Major Changes to Turkey’s Medical Tourism Sector: 2025 Regulatory Update
I. Introduction – Why 2025 Changes Matter
Turkey remains a popular destination for patients who travel to combine medical treatment with a visit abroad. The legal framework that governs this activity changed on 26 April 2025, when the Ministry of Health published the new Regulation on International Medical Tourism and Tourist Health in the Official Gazette (No. 32882). This 2025 Regulation replaces the previous 2017 version, establishing new procedural and technical requirements for both healthcare facilities and medical tourism intermediary agencies (companies that organize treatment for foreign patients).
Under these new rules, every intermediary agency must now hold an International Medical-Tourism Authorization Certificate issued by USHAS – International Health Services Inc. A separate Group A Travel-Agency License from TURSAB is still required, but only if the company also offers traditional tourist services like hotel bookings or ground transportation. Agencies that focus solely on arranging medical care are exempt from this additional license.
The Regulation also introduces ongoing duties. Licensed agencies are expected to (i) operate a 24‑hour call center that can answer in English and at least one other language, (ii) register on the HealthTürkiye digital portal, and (iii) undergo an annual performance review by USHAS.
II. Corporate Structure for a Medical Tourism Agency in Turkey
2.1 Corporate Forms & Minimum Capital
In practice, two main capital company structures are commonly used in the medical tourism sector:
- Limited Liability Company (Limited Şirket), with a statutory minimum capital of TRY 50,000.
- Joint-Stock Company (Anonim Şirket), with a statutory minimum capital of TRY 250,000.
Both structures are acceptable for obtaining a medical tourism authorization, provided their articles of association explicitly state international medical tourism intermediation as a business purpose.
2.2 Incorporation Process – Further Information
The standard incorporation steps, such as drafting and notarizing articles, registry filing, and tax number allocation, follow the general procedures outlined in the Turkish Commercial Code. For a comprehensive, step-by-step guide, including detailed timelines, documentation lists, and cost breakdowns, you can refer to “Company Formation in Turkey – 2025” (accessible at www.asylegal.com/company-formation-in-turkey-2025). This resource can be consulted before addressing the sector-specific licensing requirements detailed below.
III. Licensing and Regulatory Compliance under the 2025 Framework
The April 2025 Regulation replaced the 2017 text in its entirety. While the basic obligation to hold a sector authorization remains, the issuing authority, ancillary licensing rules and continuing‑compliance thresholds have all been revised. The licensing requirements for different types of agency services can be summarized below:
| Scope of Activity | Medical Tourism Authorization Certificate | Group A Agency Certificate |
|---|---|---|
| A. Medical‑tourism intermediation only | Required | Not required |
| B. Medical‑tourism intermediation + direct tourist services | Required | Required |
3.1 International Medical Tourism Authorization Certificate: Changes from 2017 to 2025
The table below highlights the key differences between the 2017 and 2025 Regulations concerning medical tourism authorization:
| Issue | 2017 Regulation | 2025 Regulation |
|---|---|---|
| Issuing body | Provincial Directorates of the Ministry of Health | USHAS |
| Application medium | Paper dossier submitted locally | Digital filing via USHAS portal |
| Physician‑experience threshold | Minimum five years’ practice (two in a licensed facility) | Threshold removed |
| Call‑centre language standard | 24 / 7 service in two foreign languages | Unchanged: two foreign languages |
| Digital reporting & KPI audit | No portal; no formal audit cycle | Mandatory HealthTürkiye portal membership and annual USHAS audit |
3.2 Group A Travel‑Agency License (TURSAB)
a. License Requirement
Before April 2025, all medical tourism intermediaries were required to hold a travel-agency business certificate. The current Regulation limits this requirement to cases where the intermediary directly provides or sells traditional tourism services (e.g., hotel accommodation, ground transfers, leisure excursions) to the patient or accompanying persons. If the intermediary’s activity is limited to arranging medical treatment, a travel-agency license is no longer necessary.
It is important to note that on May 23, 2025, TURSAB announced that they initiated annulment proceedings before the Council of State (file no. 2025/2450). This lawsuit seeks to invalidate the provisions that removed the universal travel-agency obligation for health tourism intermediaries. Depending on the outcome of this legal challenge, TURSAB license requirements may change in the future.
b. Application Outline and Statutory Tariff (2025)
The TURSAB application procedure remains unchanged, requiring the following steps for a successful application:
- Agency name reservation with the Ministry.
- Submission to TURSAB, containing corporate documentation, authorized‑signatory list, proof of suitable premises and evidence of payment of the entry fee.
The 2025 tariff sets a one-off entry fee of TRY 517,395 and an annual membership fee of TRY 25,869.76, which is indexed annually to the revaluation rate under Article 298 of the Tax Procedure Law.
3.3 Common Post‑Licensing Obligations
Regardless of whether a travel-agency license is held, all authorized intermediaries in medical tourism must comply with the operational standards imposed by the 2025 Regulation. These include: continuous bilingual call-center capability, active participation in the HealthTürkiye portal, maintenance of adequate staffing and technological infrastructure, and full cooperation with USHAS during annual audits
Existing intermediaries are required to achieve compliance by 26 October 2025; newly established entities must demonstrate conformity from the date of first licensing.
IV. Staffing & Service‑Infrastructure Standards
The 2025 Regulation maintains the core operational duties from the 2017 framework—most notably the obligation to maintain a round-the-clock call center capable of assisting medical tourism patients in at least two foreign languages, including English. However, these duties are now subject to continuous, data-verified oversight through the HealthTürkiye portal. While the previous rule required four language-certified employees, the current minimum is now three.
4.1 Twenty‑Four‑Hour Call Center and Multilingual Personnel
A licensed intermediary must operate (or contract for) a call center that is accessible 24 hours a day, seven days a week, in a minimum of two foreign languages. Whether the function is kept in‑house or outsourced, the provider’s location, telephony infrastructure, and service agreement must be filed with USHAŞ at the licensing stage and kept up to date thereafter. Inspectors typically verify that calls route to trained, named staff, that logging software captures time, caller identity, and resolution status, and that continuity plans protect against hardware or connectivity failures.
Staffing rules have been refined rather than relaxed. The head‑count threshold is reduced to three language‑certified employees, one of whom must demonstrate English proficiency, but each individual must provide objective proof—a qualifying YDS score or its international equivalent, a CEFR B2‑level certificate, or an accredited degree in translation or linguistics. To curb nominal staffing, any key employee may be listed on no more than two separate intermediary licenses, a limitation enforced automatically through the HealthTürkiye database.
4.2 HealthTürkiye Portal – Mandatory Compliance Interface
The HealthTürkiye portal has been transformed from an optional promotional tool into the central compliance interface. Each intermediary must establish a profile, upload corporate and staffing data, and begin recording every patient episode in the portal. Because personal health information is processed, intermediaries must structure data‑flows in line with the Personal Data Protection Law and recognized information‑security standards.
V. Enforcement and Sanctions
Since enforcement triggers are directly linked to HealthTürkiye data and on-site audit findings, deficiencies in call-center uptime, staff certification, or portal reporting are quickly identified and automatically escalated. Therefore, maintaining accurate records, synchronizing case-management software with the portal, and conducting quarterly internal compliance checks are essential risk-mitigation measures for prospective medical tourism investors.
VI. Conclusion – Strategic Considerations for 2025 and Beyond
Turkey’s 2025 overhaul of medical tourism regulation preserves the sector’s established strengths—cost efficiency and high clinical quality—while introducing a significantly stricter compliance regime. A centralized licensing process under USHAS, mandatory digital reporting through the HealthTürkiye portal, and formal KPI audits collectively make operational shortcomings visible in real-time and subject to swift sanctions.
The selective reinstatement of the TURSAB Group A license underscores the legislature’s intention to distinguish medical facilitation from traditional tourist-service sales. Entities that limit their role to arranging medical treatment retain a single-license structure. Those wishing to package accommodation, transfers, or excursions must accept a second layer of oversight and associated fees. Given the pending annulment action brought by TURSAB, this conditional rule remains subject to judicial revision, and investors should closely monitor the legal developments.
In summary, the 2025 framework rewards entities that embed compliance into daily workflows and penalizes those that rely on episodic, paper‑based checks. Investors prepared to make early, targeted investments in multilingual human resources, secure data pipelines, and integrated call‑center technology will find Turkey’s health‑tourism market both accessible and scalable.
