In short: Airlines and civil aviation in Türkiye are governed by Turkish Civil Aviation Act No. 2920, SHGM regulations, international aviation treaties and bilateral air service agreements. The operating model also determines whether an airline needs an AOC, traffic rights, flight permits, aircraft registration, slots, ground-handling arrangements and passenger or cargo compliance.
Why it matters: An aviation project is a connected regulatory chain. A problem with ownership and control, aircraft leasing, airworthiness, permits, slots or operational contracts can delay an airline’s launch, restrict its routes or affect fleet finance.
Our Legal Services for Airlines and Aviation Businesses in Türkiye
Turkish Trade Lawyers advises airlines, aircraft operators, lessors, financiers, airports, ground handlers, cargo businesses and aviation investors.
AOC and airline licensing
SHGM applications, licensing roadmaps, operational documentation, management and continuing compliance.
Foreign airline operations
Traffic rights, designation, flight permits, slots and Turkish safety and security requirements.
Foreign investment
Turkish aviation company formation, acquisitions, shareholding, control and governance review.
Aircraft registration and leasing
Purchase, lease, import, registration, deregistration, redelivery and repossession planning.
Aviation finance
Security documents, Cape Town Convention, Aircraft Protocol, IDERA and lender or lessor protection.
Airport and ground handling
Slot, airport, handling, maintenance, fuel, catering and other aviation service agreements.
Passenger and cargo claims
SHY-YOLCU, Montreal Convention, baggage, cargo, dangerous goods and insurance coordination.
Accidents, proceedings and recovery
Regulatory response, administrative proceedings, litigation, arbitration, enforcement and debt collection.
Who Regulates Airlines and Civil Aviation in Türkiye?
The civil aviation framework is administered through several institutions. The Directorate General of Civil Aviation (SHGM) is the primary regulator for airline licensing, AOCs, safety, security, aircraft registration, permits and many operational approvals. DHMİ operates airports and is relevant to airport services and slot coordination. The Transport Safety Investigation Center investigates accidents and serious incidents; its technical investigation is distinct from civil liability, criminal investigations and commercial claims.
SHGM
Air operator certificates, airline licensing, aircraft registration, flight permissions, safety, security, airworthiness and sector-specific approvals.
DHMİ
Airport operations, airport services and coordination of airport slots at congested airports through the Airport Slot Coordination Center.
Transport Safety Investigation Center
Independent investigation of accidents and serious incidents under the applicable Turkish and ICAO framework, without deciding private liability.
The Main Aviation Law in Türkiye: Turkish Civil Aviation Act No. 2920
Turkish Civil Aviation Act No. 2920 is the core statute for civil aviation activities in Türkiye. It sits alongside secondary SHGM legislation, international conventions and bilateral or multilateral air service agreements. The correct legal analysis depends on whether the client is an airline, aircraft owner, lessor, airport service provider, ground handler, cargo operator, maintenance organization or passenger.
Before starting a new aviation operation, counsel should identify the activity, aircraft, route, ownership, operating certificate, permit, airport and contracting chain. A general company incorporation is not, by itself, authorization to carry out regulated air transport.
Air Operator Certificate and Airline Licensing in Türkiye
Commercial air transport operators generally need an Air Operator Certificate (AOC) and the associated operating authorizations. The SHY-6A framework is central to the licensing analysis. SHGM’s review is both documentary and operational: it examines whether the proposed operator has the organization, management, aircraft, personnel, technical systems, safety management and financial or operational capability required for the intended activity.
A licensing plan commonly includes:
- preliminary application and preliminary authorization;
- corporate, ownership, management and business-plan documents;
- aircraft and fleet information, ownership or lease documents and insurance;
- operations manuals, safety management and security arrangements;
- technical, maintenance and continuing-airworthiness coordination;
- SHGM operational review, inspections and corrective actions; and
- final licensing and continuing compliance after the AOC is issued.
An AOC is not a one-time commercial milestone. Changes to fleet, ownership, management, routes, operational control or technical arrangements may trigger notifications, approvals or a fresh compliance review.
Can a Foreign Investor Establish an Airline in Türkiye?
A foreign investor may invest in a Turkish aviation company, but the intended structure must be tested against the ownership, control, headquarters, management and operational requirements applicable to an AOC holder. For an airline seeking Turkish operating rights, the analysis may include Turkish citizenship and control conditions, the location of the principal place of business, board and voting rights, effective control, fleet and operational management.
The shareholding structure should be reviewed before incorporation, acquisition or a shareholder agreement is signed. An arrangement that is acceptable for an ordinary Turkish company may not satisfy aviation licensing requirements if it gives a foreign party prohibited control or leaves the operator unable to demonstrate the required Turkish connection.
Foreign Airlines Operating Flights to Türkiye
Foreign airlines must coordinate several separate questions: whether the airline has traffic rights, whether it is designated under an applicable agreement, whether the planned service requires a flight permit, whether the airport has available slots and whether the aircraft and operation satisfy Turkish safety and security requirements.
Scheduled, charter, cargo, positioning, ferry, business and special operations can be subject to different application documents and timelines. A foreign carrier should confirm the regulatory route before selling tickets, scheduling a series or committing to airport and handling capacity.
Bilateral Air Service Agreements and Traffic Rights
International routes are shaped by bilateral or multilateral air service agreements. These agreements may determine designated airlines, permitted routes, frequencies, capacity, aircraft types, code-share rights, cargo rights and the conditions for operating into or across Türkiye. A commercial plan should therefore be checked against both the agreement and the administrative designation or permit process.
Flight Permits in Türkiye
Flight permits are relevant to foreign airlines and to particular operations by Turkish and foreign operators. The application may need to identify the operator, aircraft, route, schedule, purpose, insurance, safety information, airport arrangements and the legal basis for the operation. Late, incomplete or inconsistent information can affect launch dates and commercial commitments.
Permit advice should be coordinated with traffic rights, aircraft registration, slot applications, handling arrangements, customs and the operator’s AOC or equivalent authorization.
Aircraft Registration and Importation in Türkiye
Aircraft registration work may involve reservation of a registration mark, initial registration, ownership or operator changes, deregistration and the supporting title, lease, insurance and airworthiness documents. The transaction should identify who is entitled to register the aircraft and how the registry position interacts with a lease, mortgage or international security interest.
Aircraft importation can require technical conformity documentation for customs and a coordinated review of sale documents, customs clearance, airworthiness, registration, lease or finance security, insurance and delivery conditions. The aircraft should not be treated as an ordinary imported asset; its technical and regulatory status must remain consistent across the entire closing file.
Aircraft Leasing in Türkiye
Aircraft leases may be structured as dry leases or wet leases, with different allocation of operational control, crew, maintenance and insurance. The SHT-KİRALAMA framework and SHGM approval process should be considered together with the lease wording and the operator’s AOC permissions.
Key provisions include delivery and acceptance, aircraft condition, records, maintenance reserves, inspections, insurance, registration, subleasing, redelivery, default, termination, repossession, export and cooperation with SHGM. A lease that works commercially but does not support the required approval or registration position can create serious financing and recovery risk.
Aircraft Finance, Cape Town Convention and IDERA
Aircraft finance may involve mortgages, assignments, security agreements, guarantees, engine or component interests and international registry filings. Türkiye is a party to the Cape Town Convention and Aircraft Protocol; the Convention framework entered into force for Türkiye on 1 December 2011. Lenders and lessors should coordinate Turkish registry steps with international interests and the available remedies.
An IDERA can support deregistration and export remedies where the applicable requirements and filing procedures are satisfied. Legal due diligence should cover authority, registration, priority, consent, notices, default mechanics, insolvency risk and the practical steps needed for repossession or export.
Airworthiness and Continuing Airworthiness
Airworthiness is both a certification issue and an ongoing operational obligation. Airlines and aircraft owners should maintain accurate technical records, comply with airworthiness directives, use approved maintenance organizations, monitor life-limited parts and preserve continuing-airworthiness arrangements throughout the aircraft’s operation and lease term.
Maintenance agreements should allocate responsibility for scheduled and unscheduled work, technical records, inspections, modifications, parts, warranties, service bulletins, delays, return conditions and regulatory reporting. These provisions are especially important in a lease, aircraft sale or fleet acquisition.
Airport Slots and Ground Handling in Türkiye
At congested airports, an airline may need airport slots coordinated through DHMİ’s Airport Slot Coordination Center. The legal and commercial questions can include route and schedule, series of slots, historic rights, new entrant status, use requirements, changes and the consequences of failing to operate the allocated schedule.
Ground handling is regulated under the applicable SHY-22 and SHT-YHT framework. Ground-handling agreements should address service levels, airport authorizations, baggage, ramp and passenger services, cargo, equipment, personnel, subcontractors, safety, security, damage, indemnities, insurance, audits, delay responsibility, incident reporting and termination.
Passenger Rights in Türkiye
Under the SHY-YOLCU passenger-rights framework, airlines may have obligations in cases of denied boarding, cancellation, delay, downgrade or upgrade. Depending on the event, passengers may be entitled to information, assistance, meals, accommodation, reimbursement, rerouting or compensation. Operational teams should align disruption procedures, notices, evidence and complaint handling with the applicable rules.
Passenger claims should be assessed together with the ticket, itinerary, carrier identity, cause of disruption, extraordinary circumstances, assistance offered and any applicable international convention.
Montreal Convention and Airline Liability
The Montreal Convention can apply to international carriage for passenger injury or death, baggage loss or damage and cargo claims. The Convention entered into force for Türkiye on 26 March 2011. Liability analysis must still confirm the Convention’s scope, the place and nature of carriage, applicable limits, notice and limitation rules, and the relationship with Turkish procedural law.
Airline contracts, cargo terms, handling records, baggage reports, passenger communications and insurance notifications should be preserved from the first incident.
Aviation Accidents, Serious Incidents and Liability
After an accident or serious incident, the Transport Safety Investigation Center may conduct a technical investigation under the Turkish and ICAO framework. That investigation is not a substitute for the separate assessment of passenger, crew, third-party, hull, cargo, insurance, criminal, administrative and commercial liability.
A response plan should coordinate the preservation of flight and maintenance records, evidence, crew and passenger communications, insurer notifications, regulatory cooperation, family assistance, media statements and litigation strategy.
Aviation Security Requirements
Aviation safety concerns the technical and operational safety of flight; aviation security concerns protection against unlawful interference. Airlines, airports, cargo agents, known consignors, suppliers and service providers may need security plans, responsible managers, training, audits, access controls and incident reporting. Contracts should clearly allocate security duties and audit rights across the supply chain.
Dangerous Goods and Cargo Operations
Dangerous-goods operations require coordinated rules for classification, documentation, packaging, acceptance, storage, loading, training and reporting. Cargo terms should address lithium batteries and electronic devices, misdeclaration, screening, handling, temperature or other special conditions, subcontracting and liability. The 2026 administrative guidance on lithium batteries and electronic devices should be checked against the current operation and effective date before implementation.
Aviation Environmental and Emissions Compliance
Airlines and aircraft operators should monitor the environmental rules relevant to their operations, including emissions monitoring, reporting and verification requirements under the SHY-16.4 framework and applicable international obligations. Draft consultation materials should not be treated as enacted law; the effective text and date should be confirmed before advising on a new reporting or cost obligation.
Key Contracts for Airlines and Aviation Businesses in Türkiye
Aircraft purchase agreements
Title, delivery condition, inspections, warranties, records, acceptance, defects and closing conditions.
Aircraft lease agreements
Dry or wet lease structure, approvals, maintenance, insurance, redelivery, default and repossession.
Aircraft finance and security
Mortgages, guarantees, assignments, international interests, IDERA and enforcement planning.
Ground handling agreements
Service levels, airport requirements, safety, baggage, cargo, subcontractors, indemnity and audit rights.
Airport and terminal services
Airport access, facilities, passenger services, charges, operational standards and disruption responsibility.
Maintenance agreements
Approved maintenance, records, warranties, service bulletins, parts, delays and return conditions.
Code-share and interline agreements
Traffic rights, consumer disclosures, operational control, liability, revenue and disruption allocation.
GSA, cargo and logistics agreements
Sales authority, territories, cargo acceptance, rates, documents, screening and claims handling.
Catering, fuel and charter agreements
Quality, safety, delivery, specifications, contamination, scheduling, pricing and operational liability.
Common Legal Risks for Airlines and Aviation Businesses
Licensing and ownership
AOC gaps, unsuitable shareholding or control, management changes, licence suspension and foreign airline designation.
Fleet and finance
Registration, lease approvals, airworthiness, maintenance records, security interests, IDERA and repossession.
Airport operations
Slots, ground handling, airport charges, safety, security, cargo, dangerous goods and subcontractor failure.
Claims and compliance
Passenger, baggage, cargo and accident liability, emissions duties, administrative sanctions and unpaid receivables.
Legal review should begin before an airline signs a lease, buys an aircraft, announces a route or commits to a new airport. Early advice can connect regulatory approvals with the commercial documents that make the operation workable.
Why Aviation Legal Due Diligence Matters
Aviation due diligence should test the entire operating model rather than reviewing only a corporate certificate or aircraft title. The route, operator, aircraft, airport, lease, maintenance program, finance documents, handling providers, passenger terms and insurance must work together.
Legal Counsel for Airlines and Aviation Businesses in Türkiye
Whether the matter concerns a new airline, a foreign carrier, an aircraft purchase, a lease, a financing, a route, an airport agreement, a passenger claim or an accident, the legal answer depends on the operation’s exact regulatory and contractual facts.
Frequently Asked Questions About Airlines and Aviation Law in Türkiye
What law regulates airlines and civil aviation in Türkiye?
The principal framework is Turkish Civil Aviation Act No. 2920, together with SHGM regulations, international aviation treaties and bilateral air service agreements. The applicable requirements depend on the operator, aircraft, route, service and transaction.
Who regulates airlines and aviation businesses in Türkiye?
SHGM is the primary civil aviation regulator. DHMİ is relevant to airport operations and slot coordination, while the Transport Safety Investigation Center investigates accidents and serious incidents independently from liability and criminal proceedings.
How does an airline obtain an Air Operator Certificate in Türkiye?
An airline must complete the SHGM licensing process under the applicable SHY-6A framework. This generally includes preliminary application and authorization, document review, operational and technical assessment, aircraft and fleet review, management and safety systems, and final licensing.
Can a foreign investor establish an airline in Türkiye?
A foreign investor may establish a Turkish aviation company, but an AOC holder must satisfy the applicable ownership, control, management, headquarters and operational requirements. The proposed shareholding and control structure should be assessed before incorporation or acquisition.
Do foreign airlines need permits to fly to Türkiye?
Foreign airlines generally require traffic rights, designation where relevant, flight permits, airport slots where applicable, and compliance with Turkish safety and security requirements.
What should an aircraft lease governed by Turkish law address?
The lease should address SHGM approvals, registration, delivery and return, maintenance, insurance, records, security interests, default, termination, repossession, export and the relationship with the Cape Town Convention and Aircraft Protocol.
What passenger rights apply to flights in Türkiye?
Passenger rights may include assistance, reimbursement, rerouting, notification and compensation for denied boarding, cancellation, delay or downgrade under the applicable SHY-YOLCU framework and relevant international convention.
What is the Montreal Convention’s role in airline liability?
The Montreal Convention can govern international airline liability for passenger injury or death, baggage loss or damage and cargo claims, subject to its scope and limits. Turkish law and the flight’s international character must be assessed for each claim.
Why is aviation legal due diligence important?
Aviation projects depend on a connected chain of authorizations, traffic rights, permits, registration, leasing, airworthiness, slots, ground handling and passenger or cargo liability. A gap in one workstream can affect the airline’s ability to operate or finance its fleet.
