lawsuit, pending cases—including actions for title cancellation and registration, removal of forest annotations, and compensation actions filed due to cancellation of title deeds for these properties—will be decided as having become moot. In this event, litigation costs will be borne by you and no attorney's fee will be awarded in your favour. If you do not withdraw, the case will continue by taking account of the outcome of the administrative process.

The Law suspends the time limits that result in loss of the right to bring actions concerning ownership of these properties during this process. However, this is separate from the two-year administrative application period applicable to properties transferred to the Treasury, which should be carefully monitored.

PROPERTIES THAT WILL NOT BE ASSESSED UNDER THE REGULATION

The Law excludes certain properties; these cases are listed in a limited and technical manner. The basis on which your property was acquired, its use status and its cadastre history should also be examined from this perspective. The principal exclusions include:

• Places on which buildings or facilities have been constructed for the protection, production or improvement of forests.

• Places registered under Law No. 3573; places registered under repealed Law No. 4753 for which transfer conditions have not been met; places nationalised for consideration under Law No. 4785; places distributed under repealed Laws No. 3116 and 5653 but not registered; formerly recorded properties that have not been processed in title, cadastre or zoning works; and properties covered by the Pasture Law No. 4342.

• Places within culture and tourism protection and development regions, tourism centres, tourism regions and tourism areas; places covered by the Bosphorus Law and exchange agreements; forests with special status and places subsequently brought under the forest regime.

• Properties formed by subdivision due to permits or establishment of easement rights; properties within burnt forest areas; and properties whose boundaries or location on the land cannot be determined.

The fact that a property has subsequently undergone a zoning implementation does not, on its own, mean that it is excluded; that circumstance must be assessed together with its other characteristics.

CONSEQUENCES OF RETURN OR OF A LAND REGISTRY RECORD BEING DEEMED VALID

If there are existing forest permits or leases on a property covered by Additional Article 22, they will be deemed cancelled. If the property is returned to you, you may not claim compensation or ecrimisil (unjust use compensation) from the administrations for past periods. It is therefore in your interest to assess any ongoing lawsuits and other claims you may consider pursuing before benefiting from the return option.

Once procedures under Additional Article 22 are completed, forest cadastre records will be updated in accordance with the new status. The Law also provides for the allocation to the General Directorate of Forestry, for afforestation or forest use, of other properties under State control or private ownership of the Treasury in an area not less than the total area of properties whose title record is deemed valid, which are returned to you, or which will be assessed by the General Directorate of National Property. The competent court for disputes arising from implementation of Additional Article 22 is the Civil Court of First Instance located where the property is situated.

CURRENT STATUS OF THE APPLICATION PROCESS AND IMPLEMENTING PROCEDURES

Under the final paragraph of Additional Article 22, the procedures and principles for implementation will be determined by the General Directorate of Forestry after obtaining the opinion of the Ministry of Environment, Urbanization and Climate Change. As of the date this information note was prepared, those procedures and principles have not yet been published. Accordingly, there is currently no definitive information on the authority to which an application will be made, the form of application, documents to be requested, how the administrative examination will be conducted, or the sequence of land registry procedures.

At this stage, we cannot offer a definitive application roadmap; however, this uncertainty does not mean that you have lost your right. During this period, we recommend determining the legal category into which your property falls and preparing documents concerning its title and litigation history; we are also closely monitoring the publication of the implementing procedures and principles on your behalf. Since a two-year period applies to properties registered in the name of the Treasury, it is important to assess your application without delay once the procedures and principles are published.

REVIEW REQUIRED FOR THE SPECIFIC PROPERTY

For your property, you should first examine the current land registry records showing chain of title and encumbrances; the original establishment and acquisition documents; the forest cadastre record and map; and, where applicable, your court file, final court judgment and documents showing entry of that judgment in the land registry.

You should also obtain the coordinated survey plan, cadastral sheet, technical documents showing the overlap with the forest boundary, zoning and special-status information, and, if you are not the former owner, documents showing your legal succession. This review is important to determine which group under Additional Article 22 applies to the property and whether it falls into one of the excluded cases.

CONCLUSION AND LEGAL ASSESSMENT

Additional Article 22 introduces an important possibility for the protection of title and return of property for properties whose title rights have been affected by forest cadastre. Nevertheless, the regulation does not apply to every forest dispute and does not automatically produce a result for any property. The title and litigation status of the property must also be examined in terms of the exclusions listed in the Law.

The manner in which the application will be implemented in practice depends on the procedures and principles to be determined by the General Directorate of Forestry. At the current stage, we recommend preparing records concerning your property and clarifying your legal position; the application method and order of procedures should be reassessed specifically for your property once the procedures and principles are published. This information note has been prepared for general legal information purposes and will be updated when the implementation procedures are clarified. We are available to answer your questions at every stage of the process.