Groundbreaking Shift in Project-Based State Aid: Investment Thresholds and Digital Invitation Mechanism

Turkey is overhauling its investment incentive framework with a sweeping revision to project‑based state aid.

Core Elements of the New Regulation

■Article 4’s heading has been updated to "application period and required documents".

■The ministry now may invite one or multiple firms via formal letters.

■Announcements can be made through the official website and digital platforms, with the invitation letter allowed to set bespoke conditions.

Digital‑Era Invitation Process

■Digital platforms enable real‑time calls for proposals, giving investors immediate access.

■Applicants must submit a feasibility report and petition prepared by development and investment banks.

■Projects under the Technology Move Program are exempt from this procedural requirement.

Investment Thresholds and Support Conditions

■For projects targeting products on the priority list and approved under the Technology Move Program, the minimum fixed investment is TRY 100 million.

■All other projects must meet a minimum fixed investment or R&D spend of TRY 2 billion.

■Investors will submit an annual activity report for 5 years, detailing the support amounts received.

■Except for force‑majeure cases, within 3 years of the decision’s effective date, investors must prove spending of TRY 200 million or 10 % of the investment amount.

■Energy support available before the completion visa cannot exceed 50 % of the maximum allocated amount.

■For projects with a fixed investment of TRY 5 billion and classified as entirely new investments, the ministry may sign full‑ownership contracts with the investors.

Implementation Timeline and Monitoring

■After receiving a completion visa, investors will file a yearly report for 5 years.

■Partial operational start must be verified on‑site by at least two independent experts.

■Energy subsidies and employer‑share insurance premiums will be activated post‑completion visa.

■KOSGEB and TÜBİTAK can provide direct support to projects covered by the Technology Move Program.

Markets are likely to see this framework boost liquidity flows, especially in high‑capital technology and energy projects, prompting HFT algorithms to monitor state‑backed liquidity injections and adjust positions accordingly. The TRY 2 billion R&D threshold could spur long‑term sovereign bond issuance, while the transparency of digital invitations should enhance investor confidence and dampen short‑term volatility in related sector equities.