Restriction codes based on “public security”, such as Ç-184 and Ç-141, are often entered against foreign nationals without any concrete act being shown, and they can last for years. Turkish courts increasingly require the administration to support such entry bans with concrete and sufficient information. In two judgments of 28 January 2026, the Constitutional Court reaffirmed this line from the perspective of both family life and the right to a fair trial.
What is a restriction code?
A restriction code (tahdit kodu) is a record in the system of the Presidency of Migration Management that bans a foreign national’s entry into Turkey or makes it subject to permission. Foreign nationals usually learn of it only when they are turned back at the border. Some “Ç” codes seen in administrative records and case files are described as follows:
| Code | Description in the records | Meaning in practice |
|---|---|---|
| Ç-138 | Precautionary record for an inadmissible passenger (INAD) | Entered at the border by risk analysis units |
| Ç-141 | Considered objectionable for international security | Usually a 5-year entry ban |
| Ç-184 | INAD passenger on public security grounds | Usually a 5-year entry ban; also used to “re-issue” bans that have expired |
There is no official public list of the codes; their meaning is learned from the administration’s own records and case files. The first step is therefore to request, in writing, the record and its legal basis from the administration.
Legal framework
Entry bans are based on Article 9 of the Law on Foreigners and International Protection No. 6458. Judicial review is shaped by Article 20 of the Administrative Procedure Law No. 2577 (İYUK).
- Power (Law 6458 Art. 9/1): the Migration Administration may, where necessary after consulting the relevant institutions, ban the entry of foreign nationals whose entry is considered objectionable for public order, public security or public health.
- Duration (Art. 9/3): an entry ban may last up to five years. Only where there is a serious threat to public order or public security may it be extended by up to ten more years.
- Lifting and temporary permission (Art. 9/6): the administration may lift the ban or, while keeping it, permit entry for a specified period.
Two consequences follow. First, a ban must rest on an individual assessment. Second, a ban exceeding five years requires the additional “serious threat” condition. “Re-issuing” an expired ban without any new fact can, in practice, amount to circumventing that condition.
- İYUK Art. 20: courts examine cases of their own motion and may request documents from the parties. Information and documents concerning state security or high state interests may be withheld only by the President, the relevant Vice President or the relevant Minister, with reasons. In that case, no decision may be based on a defence relying on the withheld information and documents.
In practice, the administration often merely refers to “intelligence information” without placing the documents in the file. Article 20/3 makes clear that a ban cannot be upheld on the basis of documents that were not submitted.
Common problems in practice
- General “profiling”: some records rely not on individual information but on risk analysis based on general criteria such as nationality, age or travel route. Administrative letters use speculative language that the person “may have” come for a certain purpose; this is not a finding of fact.
- Collective decisions: a ban may be imposed by a collective approval that does not even name the person and merely refers to an attached list. The file may then contain no individual assessment at all.
- “No objection” opinions: an intelligence unit’s statement that it has “no objection to the entry being made” is not a finding of a threat but a notice that there is no objection.
- Renewal of expired bans: after the five-year period expires, a new code may be entered on the same grounds without any new fact. This should be assessed against the “serious threat” condition in Art. 9/3.
- Incomplete replies to interim orders: when the court asks for the basis of the ban, the administration often sends only system printouts and summary letters, not the underlying intelligence documents.
- Lack of notification: the ban is usually not notified to the foreign national, who learns of it at the border.
Each of these points is a concrete argument that can be raised in an annulment action against the “reason” element of the administrative act.
Case law
Decisions of the Council of State and the Constitutional Court converge on two points: the administration must support an entry ban with concrete and sufficient information, and secret documents relied on in the judgment cannot be withheld from the claimant without justification.
- Council of State, 10th Chamber, E. 2018/3756, K. 2023/3866: the entry ban on an Italian national was based on intelligence information stemming from an Interpol-Europol notice. The Chamber requested information by interim order; the National Intelligence Organisation replied that it held no information of the kind requested. The Chamber concluded that there was no concrete finding justifying the ban.
- Constitutional Court, A.G. [2nd Section], App. No. 2018/6143, 16/12/2020: concerning an entry ban on a foreign national living in Turkey with his Turkish wife and four children, the Court held that the administration’s abstract intelligence defence and the lower court’s acceptance of it, without balancing the public interest against family life, violated the right to respect for family life (Constitution Art. 20). The State may ban entry on security grounds, but must provide sufficient and serious information, and the court must assess it with reasons.
- Constitutional Court, Bılal Padalı Chasanoğlu [1st Section], App. No. 2021/14332, 28/1/2026: a Greek national was turned back at the border because of a G-82 code. The Court found that the administration relied on abstract intelligence information, that the court accepted the national security argument without requiring sufficient detail, and that no balance was struck between family life and the public interest, and found a violation of the right to respect for family life.
- Constitutional Court, V.C. [1st Section], App. No. 2020/20798, 28/1/2026 (Official Gazette 2/4/2026, No. 33212): in a promotion dispute, a “confidential” note submitted by the administration in a sealed envelope was never shown to the claimant. The Court found a violation of the principles of equality of arms and adversarial proceedings (Art. 36). The case does not concern an entry ban, but its principles on secret evidence apply directly to restriction code cases.
- Constitutional Court, Bünyamin Uçar [1st Section], App. No. 2017/32004, 3/6/2020: in an administrative case based on secret security investigation documents, the applicant’s inability to respond to documents relied on in the judgment violated the adversarial principle.
- Constitutional Court, Rıdvan Batur [1st Section], App. No. 2018/17680, 3/12/2020: the claimant’s lack of knowledge of the administration’s documents until judgment, and the absence of any effective opportunity to challenge them, amounted to a violation.
In practice: where the foreign national has family in Turkey, a violation of family life under Article 20 can be argued; in every case, the use of secret documents can ground a fair trial complaint under Article 36. For foreign nationals without family ties in Turkey, the emphasis should be on Council of State case law and İYUK Art. 20/3.
The process, step by step
- Learn the record: request the code, its date, duration and legal basis from the Migration Administration in writing.
- Application to lift: under Art. 9/6, request that the ban be lifted or that entry be permitted for a specified period, documenting previous trouble-free entries and professional and family circumstances.
- Annulment action: if the application is rejected or left unanswered, file an action before the competent administrative court against the rejection and the underlying entry ban. The time limit follows the general rules of İYUK; the date of notification of the rejection should be carefully recorded.
- Stay of execution: request a stay by showing both clear unlawfulness and harm that would be difficult to remedy.
- Interim order and response: the court usually asks the administration for the basis of the ban. When the reply arrives, examine each document: whether it contains an individual finding, which documents are missing, and the position under İYUK Art. 20/3, and set this out in a written response.
- Appeals and individual application: after the judgment, appeal and, where available, cassation follow. Once ordinary remedies are exhausted, an individual application to the Constitutional Court is possible. See our article on individual applications against deportation.
Frequently asked questions
Does a Ç-184 code lapse automatically when it expires? The record is time-limited, but in practice expired bans are sometimes re-issued. The current status should be checked with the administration.
Does a previous Turkish visa matter? Yes. A visa issued by a Turkish consulate between ban periods is an important fact showing that the State did not then consider the person’s entry objectionable.
What if the administration says the information is secret? Under İYUK Art. 20/3, secrecy may be invoked only by a reasoned decision of the competent authority, and no decision may be based on withheld documents. The Constitutional Court also treats the unjustified withholding of secret documents relied on in the judgment as a rights violation.
Can a foreign national without family in Turkey apply to the Constitutional Court? Yes, but since a family life complaint is not available, the focus should be on the right to a fair trial, particularly the use of secret documents.
General information only; not legal advice. Each case must be assessed on its own facts. Code descriptions are based on wording seen in administrative records and case files; no official list has been published. Sources: Law No. 6458 Art. 9; Law No. 2577 (İYUK) Art. 20; Council of State 10th Chamber, E. 2018/3756, K. 2023/3866; Constitutional Court, A.G., App. No. 2018/6143 (Official Gazette 25/2/2021, No. 31406); Bılal Padalı Chasanoğlu, App. No. 2021/14332; V.C., App. No. 2020/20798; Bünyamin Uçar, App. No. 2017/32004; Rıdvan Batur, App. No. 2018/17680. Full texts: Constitutional Court decisions database.