Türkiye has developed into a major destination for cross-border healthcare, serving patients who travel for medical, dental, surgical, diagnostic, rehabilitative and other health services. The sector brings together healthcare law, tourism regulation, consumer protection, contract law, data protection, insurance, immigration and private international law. It also creates distinct legal risks because treatment, payment, advertising, travel arrangements and follow-up care may involve several providers in different jurisdictions. This guide explains the principal Turkish rules governing international medical and health tourism for healthcare providers, intermediaries and international patients. The applicable framework depends on the treatment, provider, patient status and service chain.

1. International Medical and Health Tourism in Türkiye

International health tourism under Turkish law broadly concerns health services received by non-Turkish citizens, or Turkish citizens resident abroad, who come to Türkiye temporarily for health purposes. “Tourist health”, by contrast, concerns foreigners who require healthcare because of an illness or emergency arising while they are temporarily in Türkiye for another reason. Although the two categories may involve different circumstances, both fall within the regulatory framework established for international patients.

The market is substantial. According to official USHAŞ figures, 1,506,442 people visited Türkiye for healthcare services in 2024, generating approximately USD 3.023 billion in health tourism revenue. The Ministry of Health’s Health Statistics Yearbook 2024, published on 31 December 2025, records 1,562 hospitals, 268,359 hospital beds, 221,133 physicians and 50,434 dentists. These figures illustrate the scale of the healthcare infrastructure supporting domestic and cross-border treatment, but they do not remove the need to verify the authorisation, qualifications and suitability of the particular provider.

International patients commonly seek dental treatment, cosmetic and reconstructive surgery, ophthalmology, orthopaedics, bariatric procedures, fertility treatment, cardiology, oncology, rehabilitation and diagnostics. Each field may also be governed by profession- or treatment-specific rules; individual legal and medical assessment remains necessary.

2. The Regulatory Framework

The central instrument is the Regulation on International Health Tourism and Tourist Health, published in Official Gazette No. 32882 on 26 April 2025. It expressly repealed the regulation dated 13 July 2017 and introduced a more detailed system of authorisation, accreditation, certification, insurance, reporting, performance assessment, advertising control, inspection and sanctions.

The Regulation is based principally on the Basic Law on Health Services No. 3359, relevant provisions of Decree-Law No. 663 and the Presidential Decree on the Organisation of the Presidency. It operates together with the legislation governing private hospitals, medical centres, outpatient diagnosis and treatment institutions, dental healthcare, medical laboratories, dialysis centres, healthcare professionals, remote healthcare, patient rights and health-service advertising.

Other important legal layers include the Turkish Code of Obligations No. 6098, Consumer Protection Law No. 6502, Personal Data Protection Law No. 6698, Law No. 1219 on the Practice of Medicine and Medical Sciences, the Turkish Civil Code, the Turkish Penal Code, private international law and procedural legislation. The facts of a transaction, complaint or dispute determine which combination applies. Consumer-law characterisation, the competent forum and limitation periods should not be assumed solely from the fact that the patient paid for treatment.

3. Who Falls Within the Medical Tourism Regime?

The 2025 Regulation applies principally to persons coming from abroad for healthcare, tourists whose need for treatment arises during their stay, and the public, university and private facilities and intermediaries serving them. It does not cover every foreign national receiving treatment in Türkiye.

Specified exclusions include certain persons receiving care under international social security or bilateral cooperation arrangements, students and qualifying family members holding the relevant residence permits, persons under temporary or international protection, stateless persons, certain persons of Turkish origin, and defined humanitarian or officially coordinated cases. A person within an excluded category may nevertheless elect to receive services under the international health tourism regime by undertaking to pay the relevant charges.

Classification affects pricing, registration, reporting and institutional responsibility. Providers should document the patient’s status at the outset, while patients should understand the category under which they receive care.

4. Authorisation of Healthcare Providers

A healthcare facility may not conduct international health tourism activities merely because it holds an ordinary healthcare licence. It must also obtain an International Health Tourism Authorisation Certificate from the Ministry of Health. Conversely, the health-tourism certificate is additional to the facility’s underlying licence and activity permissions: it does not enlarge the clinical services the facility may lawfully provide. Applications are submitted through the Ministry’s Integrated Corporate Transaction Platform, EKİP. Following documentary review by the provincial or district health directorate, an on-site assessment is conducted before the file is transmitted to the Ministry for decision.

The authorisation is not transferable. Changes in ownership, premises, activity or corporate structure must therefore be reviewed carefully. A provider must not treat the certificate as an asset that can simply pass with a commercial transaction. Healthcare groups should also verify the status of each relevant facility rather than relying on the authorisation of another group company or location. Inclusion on an official authorised-provider list confirms a regulatory status at the relevant verification date; it is not a government guarantee of clinical quality, suitability or outcome.

5. Authorisation of Medical Tourism Intermediaries

An intermediary coordinates services such as healthcare-facility arrangements, accommodation, transport and transfers for international patients and their companions. Under the 2025 framework, the intermediary must be operated by a legal entity and obtain its own authorisation from USHAŞ, the International Health Services Joint Stock Company. Applications are made to USHAŞ and include documentary review and on-site inspection. A separate certificate is required for every additional intermediary establishment or branch. Unauthorised branches cannot conduct health-tourism activities, and certificates are not transferable.

The distinction between an intermediary and an informal lead generator is important. A business may fall within the regulated activity because of what it actually does, irrespective of the label used in its contract or website. Digital platforms, overseas representatives and marketing partners should therefore be reviewed for authorisation, agency, advertising, data-processing and liability consequences. As the Ministry and USHAŞ lists are living regulatory data, checks should record the exact legal entity, establishment, address, facility category, status and date of verification.

6. Accreditation, Certification and Quality Standards

The 2025 Regulation adds a quality-assurance framework. Hospitals, medical centres, medical laboratories and dialysis centres must be accredited by TÜSKA; other healthcare facilities must obtain the certificate prescribed by the Ministry of Health. Existing authorised providers must fulfil the accreditation or certification obligation by 31 December 2026. Providers should identify the applicable standard, complete a gap assessment, retain evidence and prepare for external assessment.

Healthcare facilities must also obtain complication insurance for surgical and interventional procedures performed in an operating-theatre environment within international health tourism. Insurance does not replace clinical responsibility or eliminate patient claims. Policy scope, exclusions, notification conditions and consistency with patient and intermediary contracts require careful review.

7. Operational Duties of Healthcare Providers

An authorised facility must establish an international health tourism unit responsible for admission, registration, diagnosis and treatment coordination, invoicing, discharge, interpretation and dealings with intermediaries. At least one member of the unit must have documented foreign-language competence. Staff details must be reported through EKİP. For each international health tourist, the facility must designate a responsible staff member and register that person in the HealthTürkiye Portal. This requirement creates an identifiable coordination point across the patient journey and should be reflected in internal procedures.

The facility may accept patients directly without an intermediary. Where an intermediary function is required, however, it may not obtain regulated intermediary services from an unauthorised person or entity. Providers should conduct and record authorisation checks before contracting, renew those checks periodically and address suspension or cancellation in their agreements. An authorised facility may also provide remote healthcare within the separate Regulation on Remote Health Services and announce that capability through the Portal. Remote delivery does not remove profession, facility, consent, record, security or cross-border data-transfer requirements.

8. Operational Duties of Intermediaries

An authorised intermediary must answer calls in at least two foreign languages on a 24/7 basis, directly or through a capable call centre. Personnel assigned to international health tourism may not work simultaneously for more than two intermediaries. Accommodation, transportation and transfer services must be provided through travel agencies authorised under Law No. 1618, unless the intermediary is itself an authorised travel agency. The use of subcontractors does not eliminate the need to allocate responsibility clearly and supervise performance. Intermediaries should document provider checks, quotations, patient communications, complaints, emergencies, cancellations, refunds, data security and post-treatment contact. They must not present themselves as the treating provider or make clinical promises outside their competence.

9. HealthTürkiye Portal, Records and Regulatory Reporting

Healthcare facilities and intermediaries must join the HealthTürkiye Portal and enter complete, accurate and current information. Domestic and overseas service units used for health-tourism activities must be reported through the Portal. Intermediaries must register the personnel assigned to these services, including at least one responsible staff member. Healthcare facilities must use a health information management system registered within the Ministry’s system for the recording and archiving of healthcare data. Relevant information must be transmitted to the central health data system in accordance with the Ministry’s requirements. Both providers and intermediaries must supply documents and information requested by the competent authorities. Regulatory reporting should be reconciled with medical, financial and contractual records. Providers should assign responsibility for data fields, access, corrections, retention and periodic review.

10. Patient Information, Informed Consent and Language Access

Valid consent requires more than a patient’s signature on a standard form. The patient must receive understandable information about the proposed intervention, material risks, likely benefits, reasonable alternatives and the consequences of refusing treatment. The information process must occur sufficiently before the intervention to permit a genuine decision, except where emergency rules apply. Language is especially important in cross-border treatment. A form translated into the patient’s language does not cure an inadequate clinical explanation. Providers should document the language used, the interpreter’s identity where relevant, the questions asked and any treatment-specific information supplied. An intermediary should not distort, shorten or replace information that must be provided by the treating professional. Treatment consent, data-processing consent and permission to use photographs or testimonials are legally distinct and should not be improperly bundled.

11. Contracts, Pricing, Payments and Insurance

The patient journey may involve contracts with a healthcare facility, physician, intermediary, hotel, travel agency or insurer. A “package” does not necessarily identify responsibility for each component. Contracts should state the providers, treatment scope, included and excluded costs, payment, cancellation, refund, complication and follow-up terms.

Quotations should distinguish expected treatment from services that may become necessary because of clinical findings or complications. Clauses attempting to exclude all liability for negligence, defective performance or misleading information may be ineffective under mandatory Turkish law. Consumer status and the nature of the healthcare relationship must be assessed in each case.

International patients should verify whether private or travel insurance covers elective treatment abroad, complications, extended accommodation, repatriation and follow-up care at home. Providers and intermediaries should avoid representing that reimbursement is guaranteed unless this has been confirmed by the responsible insurer.

12. Advertising and Digital Communications

Healthcare facilities and intermediaries are subject to the Regulation on Promotion and Information Activities in Health Services, published in Official Gazette No. 33075 on 12 November 2025, together with consumer and commercial-advertising rules where applicable. They must maintain a website with a foreign-language option, and the establishment name and ownership information shown online must correspond to the authorisation certificate. Healthcare facilities must publish the applicable accreditation document or Ministry certificate on their website. Websites, search advertisements, social media, influencers, before-and-after images, patient reviews and overseas campaigns may all create regulatory exposure. Content must not mislead patients, exploit their lack of medical knowledge, guarantee results or encourage unnecessary treatment. Commercial partners should not make claims that the authorised entity could not lawfully make itself. Agreements with marketing agencies and overseas representatives should address approvals, patient leads, data protection, records and removal of non-compliant content. Advertising compliance requires continuing review.

13. Medical Records, Privacy and Cross-Border Data Transfers

Health information is special-category personal data under Law No. 6698. Healthcare facilities and intermediaries must identify their respective roles, legal grounds and responsibilities for collecting, using, sharing, storing and deleting patient information. The analysis must reflect the materially amended Article 6 regime in force since 2024; explicit consent is not the only possible legal basis and should not be treated as a universal cure for deficient processing. Access should be limited to persons who require the information for a lawful and defined purpose, with the additional safeguards required for special-category data.

Cross-border care frequently involves medical records sent before travel, information shared with overseas physicians, cloud services hosted abroad, call centres, translators, insurers, foreign counsel and relatives. Each transfer must be assessed under amended Article 9 and the current cross-border transfer framework, including the hierarchy of adequacy decisions, appropriate safeguards and limited exceptional transfer grounds. Standard contracts, approved undertakings or another legally recognised mechanism may be required depending on the transfer. A general consent clause should not be used as a substitute for a properly designed data-processing structure.

Patients may seek access to their records under applicable law. Providers need secure identity verification, delivery and post-return communication procedures. Medical-data breaches may create contractual, regulatory and civil exposure.

14. Complications, Malpractice and Allocation of Liability

An adverse outcome does not automatically establish malpractice. A recognised complication may occur despite appropriate diagnosis, treatment and follow-up. Conversely, describing an outcome as a complication does not end the legal inquiry. The decisive issues may include whether the indication was proper, the procedure met professional standards, the risk was disclosed, the complication was recognised promptly and the response was adequate.

Potential responsibility may attach to a physician, healthcare facility, intermediary or another service provider depending on their acts, representations and contractual roles. The 2025 Regulation allocates responsibility between the healthcare facility and intermediary according to the type of service supplied and expressly brings post-treatment complications and medical malpractice within that responsibility framework. This does not create automatic strict liability or dispense with claim-specific analysis of breach, fault where required, causation and damage.

Early evidence preservation is critical, including consent documents, clinical notes, imaging, test results, prescriptions, invoices, messages, advertisements, photographs and post-operative communications. Independent expert assessment is normally central to causation and the standard of care.

15. Complaints, Inspections and Administrative Sanctions

Healthcare facilities and intermediaries must evaluate complaints and implement corrective and preventive action. Complaint systems should identify recurring risks and inform governance and training. Patient-rights applications, contractual complaints, regulatory reports and compensation claims may follow different channels. USHAŞ evaluates authorised facilities and intermediaries at least annually against the performance criteria in the Regulation. Entities assessed as partially sufficient or insufficient are subject to a control assessment within three months. Inspection may lead to warnings, suspension of activities, suspension of the authorisation certificate or cancellation. A certificate may be suspended where an urgent and difficult-to-remedy situation threatens patient health or safety. Improper record keeping may result in a six-month suspension and, if repeated within one year, cancellation. The certificate may also be cancelled where the entity has conducted no health-tourism activity during the preceding year. Following cancellation, a new certificate is not issued for one year.

16. Cross-Border Claims and Dispute Resolution

When treatment or related services go wrong, the patient may have claims based on contractual breach, defective service, professional negligence, lack of informed consent, misleading advertising, privacy violations or several grounds together. Available remedies may include reimbursement, compensation for additional treatment costs, loss of earnings, support needs and non-pecuniary damage, subject to proof and the applicable legal rules.

Jurisdiction and applicable law require case-specific analysis under Turkish private international law and the relevant procedural rules. A foreign patient, overseas intermediary and Turkish provider may have selected a court or arbitration clause, but mandatory jurisdiction and consumer-protection rules may affect its validity. Consumer Court jurisdiction must not be assumed in every paid healthcare relationship. Claims arising from private healthcare are generally pursued through private-law routes, whereas proceedings concerning public healthcare may fall within administrative jurisdiction and may require a prior administrative application. University-hospital status and the identity of the operating body must be checked rather than inferred from the hospital name.

Medical disputes are evidence-intensive. Counsel should identify the defendants, secure the medical file, evaluate time limits, obtain appropriate expert assessment and consider settlement or mediation. Foreign judgments may require recognition or enforcement in Türkiye, and Turkish judgments may require enforcement abroad.

17. Immigration and Continuity of Treatment

The right to receive treatment does not itself remove immigration requirements. Patients and companions should check visa rules, permitted stay, passport validity and any need for an extension before travel. Treatment schedules, recovery periods and unexpected complications may affect the intended departure date. Medical documentation may support an immigration application, but approval is not automatic. Providers and intermediaries should not promise a visa, residence permit or extension. Continuity planning should begin before discharge. The patient should understand medication, warning signs, follow-up appointments, access to records and whom to contact after returning home. Where further care will be provided abroad, lawful and secure communication between professionals may reduce clinical and legal risk.

18. How Bıçak Law Firm Assists

Bıçak Law Firm advises international patients, healthcare providers, medical tourism intermediaries, investors and other participants in the cross-border healthcare sector. Our work combines healthcare regulation with contracts, data protection, corporate structuring, immigration and dispute resolution.

For healthcare facilities and intermediaries, our services may include regulatory mapping; authorisation and compliance support; review of operating models and service chains; drafting and negotiating patient, intermediary, travel and supplier agreements; advertising and website review; data-protection governance; complaint and incident response; inspection support; and representation in administrative or commercial disputes.

For international patients and families, we may review treatment and intermediary agreements, clarify the legal significance of available authorisation information, advise on informed consent and records, assess potential malpractice or contractual claims, work with appropriately qualified independent experts where necessary and provide representation in negotiations or Turkish proceedings. We provide legal services and do not select treatments, recommend clinical providers, guarantee regulatory status or act as a medical-tourism coordinator. Each engagement is defined according to the available evidence, urgency, treatment status and jurisdictions involved.

19. Conclusion

Türkiye’s international healthcare sector combines extensive clinical capacity with a detailed and evolving regulatory system. The 2025 Regulation has raised expectations concerning authorisation, quality assurance, complication insurance, operational organisation, digital reporting, advertising, performance and enforcement. Healthcare facilities and intermediaries should treat these obligations as an integrated compliance programme rather than a collection of application documents.

International patients should identify the authorised parties, obtain clear clinical and financial information, understand the contractual service chain and preserve records throughout the treatment journey. Where a regulatory problem, adverse outcome or cross-border dispute arises, early legal and expert assessment can protect evidence, clarify responsibility and identify the most effective remedy.

This publication provides general information on Turkish law and does not constitute legal or medical advice. Specific advice should be obtained for the facts of each matter.