C-117 and C-119 Restriction Codes Turkey: Illegal Work, Unpaid Fine

Ç-117 (C-117) and Ç-119 (C-119) are two separate restriction codes concerning foreigners who work in Türkiye without a work permit. Ç-117 shows that illegal work was detected and that deportation and an entry ban followed from it. Ç-119 points to an unpaid administrative fine imposed for illegal work. In most cases the two codes are seen one after the other, and unless payment is made, one prolongs the effect of the other.
In short: A foreigner working illegally is deported under Law No. 6458 Art. 54/1-ğ and receives an administrative fine under Law No. 6735 Art. 23/5-b. If the fine is not paid within one month, Ç-119 may be entered on the record; the governorate may make admission to the country subject to prior permission until the public receivable is paid (Art. 9/7).
What this article covers
Note: The meaning of the Ç-117 and Ç-119 codes is known from administrative practice; there is no published legislative list of the codes. Because the ban period attached to Ç-119 in particular is reported differently in different sources, the actual period on a person's record should be verified through a freedom-of-information request or the court file.
🔎 What Does the Ç-117 Restriction Code Mean?
Article 6/2 of the International Labour Force Law No. 6735 prohibits foreigners within its scope from working, and from being employed, without a work permit. A foreigner found to be working illegally during an inspection is reported by the provincial directorate of labour and employment to the provincial migration management office for deportation, under Art. 23/8 of the same Law and Art. 65 of the Implementing Regulation.
After the report, Art. 54/1-ğ of Law No. 6458 comes into play: a deportation decision is taken for "those found to be working without a work permit"; when the decision is carried out, entry into the country is also banned under Art. 9/2. Ç-117 is the record counterpart of this chain and in practice is generally mentioned together with a one-year entry ban.
Important: Holding a valid residence permit does not by itself give the right to work. Art. 12/1 of Law No. 6735 states this expressly; residence permits other than refugee and subsidiary protection status do not replace a work permit.
💳 What Does the Ç-119 Restriction Code Mean?
The administrative fine imposed for illegal work must be paid within one month of notification, under Art. 23/4 of Law No. 6735. Ç-119 is entered on the record of a foreigner who leaves the country, or is deported, without paying the fine. An unpaid fine is a public receivable and is pursued under Law No. 6183.
Article 9/7 of Law No. 6458 provides that, because of administrative fines and public receivables, governorates may make the admission of foreigners to the country subject to prior permission. The practical effect of Ç-119 is therefore that the foreigner is not admitted at the border gate until the debt is paid. The fact that sources report the period attached to this code anywhere between one and five years also stems from the period depending largely on the payment situation.
Article 8/2-ç of the Regulation further provides that a foreigner who is deported with travel costs met from the Migration Management budget may be refused entry if the foreigner does not pay those costs. An unpaid travel cost may therefore also exist alongside Ç-119.
🧾 The Administrative Fine and the Employer's Position
Article 23/5-b of Law No. 6735 attaches three separate fines to illegal work: to a foreigner working for an employer, to a self-employed foreigner, and to the employer who employs the foreigner, for each foreigner separately. The fine on the employer is higher than the fine on the foreigner, and in case of repetition the fines are increased by one fold (Art. 23/6). The amounts are determined by updating the base figures in the Law every year with the revaluation rate.
The Law also places part of the cost on the employer: under Art. 23/9, the employer must cover the accommodation, return to the home country and, where necessary, health expenses of a foreigner without a work permit and, if any, of the spouse and children; if these are paid from the Migration Management budget, they are collected from the employer under Law No. 6183. The employer's obligations are covered in the article on work permit applications and employer obligationsTR.
🔀 How It Differs From Ç-116
Ç-117 and the Ç-116 restriction code are often confused. Ç-116 is based on the ground of earning a living by illegitimate means (Art. 54/1-ç) and is mentioned with a longer ban. Ç-117, on the other hand, concerns only unauthorised work (Art. 54/1-ğ); the work done is legitimate in itself, and what is missing is the permit. Which sub-paragraph was applied in the record directly affects how a case is built and its chances.
⚖️ Objection and Court Routes
- Administrative fine: Since Law No. 6735 does not provide a separate route of appeal, the general provision, Art. 27 of the Misdemeanours Law No. 5326, applies; an application may be made to the criminal judgeship of peace within fifteen days of notification.
- Deportation decision: An action is brought before the administrative court within seven days of notification (Law No. 6458 Art. 53/3); during the action the foreigner is not deported against their will. Details: deportation and objectionTR.
- Entry ban: The general sixty-day period for bringing an action (Administrative Procedure Law Art. 7) runs against the ban.
- Payment and re-entry: The effect of a Ç-119 record often ends once the debt is paid. If a compelling need to enter arises while the ban continues, the endorsed visa route may be assessed separately.
Related articles: Ç-101, Ç-102, Ç-103, Ç-104, Ç-105 Restriction Codes, entry bans and restriction codesTR, work permits for foreignersTR.
❓ Frequently Asked Questions
I have a residence permit but no work permit; will Ç-117 be entered if I work?
Is the Ç-119 code lifted once payment is made?
Is the employer's fine also written against me?
What applies when Ç-117 and Ç-119 exist together?
For information on the Ç-117 and Ç-119 restriction codes, you can contact Savun Law & Consultancy.
This page is an English adaptation of our Turkish article Ç-117 ve Ç-119 Tahdit Kodu: Kaçak Çalışma ve Ödenmeyen Ceza.
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