How To Establish A Health Tourism Company in Turkey?

Health tourism is becoming increasingly popular among foreigners in Turkey, and the health tourism sector is starting to become one of the most popular areas for investors. Before answering the question of how to establish a health tourism company, some general information about health tourism needs to be known.

I. What is Health Tourism?

Health tourism can be defined in its simplest form as a patient traveling to a foreign country for treatment. Legally, health tourism refers to any health service and related support services obtained by foreign citizens who come to Turkey temporarily for health purposes, or Turkish citizens who permanently reside abroad.

As can be understood from the definition, in health tourism, the patient and the provision of health services and support services are important.

In health tourism, three subjects are important. The first is undoubtedly the international health tourist who will receive treatment. The second is the international health tourism health facility that will provide health services to the international health tourist in Turkey. Th third is the international health tourism intermediary organization, also known as the agency, which brings the health tourist together with the health facility and coordinates the health tourist’s activities such as treatment, accommodation, and sightseeing during their stay in Turkey.

With the entry into force of the “Regulation on International Health Tourism and Tourist Health” published in the Official Gazette dated 26 April 2025 and numbered 32882, the “Regulation on International Health Tourism and Tourist Health” published in the Official Gazette dated 13/7/2017 and numbered 30123 has been repealed. With the new regulation, the criteria for becoming a health tourism intermediary organization have been changed and many new regulations have been introduced. The most important of these changes is the complete change of the definition of a health tourism intermediary organization.

In the old regulation, in order to become a health tourism intermediary organization, it was necessary to have a Group A travel agency operating certificate obtained in accordance with the Travel Agencies and Travel Agencies Association Law, that is, the condition of being an agency was sought.

In the new regulation that entered into force on April 26, 2025, the health tourism intermediary institution was redefined as “an organization that provides consultancy services to international health tourists and their companions and other relatives within the scope of international health tourism services, carries out the activities of health facility organization, accommodation, transportation and transfer services and is operated by legal entities with an authorization certificate”, the conditions required to become an authorized institution were listed in the continuation of the regulation and the requirement to be an agency was eliminated. However, the condition that accommodation, transportation and transfer services are provided through TÜRSAB authorized travel agencies is maintained.

In our article, the differences between the old and new regulations are examined and how to establish a health tourism company is explained.

Establishing a company in Turkey is not a very difficult process. However, people who want to establish an international health tourism company should not overlook the following points:

II. How to Establish a Health Tourism Company in Turkey?

Before establishing a health tourism company, some important points should be taken into consideration. The first of these will be the type of the company.

A health tourism company can be established as a joint-stock company or a limited company. For detailed information about company types, you can check out our articles on joint-stock companies and limited companies.

The second point will be the situation of shareholders who have a capital structure of the company. If the company’s shareholders or managers are foreign citizens and will reside in Turkey, the company establishment should be made in a way that allows these individuals to obtain a work permit. If the work permit condition of foreign company partners or company managers is not taken into account during the establishment of the company, this situation may cause even bigger problems later on.

Before establishing a health tourism company, investors must definitely make a cost feasibility study to obtain an international health tourism authorization certificate. Because there are many cost items that can create a financial burden to obtain an international health tourism authorization certificate. In the continuation of our article, we explain the cost items.

Who Can Do Health Tourism in Turkey?

In the old regulation, in order to become a health tourism intermediary institution, it was necessary to first have a Group A travel agency business license obtained in accordance with the Travel Agencies and Travel Agencies Association Law and to register with TURSAB.

In the new regulation, the follow-up of the necessary procedures to become an intermediary institution has been transferred to USHAŞ. In order to conduct health tourism, intermediary institutions must have an “International Health Tourism Authorization Certificate” issued by the International Health Services Corporation (USHAŞ). Individuals or legal entity partners and managers who conduct health tourism without an authorization certificate may be punished with imprisonment, judicial fines and administrative fines. However, since the regulation is still very new, the application guide has not yet been published by USHAŞ.

Who is awarded the International Health Tourism Authorization Certificate in Turkey?

The work and procedures for authorization of Health Tourism intermediary institutions have been transferred to USHAŞ. For this reason, applications for the International Health Tourism Authorization Certificate must be submitted to USHAŞ. When applying, the original, signed and stamped copy of the application petition filled out by the authorized signatory of the health facility, a photocopy of the identity of the person who will receive the document and the receipt of the document fee paid to the Accounting Directorate and/or the Revenue Directorate must be submitted. The document fee for 2025 is 14,825.00 Turkish Lira. When paying the document fee, the name of the health facility published on its web page and the phrase “international health tourism authorization certificate fee” must be stated on the receipt.

In addition to these, the documents included in the ANNEX-1B article of the Regulation on International Health Tourism and Tourist Health must also be submitted to USHAŞ during the application.

Employment

Another condition for becoming an international health tourism agency is to have signed a contract with at least 3 health facilities that have an international health tourism authorization certificate. The contract will enter into force upon receipt of the authorization certificate.

The health tourism company must have a 24/7 call center service that can answer incoming calls in at least 2 languages.

In addition to the personnel or personnel employed in the call center, at least 2 more personnel who speak a foreign language (one of these languages ​​must be English) must be employed. Personnel who speak a foreign language will be required to document the language requirement. No changes have been made to the employment requirement in the new regulation.

Website

It is mandatory for Health Tourism companies to create a website with a foreign language option. The organization name and titles on the website must be compatible with the title and ownership name in the authorization document for the health facility and intermediary institution. The conditions regarding the website are also preserved in the new regulation.

Health Türkiye Portal

Health Türkiye Portal is an internet portal established by the ministry for the purpose of recording, monitoring, auditing and supervising international health tourism activities. Health tourism companies must become members of the Portal and enter data completely, accurately and up-to-date. Intermediary companies are obliged to report all service units they will establish domestically and abroad for health tourism purposes through the Portal

The performance criteria of health tourism companies are evaluated by USHAŞ. As a result of the evaluation, the adequacy of health facilities and intermediary institutions is reported to the relevant parties through the Portal.

Mandatory Obligations

It is mandatory for intermediary institutions to provide accommodation, transportation and transfer services through authorized travel agencies within the scope of the Travel Agencies and Travel Agencies Association Law No. 1618 dated 14/9/1972. These services can be carried out by the intermediary institution itself if the intermediary institution is an authorized travel agency.

It is also stated in the regulation that health facilities and intermediary institutions will be responsible for the health and intermediary services that the international health tourist will receive during his/her stay in our country, depending on the type of service provided; it is stated that complications and medical malpractices that may arise after the health service provided are also included in this responsibility.

The health tourism agency must undertake to obtain travel insurance covering the entire travel of each health tourism tourist/patient.

• To research health facilities that are suitable for the health service that the international health tourist wants to receive by forwarding the health tourist’s medical information and/or documents to the health facility in advance,
• To provide detailed information to the international health tourist about health facilities that can provide the health service that the international health tourist wants to receive.
• To obtain information from the health facility about the health service fee that the international health tourist will receive and to inform the international health tourist about the approximate service fee and payment terms.
• To provide information to international health tourists on issues such as travel, passport, urban transportation, communication, consulate procedures in our country.
• To ensure the arrival of international health tourists and their companions in our country, their accommodation in our country and their return to their country.
• To transfer international health tourists to the international health tourism health facility where they will receive service, to contact the international health tourism unit in the facility and deliver the tourist to this unit, and to pick them up from the facility after they are discharged.
• To act in accordance with the Personal Data Protection Law No. 6698 dated 24/3/2016 regarding any information obtained from international health tourists during their activities.
• To keep all documents related to their activities for the periods specified in the relevant legislation.
• To provide detailed information about the services to be provided to international health tourists and their companions and to obtain their informed consent. (Information can also be provided electronically.)

These obligations, which are stipulated by the health tourism intermediary, are also another requirement for obtaining the international health tourism authorization certificate.

Are the Partners or Managers of Health Tourism Companies Foreigners?

Foreign company shareholders or managers who want to reside in Turkey are required to obtain a work permit.

If one or more shareholders of a health tourism company or the manager of the company is a foreigner, they must obtain a work permit in order to stay in Turkey, even if they are not a shareholder. There are many conditions that foreign company shareholders or managers must meet in order to obtain a work permit.

For detailed information about work permits for foreign company shareholders or managers, you can read our article “Work Permits for Foreign Company Partnets and Managers”.

III. What are the Penalties for Medical Tourism Companies or Partners or Managers?

The managers or partners of a medical tourism company who act contrary to the issues we have described in our article may face imprisonment for 1 to 3 years and a criminal fine of up to twenty thousand Turkish liras.

Additionally, if these individuals are foreigners, they may be deported from Turkey and even held in a deportation center under administrative supervision until they are deported. Moreover, foreign individuals who have been subject to deportation may be prohibited from entering Turkey for a period ranging from 1 month to 5 years.

These sanctions are not the only ones that may be imposed. Administrative penalties and administrative fines may also be imposed. The administrative fine may be up to half of the company’s monthly gross earnings.

Even if the health tourism company starts operating after meeting all competence criteria, sanctions may still be in question. Health facilities and intermediary institutions that are evaluated by USHAŞ as partially sufficient or insufficient in terms of performance criteria are subject to a control assessment within three months from the date of detection. If it is determined that competence is not achieved as a result of the control assessment;

1. In case of partial competence, the authorization certificate is suspended for three months,
2. In case of insufficiency, the authorization certificate is suspended for six months.
3. Health facilities and intermediary institutions whose authorization certificates are suspended are subject to a second control assessment within three months from the end of the suspension period. If it is determined that competence is not achieved as a result of the second control assessment, the authorization certificate is canceled.

In addition to performance criteria, administrative audits of health tourism companies are also conducted by USHAŞ. If it is determined that there are urgent and irreparable situations that negatively affect the treatment of the health tourist, endanger the health and safety of the service in case of continuation, and require the service to be stopped without delay, the authorization certificate is suspended by the Ministry for the health facility and by USHAŞ for the intermediary institution until this situation is resolved.

1. If it is determined that the records of the health facility and intermediary institution are kept inappropriately as a result of the examination of the records, the authorization certificate is suspended for six months. If the same act is repeated within one year, the authorization certificate is canceled.
2. The authorization certificate of the health facility and intermediary institution that has not operated within the scope of health tourism in the last year is canceled.
3. No new authorization certificate is issued for one year for the institutions whose authorization certificates are canceled.

Although establishing a health tourism company is attractive to many investors, companies that want to operate as a health tourism intermediary will need to strictly follow the above-mentioned points. These are the procedures related to the establishment of the company. After the establishment of the company, relations with health tourism health facilities, namely hospitals or clinics, patients/tourists and accommodation and tour companies will begin.

To summarize the changes brought by the new regulation;

• The requirement for an intermediary institution to be a travel agency has been eliminated.
• The authorities of USHAŞ have been increased and an application requirement has been introduced to USHAŞ in order to become an intermediary institution.
• The requirement to register to the Health Turkey Program has been introduced, and the requirement for intermediary institutions to integrate all data completely and up-to-date into the portal has been introduced.
• Depending on the type of health service provided, a Complication Insurance Requirement has been introduced for intermediary institutions.
• Performance evaluation has been introduced by USHAŞ.

Transition Process

The regulation entered into force as of the date of publication, but a compliance period was granted to existing brokerage firms. This compliance period is 6 months. Therefore, brokerage firms must fulfill their regulatory obligations until 26/10/2025. The licenses of existing brokerage firms that do not comply will be canceled at the end of the specified period.

IV. BAL Law Firm provides Legal Consultancy Services for Medical Tourism Company Establishment and Management.

BAL Law Firm offers legal consultancy services to medical tourism companies to reduce their legal risks and manage their legal relationships during these operational processes.

Currently, 721 companies in Turkey are engaged in medical tourism agency activities with the International Health Tourism License.

List of Intermediaries with the International Health Tourism License for 2024

List of Healthcare Facilities with the International Health Tourism License for 2023

Memduh Remzi BAL
Attorney at Law | Lawyer in Turkey

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