In short: Aviation and aerospace businesses in Turkey face a lifecycle framework covering SHGM approvals, aircraft and component certification, SHT-21 design and production requirements, MRO and continuing airworthiness, UAS operations, customs, security, technology, space and commercial contracts.
Why it matters: The correct legal route depends on the aircraft or product, certification basis, design and production role, maintenance scope, operator model, Turkish registration or import route and intended use. A manufacturing or supply contract cannot replace a required aviation approval.
Our Aviation & Aerospace Legal Services in Turkey
Turkish Trade Lawyers advises foreign aviation and aerospace manufacturers, aircraft and component suppliers, MRO businesses, technology companies, investors, drone companies, space businesses and other aviation operators on Turkish regulatory and commercial law.
SHGM approvals and certification
Regulatory advice, applications, aircraft, product, part and appliance certification, SHT-21, type certificates and supplemental type certificates.
Design and production organisations
DOA/TOO, POA/ÜOO, quality systems, conformity, subcontracting, critical parts, manufacturing and certification responsibility.
Parts, suppliers and customs
Approved-supplier routes, traceability, counterfeit-part controls, aircraft and parts imports, technical conformity, GTIP and customs.
MRO and airworthiness
SHT-145 maintenance organisations, repair and modification approvals, technical records, continuing airworthiness and maintenance agreements.
UAS, drones and advanced mobility
SHT-IHA registration, import, pilot and operational requirements, UAS certification, VTOL and eVTOL projects.
Contracts, risk and disputes
Aerospace supply, R&D, IP, technology, JV, lease, sale, insurance, product liability, export controls and regulatory disputes.
What Laws Regulate Aviation and Aerospace Companies in Turkey?
There is no single statute governing every aviation or aerospace activity. The framework can include:
- Turkish Civil Aviation Law No. 2920 and the organisation law governing SHGM, No. 5431;
- SHGM regulations and instructions, including SHY-21, SHT-21, SHT-145, continuing-airworthiness rules and SHT-IHA;
- ICAO standards and applicable bilateral, international and programme-specific arrangements;
- aircraft, engine, propeller, part, appliance, design and production certification requirements;
- aircraft registration, airworthiness, maintenance, operations and aviation-security rules;
- customs, import controls, technical conformity, export controls and sanctions;
- product liability, consumer, insurance, employment, competition and commercial-contract law;
- KVKK, cybersecurity, information security and cross-border data-transfer requirements;
- investment, industrial-site, environmental, R&D and technology-transfer rules; and
- Turkish Space Agency rules and international space-law considerations for space and satellite projects.
The applicable route should be mapped before a company commits to a product launch, aircraft import, design responsibility, supplier appointment or maintenance scope.
How Can a Foreign Aviation or Aerospace Company Enter the Turkish Market?
Foreign businesses may enter Türkiye by establishing a subsidiary, appointing an approved local representative or supplier, selling aircraft or parts, providing engineering or MRO services, forming a joint venture, operating UAS services, investing in manufacturing or developing a space and satellite project.
Before choosing the structure, the company should identify:
- the aircraft, product, part or service classification;
- the responsible design, production, maintenance and operational organisations;
- the SHGM approval, certification, registration or authorisation route;
- whether the foreign approval can be accepted, validated or supplemented in Türkiye;
- the Turkish importer, exporter, owner, operator and contracting entities;
- approved-supplier, quality, traceability and technical-record requirements;
- customs, export-control, security and sensitive-technology constraints; and
- how liability, insurance, data, IP, warranty, recall and dispute risks will be allocated.
Corporate formation is only one part of aviation market entry. The regulatory permissions and accountable organisations must be designed at the same time.
What Is SHT-21 and Why Does It Matter?
SHT-21 is the principal Turkish instruction for the airworthiness and environmental certification of aircraft and related products, parts and appliances. It is relevant to aircraft, engines, propellers, systems, components, design organisations, production organisations, type certification and supplemental type certification.
The certification analysis should establish the product, certification basis, applicable technical requirements, design data, test programme, conformity evidence, production controls, environmental requirements and the route for approval or acceptance by SHGM.
SHGM's 2026 SHT-21 revision also addressed UAS certification, upcoming ICAO Annex 8 changes, VTOL aircraft certification, environmental protection and production-organisation subcontracting. Businesses should review the current text and transition provisions before relying on an older certification plan.
Do Aviation Businesses Need DOA or POA Approval?
A Design Organisation Approval, commonly called DOA or TOO, concerns an organisation responsible for approved design work. A Production Organisation Approval, commonly called POA or ÜOO, concerns production, conformity, quality and control requirements for approved aviation products, parts or appliances.
The need for a particular approval depends on the product, design responsibility, production role, certification basis, customer and intended registration or operation. A company may need to coordinate design and production approvals, accepted alternatives, technical assistance and supplier controls.
A POA analysis should cover facilities, quality systems, production data, conformity inspection, release documentation, non-conforming products, subcontractors, critical parts, audits, records and changes. Contracts should not transfer a regulatory approval responsibility without checking whether the transfer is legally and technically effective.
Aerospace Manufacturing, Subcontracting and Supply Agreements
Aerospace supply agreements should reflect the safety-critical and heavily documented nature of the sector. They commonly address:
- technical specifications, drawings, configuration, software and change control;
- quality standards, audits, inspection, testing, conformity and release documents;
- production forecasts, capacity, lead times, delivery, acceptance and rejection;
- traceability, shelf life, storage, preservation, packaging and transport;
- subcontracting, critical parts, approved suppliers and flow-down requirements;
- non-conformities, corrective action, serial defects, warranty and recall cooperation;
- tooling ownership, maintenance, access, insurance and return after termination;
- background IP, project IP, licensing, data rights, cybersecurity and confidentiality; and
- export controls, sanctions, regulatory changes, business continuity and disputes.
Manufacturers and Tier 1 or Tier 2 suppliers should coordinate the supply contract with POA, approved-supplier, technical-record, product-liability and insurance requirements.
How Are Aircraft Maintenance Organisations Regulated?
Aircraft maintenance, repair and overhaul activities can require an applicable SHGM authorisation and compliance with SHT-145 or related maintenance and personnel rules. The organisation's approval scope, aircraft type, facilities, tools, personnel, manuals, records, parts and continuing-airworthiness responsibilities should be checked before work begins.
MRO agreements should define the work package, technical data, parts and materials, release-to-service documents, turnaround time, inspection, defects, modifications, records, warranty, liability, insurance, subcontracting, audits, storage, data security and dispute resolution.
Maintenance and continuing airworthiness are connected but distinct. A repair or modification may also require a design approval, STC, technical acceptance or additional SHGM review, depending on its scope and effect on the aircraft.
Aircraft Import, Customs and Registration in Turkey
Importing an aircraft into Türkiye requires coordination between technical conformity, airworthiness, customs, ownership, insurance, registration and operations. The transaction should identify whether the import is temporary or permanent, who owns and operates the aircraft, whether cross-border leasing is involved and which documents SHGM and customs will require.
Aircraft registration can involve de-registration evidence from the former state, export certificates, insurance, technical and weight information, ownership or lease documents, fees and other SHGM forms. An aircraft intended for Turkish registration should be reviewed before delivery or ferry flight.
Aircraft parts import analysis should separately address part status, approval or release documents, aircraft programme, GTIP, customs value, origin, duties, exemptions, technical conformity and storage. A part that is commercially available is not necessarily approved for installation on a particular aircraft.
How Are Drone and UAS Businesses Regulated in Turkey?
UAS businesses may face rules for the aircraft, control and monitoring station, command-and-control link, import, registration, pilot authorisation, operator status, flight permissions, airspace, safety and technical oversight. The business model should be assessed before importing drones, offering aerial services, training pilots or developing a UAS product.
SHGM's revised SHT-IHA instruction published in 2026 updated registration, importation, operations, pilot authorisation, manufacturer and importer duties, safety and oversight. It introduced a pilot-licensing model that separates flight authorisation from aircraft weight and uses P0, P1 and P2 licence levels. The current instruction and implementation route should be checked for each operation.
SHGM also identified 26 November 2026 as the effective date for certain ICAO Annex 8 amendment requirements relating to RPAS/UAS and control-and-monitoring stations. UAS manufacturers should review certification, design, production and transition planning ahead of that date.
Aviation Security, Cybersecurity and Data Protection
Aviation security can involve personnel, facilities, access, cargo, supply chains, sensitive technology, export restrictions and government or airport requirements. Aerospace businesses should identify security responsibilities in manufacturing, MRO, logistics, software and technical-assistance contracts.
Aircraft and aerospace systems can also process operational, passenger, crew, employee, maintenance and location data. Where information relates to an identified or identifiable person, KVKK obligations may apply. Data maps should cover aircraft systems, operators, MROs, cloud providers, suppliers, mobile applications, analytics and overseas group companies.
Software and technology agreements should address source code, object code, updates, open-source components, vulnerability reporting, cybersecurity controls, incident response, technical records, access rights, international transfers and end-of-life support. A cyber incident affecting safety-critical systems can create regulatory, contractual, insurance and liability consequences.
Space, Satellite and Advanced Aerospace Projects
Space and satellite projects may involve the Turkish Space Agency, international space law, telecommunications, spectrum, remote-sensing data, launch and insurance arrangements, government procurement, export controls, technology transfer, IP and foreign investment.
A project review should distinguish the satellite or payload, launch provider, ground station, data service, software, operator, customer and end use. R&D and technology agreements should define ownership of background and project IP, technical data, inventions, licensing, publication, confidentiality, cybersecurity, export restrictions and development milestones.
VTOL and advanced-air-mobility projects likewise require a coordinated assessment of certification, operational permissions, airspace, infrastructure, noise and environmental requirements, manufacturing, maintenance, software, passenger or cargo use and insurance.
Aerospace IP, Export Controls, Product Liability and Insurance
Aerospace projects commonly involve aircraft and component designs, CAD data, tooling, technical drawings, software, patents, know-how, trademarks, confidential engineering data and certification records. Agreements should separate background IP from project IP and specify ownership, licence scope, modifications, manufacturing rights, territory, duration and sublicensing.
Export-control review may be required for aircraft, defence-related or dual-use items, software, technical data, components, services and technology assistance. The parties should identify destination, end user, end use, sanctions, licence conditions, re-export restrictions, screening, records and termination rights before transferring sensitive material.
Product-liability and insurance clauses should address design, manufacture, maintenance, modification, installation, inspection, flight testing, recall, warranty, third-party claims, deductibles, additional insureds, limits, evidence of coverage and cooperation with investigations. Contractual indemnities should be coordinated with mandatory legal duties and the actual insurance programme.
Aviation Disputes and SHGM Investigations
Aviation disputes can involve defective parts, maintenance findings, airworthiness, certification delays, design changes, delivery, supply interruption, tooling, lease payments, insurance, product liability, passenger or customer claims, UAS operations, customs, export controls and unpaid receivables.
Depending on the contract and parties, the appropriate process may involve negotiation, mandatory mediation, Turkish court litigation, domestic arbitration, international arbitration, enforcement or debt collection. Governing law, jurisdiction, technical evidence, expert appointment, confidentiality, interim relief and the enforceability of an award should be addressed when the contract is drafted.
SHGM investigations and administrative sanctions should be coordinated with commercial strategy. A finding about an aircraft, part, maintenance action or UAS operation can affect certification, supplier indemnity, insurance, customer claims, recall, licence status and future market access.
Commercial Contracts for Aviation & Aerospace Companies
Aerospace supply and manufacturing
Quality, conformity, traceability, configuration, capacity, delivery, subcontracting, warranty and corrective action.
Design and engineering
Certification basis, design responsibility, technical data, DOA, STC, software, IP, testing and acceptance.
MRO and maintenance
SHT-145 scope, work packages, parts, records, release-to-service, defects, turnaround, warranty and liability.
Aircraft sale and lease
Title, delivery condition, airworthiness, registration, export, insurance, maintenance status and return conditions.
R&D, technology and JV
Background IP, project IP, development milestones, licensing, data, funding, governance and exit rights.
UAS, software and technical assistance
UAS operations, certification support, cybersecurity, updates, training, compliance, export controls and service levels.
Frequently Asked Questions About Aviation & Aerospace Law in Turkey
What law regulates aviation and aerospace companies in Turkey?
The framework includes the Turkish Civil Aviation Law No. 2920, SHGM's organisation law No. 5431, SHGM regulations and instructions such as SHY-21, SHT-21 and SHT-145, applicable international standards, customs and commercial law.
Who regulates aircraft and aerospace companies in Turkey?
SHGM is the principal civil-aviation regulator for aircraft, certification, airworthiness, maintenance, operators and UAS matters. The Turkish Space Agency and other authorities may have jurisdiction over space, technology, trade, customs, security and investment issues.
Can a foreign aerospace company establish manufacturing operations in Turkey?
Yes, subject to the selected corporate, investment and regulatory structure. The company should assess production-organisation approval, design responsibility, subcontracting, approved suppliers, export controls, site and investment matters before committing to manufacturing.
What is a Production Organisation Approval in Turkey?
A POA confirms that an organisation meets applicable production, quality, conformity and control requirements for approved aviation products, parts or appliances. Its precise scope depends on the approval and the organisation's activities.
Does an aerospace design company need SHGM approval?
A company responsible for aircraft, product, part or appliance design may need an applicable DOA or another accepted design-approval route. The answer depends on the product, design responsibility, certification basis and intended Turkish registration or operation.
Do aviation parts suppliers need approval in Turkey?
Requirements depend on the part, aircraft programme, customer and intended use. Suppliers may need approved-supplier status, conformity evidence, traceability, quality controls, authorised release documentation or an approval under the applicable SHGM and programme framework.
Can a foreign aircraft maintenance company provide MRO services in Turkey?
Potentially, but the organisation must meet applicable maintenance-organisation and scope-of-work requirements. SHT-145, aircraft approvals, maintenance personnel, records, continuing airworthiness and cross-border authorisations should be reviewed before services begin.
Do drones need approval before being imported into Turkey?
Importation, registration, technical conformity, operator or pilot requirements and operational permissions can apply depending on the UAS and intended activity. The current SHT-IHA framework and the aircraft's characteristics should be checked before import or flight.
Did Turkey change its drone regulations in 2026?
SHGM published a revised SHT-IHA instruction in 2026 addressing registration, importation, operations, pilot authorisation, manufacturer and importer duties, safety and oversight. UAS businesses should verify the current instruction before relying on an earlier compliance analysis.
Does Turkey regulate eVTOL aircraft and advanced air mobility?
Yes. The revised SHT-21 framework defines certification requirements for VTOL aircraft and addresses UAS and ICAO Annex 8 developments. The certification basis, operational model, infrastructure and airspace permissions should be assessed for each project.
Can Turkish Trade Lawyers advise foreign aerospace suppliers contracting with Turkish manufacturers?
Yes. We advise foreign aerospace suppliers on manufacturing, supply, tooling, design, technology, MRO, aircraft-parts, IP, export-control, product-liability, insurance, dispute-resolution and enforcement matters in Türkiye.
Aviation & Aerospace Legal Services for Foreign Businesses in Türkiye
A foreign aviation or aerospace business can encounter Turkish law at every stage of a project. Market entry determines the responsible organisations and approvals. SHT-21, DOA and POA affect design, production and certification. MRO and continuing airworthiness govern maintenance and records. UAS and VTOL projects require a separate assessment of aircraft, pilot, operator, airspace and certification requirements. Customs, export controls, cybersecurity, IP, liability and insurance shape the commercial risk.
Turkish Trade Lawyers advises foreign manufacturers, MROs, suppliers, technology companies, UAS businesses, investors and space-sector participants on aviation and aerospace legal services in Turkey, including contracts, compliance, investigations, disputes and enforcement.
