Employer of Record in Turkey
Contents
General information, not legal or tax advice — confirm with a local adviser before you act.
A foreign company can hire through a Turkish employing provider. The legal route depends on who employs the worker, what the agreements say and who directs the work. The Turkey hiring guide covers the wider options.
For regulated temporary labour supply, Article 7 sets specific conditions for a private-bureau route and separately permits assignments within a holding or company group. Turkey’s gross monthly minimum wage is ₺33,030 in 2026.
4dev.com’s Contractor Platform supports genuinely independent services in Turkey. The Turkey contractor guide covers that route.
What an employer of record does in Turkey
An employer of record is a provider that employs a worker for a client, which may direct the day-to-day work. In Turkey, the label alone does not establish the legal structure.
The client and provider set commercial terms in a service agreement; the actual employer signs the worker’s employment agreement. The contracts and day-to-day supervision determine which structure needs review.
In regulated temporary supply through an İŞKUR-permitted private employment bureau, Article 7 makes the bureau the employer and requires written agreements with the worker and user employer. A holding or company-group assignment is a separate Article 7 route.
Is an employer of record legal in Turkey?
Turkey regulates temporary labour supply under Article 7. Whether its private-bureau rules apply depends on the proposed contracts and work arrangement.
The Article 7 temporary-work test
If a private employment bureau supplies a temporary worker to a user employer, Article 7 of Labour Law No. 4857 requires an İŞKUR-permitted bureau, a listed ground and written agreements with the worker and user employer. Grounds include replacing absent staff, seasonal agriculture, domestic work, intermittent work, urgent occupational-health-and-safety needs and unforeseen demand. The worker’s basic conditions cannot fall below those of a comparable direct employee of the user employer.
For most permitted bureau-supply grounds, the initial placement is limited to four months and may be renewed twice, generally to eight months in total; statutory exceptions apply. If the placement continues after its agreed end, the user employer is deemed to have an indefinite employment contract with the worker from that date. Agree the ground, contracts and end date before work starts.
What the label leaves unanswered
Article 7 also permits assignments within a holding or company group. The bureau conditions described above do not automatically govern that route.
Other structures require a review of the actual employer, contracts, supervision and subcontracting position. In sham subcontracting, the subcontractor’s workers are treated as the principal employer’s workers from the start.
When to check a provider’s İŞKUR licence
If the proposed arrangement is Article 7 agency supply, ask for the Turkish entity’s current İŞKUR authorization for the temporary-work activity and its expiry date.
That document request is specific to supply through a private employment bureau. Company registration, a general services licence or authority to intermediate placements does not by itself show authorization for temporary labour supply; a holding or company-group assignment is a separate Article 7 route and should not be described as a bureau licence case.
Ask for the entity’s full name, authorization document, covered activity and expiry date. Confirm the document directly with İŞKUR.
show the current İŞKUR authority for the temporary-work activity itself, with its expiry date
— Onur Çalışıcı, Founding Attorney, Lex Lata, Istanbul
Who signs and files what?
In Article 7 regulated temporary supply, the private employment bureau is the employer and holds two parallel written contracts: one with the worker and one with the user employer.
| Party | Signs | Performs/checks |
|---|---|---|
| Client / user employer | The bureau–user-employer agreement; any separate commercial agreement with the provider | Directs the day-to-day work and checks that the supplied worker’s basic conditions are not below those of a comparable direct employee |
| Turkish employer / private employment bureau | The bureau–worker employment agreement and the bureau–user-employer agreement | Acts as employer in the Article 7 bureau route and completes the SGK employer filings that follow from that role |
| Employee | The employment agreement with the bureau | Performs the assigned work for the user employer under the arrangement |
The bureau’s two Article 7 agreements operate in parallel. The Labour Law separately requires a written employment contract where its term is one year or longer; Article 7 requires writing for the bureau route regardless.
SGK filing duties follow the actual employing entity. Identify the filing owner in the agreements, including any client-side obligations. Ordinarily, the electronic 4/a employee entry notice is due at least one day before work starts; the workplace notice is due no later than the first insured workday.
EOR hiring steps: from offer to first day
Confirm the employing structure, terms and any permit requirement before setting the start date. The actual employer must then meet the applicable SGK deadlines.
| Step | What happens | Takes/deadline |
|---|---|---|
| Confirm the employing structure | Identify the Turkish employing entity; if Article 7 agency supply is proposed, confirm the bureau authority and the permitted ground | Agree the setup schedule with the provider |
| Document the employment terms | Agree the gross wage and employment agreement; use the Article 7 written agreements where that bureau route applies | Confirm preparation time for the proposed contracts |
| Check the permit route, if needed | Establish whether the employee needs a work permit and prepare the relevant application | Conditional; the statutory assessment clock is separate from provider preparation |
| Meet SGK filing deadlines | File the ordinary 4/a employee entry notice electronically at least one day before work begins; file the workplace notice no later than the first insured workday | Two separate statutory deadlines |
The two SGK notices have separate deadlines; neither is a prescribed signing sequence. Obtain a provider schedule for the work that precedes these deadlines.
When a work permit changes the critical path
If a work permit is required, a first employer-tied permit may be valid for up to one year. The Ministry evaluates a complete application within 30 days from completion or from the receipt of requested additional documents; that clock does not measure the entire onboarding process.
The Ministry’s assessment criteria include two separate exceptions effective from 3 August 2026. A qualifying in-country applicant with at least one year of listed lawful stay in the preceding three years may receive an exception from employment and financial criteria for up to three workers at a workplace, subject to the Turkish-citizen headcount condition; the salary criterion remains. A separate exception for eight years of lawful stay can cover employment, financial-capacity and salary assessment criteria when the prescribed status history is proved. Neither grants a work permit automatically.
The actual cost layers of a Turkish EOR hire
The statutory baseline for a standard private-sector 4/a employee is the gross wage plus 23.75% undiscounted employer contributions, before the provider’s separately quoted charge, benefits or severance accrual.
| 2026 gross minimum wage | ₺33,030 / month | Ministry of Labour 2026 minimum wage |
| Employer pension, health, short-term insurance and unemployment shares | 12% + 7.5% + 2.25% + 2% = 23.75% of insurable earnings | SGK employer premium rates 2026 |
| 2026 monthly SGK earnings ceiling | ₺297,270 | SGK 2026 earnings limits |
| Provider charge | Obtain an itemized quote | — |
At the 2026 gross floor, ₺33,030 plus ₺7,844.63 in undiscounted employer contributions gives a monthly statutory employment cost of ₺40,874.63. Conditional incentives, wage support, benefits, severance accrual and the provider charge are excluded.
Why two quotes can differ
The 23.75% baseline applies only to insurable earnings up to the ₺297,270 monthly SGK ceiling. Eligible private-sector employers outside manufacturing may receive a two-percentage-point discount on the employer pension share, while eligible manufacturing workplaces may receive a five-point discount through 31 December 2026; timely filings and premium payments, the relevant debt position and the absence of unregistered or fictitious insured workers are among the conditions.
Separate minimum-wage support is ₺42.33 per reported premium day, or ₺1,270 for a full month, but it also has employer and earnings conditions. An itemized proposal should therefore show the gross wage, statutory employer charges, any claimed discount or support with its eligibility basis, benefits, severance treatment and the provider charge as separate lines.
The 2024 national mean gross wage of ₺34,642 and information-and-communication mean of ₺75,885 are historical observations. Used as fixed nominal inputs under the 2026 undiscounted rate, they yield ₺42,869.48 and ₺93,907.69 in monthly statutory employment cost before the same exclusions. They are not 2026 salary surveys, and the ₺297,270 ceiling is a statutory boundary rather than a market-salary benchmark.
Where the EOR model runs out
The limits depend on the legal route. A regulated bureau-supply placement remains subject to Article 7, while termination rights follow the actual employment relationship.
Duration and overrun under Article 7
For most permitted private-bureau supply grounds, the initial Article 7 placement is no more than four months and may be renewed twice, generally to eight months in total; statutory exceptions apply. The critical condition is continuation after the agreed placement end: in that case, the user employer is deemed to have an indefinite employment contract with the worker from that end date.
These private-bureau limits do not determine the terms of the separate holding or company-group route.
Exit and commercial rights
An agreed probation period is capped at two months, or four months under a collective agreement. For indefinite contracts, ordinary notice rises from two weeks for service under six months to eight weeks after three years; a qualifying termination after at least one year can bring severance calculated at 30 days’ pay per full service year, subject to the ₺73,729.87 cap for 1 July–31 December 2026. Employers with at least 30 workers must also have a valid reason to dismiss an employee with at least six months of service, subject to the statutory exceptions. The Turkey hiring guide has the full entitlement table.
The agreements should allocate the termination process and address IP, confidentiality and any non-compete. Assess permanent establishment and any work-permit sponsorship against the proposed structure; neither has a universal outcome here.
| Trigger | Consequence | Evidence |
|---|---|---|
| Bureau-supply placement continues after its agreed end | The user employer is deemed to have an indefinite employment contract with the worker from that end date | Turkish Labour Law No. 4857 |
| Temporary workers employed contrary to Article 7 | ₺4,235 per affected worker in 2026 | 2026 Labour Law penalty schedule |
| Sham subcontracting arrangement | Workers are treated as the principal employer’s from the start; the 2026 fine for registering the sham workplace is ₺302,484, separately imposed on the principal and subcontractor representatives | Turkish Labour Law No. 4857; 2026 Labour Law penalty schedule |
| Minimum-wage underpayment | ₺2,734 per affected worker per month in 2026 | 2026 Labour Law penalty schedule |
| Unpaid overtime, missing compensatory time or missing consent | ₺4,815 per affected worker in 2026 | 2026 Labour Law penalty schedule |
| Breach of working-time rules | ₺26,620 in 2026 | 2026 Labour Law penalty schedule |
When can you hire without an EOR?
You can hire through your own Turkish employing structure. Whether a foreign company can employ directly without an entity depends on the particular structure.
The Turkey hiring guide covers registration, contributions and employment rules. Turkish employment status turns on dependent work for an employer, and the party that employs under the employment contract is the employer.
Genuinely independent work follows a different route. SGK distinguishes 4/1(a) employees from 4/1(b) independent workers earning qualifying commercial or professional income in their own name and account. The Turkey contractor guide covers how to assess the actual relationship.
Which alternative fits the work?
Choose a route by identifying who will employ or contract with the person and who will direct the work.
| Route | Legal employer / contracting party | Fits when | Main check |
|---|---|---|---|
| Own Turkish employing entity | Your Turkish entity | You will employ the person directly through your own local structure | Employer registration, SGK filings and the full employment terms |
| Article 7 temporary supply | An İŞKUR-permitted private employment bureau in the bureau route | The proposed placement has a listed temporary-supply ground and the Article 7 conditions fit | Bureau authority, ground, written agreements, comparable conditions and end date |
| Another locally reviewed employment structure | The employer identified by the actual documents and arrangement | The structure does not fit the Article 7 bureau route and has been assessed on its own facts | Actual employer, supervision, subcontracting position and required filings |
| Genuinely independent contractor | The independent service provider, acting in their own name and account | The work is genuinely independent rather than dependent employment | Dependence test, the contracting party’s tax and insurance status, and the actual work pattern |
The separate Article 7 holding or company-group route needs its own assessment; private-bureau authorization, grounds and duration rules do not automatically transfer to it.
PEO, payroll administration and outsourcing describe operating models, not conclusive Turkish legal categories. For each proposal, identify the legal employer, contracts and work direction. Apply the same test before treating a services agreement as an independent relationship.
How to choose a Turkey EOR provider
Ask for documents that identify the Turkish employer and legal route.
- What is the full legal name of the Turkish employing entity, and which agreement makes it the employer?
- If the proposal is private-bureau Article 7 supply, can you provide the current İŞKUR temporary-work authorization, its activity scope and expiry date? Which permitted ground supports the placement, and what is its agreed end date? These questions apply to the bureau route, not automatically to a holding or company-group assignment.
- Can you provide both written Article 7 agreements where that route applies: the bureau–worker employment agreement and the bureau–user-employer agreement?
- Which party will file the employee entry notice and the workplace notice with SGK, and how will it meet their separate deadlines?
- If the worker needs a permit, which entity will be the employer for the application? Which work-permit assessment criteria apply, and do the 3 August 2026 exceptions have any relevance to this individual and workplace?
- Can the quote separate gross wage, statutory employer charges, any claimed incentive or support and its eligibility basis, benefits, severance treatment and the provider charge?
- Who handles an end of placement or termination, including the Article 7 consequence if a bureau-supply placement continues after its agreed end?
- What do the agreements say about IP, confidentiality, non-compete terms and the scope of any permanent-establishment analysis?
Use the documents to identify whether the proposal is regulated private-bureau supply, a group assignment or another structure requiring legal assessment.
Questions people actually ask
Is an employer of record legal in Turkey?
Turkey regulates temporary labour supply under Article 7, but an EOR label does not by itself identify the legal route. Where a private employment bureau supplies a worker to a user employer, the bureau must be İŞKUR-permitted and the listed ground, written contracts, comparable conditions and duration rules apply; other structures need assessment on their actual facts.
Does a Turkey EOR need an İŞKUR licence?
An İŞKUR temporary-work authorization is relevant when the proposal is private-bureau Article 7 supply. It is not a blanket “EOR licence” for every arrangement, and a holding or company-group assignment is a separate Article 7 route; ask for the Turkish entity’s activity-specific authorization and expiry date.
Can I hire an employee in Turkey without setting up a company?
You can use a Turkish employing route where the actual structure supports it, but whether a foreign company can employ directly without an entity requires a structure-specific analysis. A contractor agreement is not a substitute where the actual relationship is dependent employment; see the Turkey hiring guide for the local-employer route.
How long can an EOR placement last?
For most permitted private-bureau Article 7 grounds, the initial placement lasts at most four months and may be renewed twice, generally up to eight months in total; statutory exceptions apply. Those limits do not automatically describe a holding or company-group assignment or another structure called EOR.
What does it cost on top of gross salary?
For a standard private-sector 4/a employee, the undiscounted employer contribution baseline is 23.75% of insurable earnings. At the ₺33,030 2026 gross monthly minimum wage, that is ₺7,844.63 in employer contributions and ₺40,874.63 in statutory monthly employment cost before conditional incentives, wage support, benefits, severance accrual and the provider charge.
Can an EOR sponsor a work permit?
Identify the actual employer for the proposed permit application; sponsorship depends on the provider structure. A first employer-tied permit may be valid for up to one year, and the Ministry’s 30-day assessment period begins only when the application is complete or requested additional documents have been received.
What if a placement runs past its end date?
For Article 7 private-bureau supply, the consequence follows only if the placement continues after its agreed end. The user employer is then deemed to have an indefinite employment contract with the worker from that end date.
Is a PEO or contractor agreement the same?
No label decides the legal employer or the worker’s status. Establish who signs the employment or services contract, who directs the work and whether the service provider acts independently in their own name and account; those facts distinguish an employment structure, a provider-administered model and genuinely independent services.
Sources
- 4dev.com. Hiring in Turkey. Accessed 27 October 2026.
- 4dev.com. Hiring contractors in Turkey. Accessed 27 October 2026.
- 4dev.com. Employer of record. Accessed 25 October 2026.
- Ministry of Labour and Social Security. 4857 sayılı İş Kanunu (Turkish Labour Law No. 4857). Accessed 25 October 2026.
- Lex Lata. Is an Employer of Record Lawful in Türkiye?. Accessed 25 October 2026.
- Social Security Institution (SGK). İşverenin Yükümlülükleri (SGK employer obligations). Accessed 25 October 2026.
- Ministry of Labour and Social Security. Çalışma İzni Değerlendirme Kriterleri (Ministry work-permit assessment criteria). Accessed 25 October 2026.
- Ministry of Labour and Social Security. Work Permit (Ministry work-permit portal). Accessed 25 October 2026.
- Ministry of Labour and Social Security. Asgari Ücret (Ministry of Labour 2026 minimum wage). Accessed 25 October 2026.
- Social Security Institution (SGK). İşveren Prim Oranları (SGK employer premium rates 2026). Accessed 25 October 2026.
- Social Security Institution (SGK). Prime Esas Kazanç Miktarları (SGK 2026 earnings limits). Accessed 25 October 2026.
- Ministry of Labour and Social Security. 4857 Sayılı İş Kanunu 2026 Yılı İdari Para Cezaları (2026 Labour Law penalty schedule). Accessed 25 October 2026.
- 4dev.com. Countries. Accessed 25 October 2026.
- Social Security Institution (SGK). Güncel Sigorta Primi Teşvik, Destek ve İndirimleri (SGK current incentives). Accessed 25 October 2026.
- Istanbul Commodity Exchange. Monthly average gross wage, gross earnings and labour cost by economic activity, 2024 (TurkStat 2024 wage statistics). Accessed 25 October 2026.
- Ministry of Labour and Social Security. Ücret ve Sendikal İstatistikler (Ministry severance ceiling, July–December 2026). Accessed 25 October 2026.
- Ministry of Labour and Social Security. 40 Soruda İş Kanunu'ndan Doğan Tazminat Haklarımız (Ministry severance formula). Accessed 25 October 2026.
- Grand National Assembly of Turkey. Law No. 4857 (employment definition). Accessed 25 October 2026.
- Social Security Institution (SGK). Sigortalılık Statüleri (SGK insurance statuses). Accessed 25 October 2026.