Significant amendments have been introduced to the procedures and principles governing the evaluation of investment projects within the scope of financing programs through the “Communiqué Amending the Communiqué on the Strategic Prioritization and Technical Evaluation of Investment Projects,” published in the Official Gazette dated 3 September 2026 and numbered 33359.

The amendment preserves the existing Technological and Strategic Projects (“TSP”) Certificate while introducing a new evaluation mechanism, the “Priority Financing Certificate.” As a result, investment projects seeking access to financing programs will now be assessed through two separate Ministry evaluation channels, depending on the nature of the investment: one through the TSP Certificate and the other through the Priority Financing Certificate.

The TSP Certificate remains relevant for certain projects relating to the Türkiye Century Development Initiative, project-based state aid, products included in the Strategic Priority Product List, technology fields included in the Technology Fields List, and items included in the Critical Raw Materials List. At the same time, the Priority Financing Certificate establishes a new financing evaluation channel, particularly for investments in the manufacturing industry.

TSP Certificate and Priority Financing Certificate

Under the Communiqué, the TSP Certificate continues to apply to investments within the scope of the Türkiye Century Development Initiative, as defined in the Decision on State Aid for Investments enacted by Presidential Decision No. 9903 dated 29 May 2025, or investments within the scope of the Decision on Granting Project-Based State Aid to Investments enacted by Council of Ministers Decision No. 2016/9495 dated 17 October 2016, as well as to projects that meet the qualifications determined under the Strategic Priority Product List, the Technology Fields List, and the Critical Raw Materials List.

The newly introduced Priority Financing Certificate creates a separate channel for investors holding an investment incentive certificate for the manufacturing industry to obtain the Ministry’s evaluation before applying to financing programs. The certificate indicates that the allocation of credit is deemed appropriate for the relevant project in line with the priority criteria determined by the Ministry.

The Priority Financing Certificate is not an investment incentive certificate under the Communiqué. Rather, it is granted following the Ministry’s evaluation before the application to the relevant financing program. Investors wishing to benefit from a financing program must apply to the intermediary bank together with the TSP Certificate or Priority Financing Certificate obtained from the Ministry.

The Regulation also provides specific exceptions for TSP Certificate applications submitted without an investment incentive certificate. Investors that are not able to benefit from support measures under the investment incentive legislation may apply for a TSP Certificate for projects falling within subparagraph (b) of the first paragraph, even if an investment incentive certificate has not yet been issued. In addition, for projects for which an invitation letter has been issued or a support decision has been adopted under subparagraph (a) of the first paragraph, applications and preliminary applications may be evaluated before the incentive certificate is issued. For these projects, however, the final application evaluation is conducted only after the incentive certificate has been issued.

Investors seeking to obtain the Ministry’s evaluation regarding their projects prior to applying for financing are expected to submit their applications through the electronic portal established by the Ministry.

A New Evaluation Channel for a Broader Group of Investors

One of the key differences between the two certificates concerns the investment amount thresholds. While the minimum investment amount for the TSP Certificate is set at TRY 1 billion, this amount is determined as TRY 100 million for the Priority Financing Certificate. In addition, while TSP Certificate applications require the equity or paid-in capital shown in the balance sheet for the most recently completed fiscal year to be at least TRY 50 million, no separate financial sufficiency requirement of the same nature is envisaged for the Priority Financing Certificate. These investment amounts are taken into account based on the projected total investment amount, including R&D expenditures, as of the application date.

This distinction indicates that the Priority Financing Certificate offers an application opportunity based on a lower minimum investment amount compared to the TSP Certificate. In particular, a new evaluation channel has emerged for investments in the manufacturing industry that do not meet the investment size envisaged for the TSP Certificate, but that are TRY 100 million or more and satisfy the other conditions set out in the Communiqué.

However, it should be noted that the minimum investment requirement of TRY 100 million alone is not sufficient to obtain a Priority Financing Certificate. For investments falling within the scope of Annex-5, a Priority Financing Certificate is issued without any additional evaluation, whereas for other applications, scoring is carried out according to the criteria set out in Annex-6, and a Priority Financing Certificate is issued for those receiving 50 points or more.

Differentiated Process for Investments within the Scope of Annex-5

Annex-5, added to the Communiqué through the amendment, constitutes one of the significant elements of the Priority Financing Certificate system. Annex-5 covers Project-Based State Aid, the Technology Initiative Program, the Local Development Initiative Program and the Strategic Initiative Program under the Türkiye Century Development Initiative, as well as the incentive of strategic investments under the repealed Decision No. 2012/3305.

For investments holding an investment incentive certificate within the scope of Annex-5, a Priority Financing Certificate will be issued without applying the Annex-6 scoring system or conducting an additional evaluation. Accordingly, no separate scoring process is required at the Priority Financing Certificate stage for investments already covered by the relevant incentive programs.

This differentiated procedure means that investments within the scope of Annex-5 are not subject to an additional scoring or evaluation stage at the Priority Financing Certificate phase.

Scoring-Based Evaluation under Annex-6

For Priority Financing Certificate applications that do not fall within the scope of Annex-5, the evaluation criteria set out in Annex-6 will apply. For a Priority Financing Certificate to be issued in such applications, the investment must receive at least 50 points according to the relevant criteria.

The Annex-6 criteria ensure that the investment amount is not the sole determining factor. The evaluation also takes into account the economic and technological characteristics of the project, including value added and technology level, sectoral impact, capacity utilization rate, type of investment, stage of completion, export/turnover ratio, location in an Organized Industrial Zone or Industrial Zone, and indicators relating to R&D and innovation capacity.

This structure includes elements that may provide points in the evaluation, particularly for companies operating in fields included in the Medium-High and High Technology List, companies that have an R&D or Design Centre, companies with a branch in a techno park, companies that have successfully completed a TÜBİTAK project within the last five years, or companies that have had at least one patent registered within the last five years. Similarly, the fact that more than 20% of the investment has been completed, that the average export/turnover ratio for the last three years exceeds 10%, and that the investment is located in an Organized Industrial Zone or Industrial Zone are also among the criteria taken into account under Annex-6.

In this framework, the system attaches importance not only to the investment amount, but also to indicators relating to the technology level of the investment project, its sectoral impact, export capacity, stage of completion, and the company’s R&D and innovation capabilities.

The fact that the scoring criteria are set out in the annex to the Communiqué also provides investors with the opportunity to assess their own projects before applying and to prepare the information and documents supporting the application accordingly. For this reason, for investments within the scope of Annex-6, it will be important to prepare the application not only in terms of formal requirements, but also by taking into account all of the scoring criteria.

Prioritization of Financing Resources

The new system also addresses the possibility that resources allocated to financing programs may be limited. If the Financing Program is terminated or suspended, or if the limits allocated to the program are exhausted, the acceptance of new applications may be discontinued following the relevant announcement. Where deemed necessary, existing Priority Financing Certificate applications that have been scored may also be ranked by score and evaluated starting from the highest-scoring application.

Accordingly, obtaining 50 points or more under Annex-6 does not, in all cases, mean that the applicant will actually benefit from the financing program. Particularly where financing resources are limited and applications are ranked based on their scores, the score obtained may affect the order in which applications are evaluated.

This matter increases the importance of project preparation for investors. Properly and sufficiently demonstrating R&D and technology capacity, export performance, investment location, completion status and other scoring elements at the application stage may be significant not only for the issuance of the Priority Financing Certificate, but also for any possible score-based ranking among applications.

Combined Use of Financing Support and Incentive Elements

The amendment to the Communiqué also includes a provision limiting duplicate support for the same financing cost. Investors benefiting from the Financing Program will not be provided with separate interest or profit share support under the relevant incentive certificate in respect of interest or profit share payments arising from such financing.

Therefore, when structuring their financing arrangements, investors will need to assess not only the eligibility requirements for the Priority Financing Certificate or the TSP Certificate, but also the relationship between the financing program and the existing investment incentive elements.

Strategic Stock Arrangement for TSP Project Size

The amendment also enables the amount invested by the project owner in strategic stocks relating to the final products or intermediate inputs that are the subject of the investment to be included in calculating the TSP project size, where deemed appropriate by the Technical Committee.

This provision is also of particular importance for investments within the scope of the TSP, as it allows investments in strategic stocks relating to strategic products or intermediate inputs to be taken into account in calculating the project size.

Importance of the Regulation for Investors

One of the most significant consequences of the amendment to the Communiqué for investors is that, in addition to the TSP Certificate, a separate evaluation channel through the Priority Financing Certificate has been established for investment projects that may be subject to the Ministry’s evaluation within the scope of financing programs. For manufacturing industry investments that do not meet the TRY 1 billion minimum investment amount envisaged for the TSP Certificate, but that meet the TRY 100 million minimum investment amount envisaged for the Priority Financing Certificate and satisfy the other conditions under the Communiqué, a new evaluation channel is now available.

In addition, the regulation emphasizes not only the monetary size of the investment, but also its economic and technological nature. The inclusion of elements such as R&D and design activities, patents, technology level, export performance, stage of completion of the investment, and the sectoral impact of the investment in the scoring system enables project and company characteristics to be taken into account more comprehensively in the evaluation of financing program applications.

The non-application of the scoring process for investments within the scope of Annex-5 ensures that no additional evaluation stage is applied for projects holding incentive certificates issued under certain priority investment programs. For investments within the scope of Annex-6, the fact that the criteria have been predetermined allows investors to assess, before applying, the elements on the basis of which their projects will be scored.

Nevertheless, the new system should not be regarded as a process consisting merely of obtaining a certificate. After obtaining the certificate, the investor must apply for financing to the intermediary bank under the relevant Financing Program. In addition, the possibility that new applications may cease to be accepted if program limits are exhausted, and that existing applications may be ranked according to their scores where deemed necessary, makes it important for investors to prepare their application processes and project submissions carefully.

Concluding Remarks

The amendment to the Communiqué on the Strategic Prioritization and Technical Evaluation of Investment Projects creates a more differentiated evaluation structure for access to financing programs by introducing the Priority Financing Certificate alongside the existing TSP Certificate.

In particular, the creation of a new evaluation opportunity for manufacturing industry investments based on a minimum investment amount of TRY 100 million establishes a new application channel for certain investments that fall below the TRY 1 billion investment threshold envisaged for the TSP Certificate. At the same time, it is also noteworthy that, for TSP Certificate applications, in certain cases, applications and preliminary evaluations may be conducted even if an investment incentive certificate has not yet been issued.

The differentiated process envisaged for investments within the scope of Annex-5 and the 50-point evaluation model under Annex-6 provide for two separate evaluation methods depending on the nature of the investments.

Under the new structure, alongside investment size, factors such as technology and value-added level, export performance, R&D and innovation capacity, the location of the investment, and stage of completion also gain importance, making it necessary for financing program applications to be prepared in a more comprehensive and strategic manner.

In this context, investors should first determine whether their projects fall under the TSP Certificate or the Priority Financing Certificate. For Priority Financing Certificate applications, they should also assess whether the project falls within Annex-5 or Annex-6. Where Annex-6 applies, investors should review the scoring criteria in detail before applying and prepare the documents needed to substantiate the relevant scoring elements. Financing program limits, possible score-based rankings, and the restriction on duplicate support for the same financing cost should also be considered at the financing planning stage.

@Zeynep EMİROĞLU