Table of Contents1. Introduction: A Growing Pattern of Legal Harassment and Persecution of Foreign Christians in Turkey 2. Christian Population in Turkey: Sharp Decline, Foreigners at Risk 3. Who are the Foreign Christians Targeted by Turkey?3.1 Western Missionaries and Church Workers 3.2 Spouses of Turkish Citizens 3.3 Refugees Converted to Christianity 4. Legal Framework Used to Expel Foreign Christians from Turkey and Undermine Domestic Christianity 4.1 Turkish Immigration Law: N-82 and G-87 Restrictions 4.2 Systematic Expulsions as a Tool to Undermine Domestic Christianity 5. Justice Denied in Turkish Courts 5.1 Amanda Jolyn Krause and Others (2024)5.2 Dave and Pamela Wilson 5.3 Rachel and Mario Zalma 5.4 David Byle 5.5 Expulsion of Spouses of Turkish Nationals: Subasiguller Case 6. Seeking Redress Before the ECtHR 6.1 Cox v. Turkey (2010)6.2 Bremner v. Turkey (2015)6.3 Wiest v. Turkey (pending)7. Expulsion of foreign Christian Converts 7.1 Violations of Non-Refoulement and Persecution upon Return 7.2 M.B. and Others v. Turkey (2010)8. International Protections for Christian Foreigners in Turkey 8.1 The Treaty of Lausanne 8.2 The European Convention on Human Rights and the International Covenant on Civil and Political Rights 9. Recommendations to Protect Religious Freedom for Christians in Turkey 9.1 The Turkish Government Has to Protect the Religious Freedom of Foreign Nationals 9.2 The Council of Europe Has to Hold Turkey Accountable for Systemic Violations of Religious Freedom 9.3 The European Union Has to Leverage Its Political and Financial Instruments to Defend Religious Freedom in Turkey 10. How the ECLJ Defends Persecuted Christians in Turkey 10.1 In General 10.2 The Andrew Brunson Case: Symbol of Religious Repression in Turkey 10.3 ECLJ Intervention in the Kenneth Wiest Case at the ECtHR 11. Conclusion: Ending the Systematic Persecution of Foreign Christians in Turkey 12. Frequently asked questions 12.1 What is the legal status of foreign Christians in Turkey?12.2 What are N-82 and G-87 travel bans?12.3 What international laws protect Christians in Turkey?12.4 Who are the victims of religious persecution in Turkey?12.5 How is the ECtHR responding to Turkey’s persecution of foreign Christians?13. Pictures of victims

Article Completion

For several years, Turkey has pursued a policy of systematic harassment against foreign Christians under the so-called guise of national security. Arbitrary expulsions, entry bans, and intrusive surveillance aim to eliminate the Christian activity, particularly Protestant activity. This quiet yet targeted persecution, though in clear violation of Turkey’s international commitments, is tolerated—if not justified—by national courts. This article exposes the mechanisms behind this repression, highlights emblematic cases, and outlines avenues for legal and diplomatic response.

1. Introduction: A Growing Pattern of Legal Harassment and Persecution of Foreign Christians in Turkey

Since the founding of the Republic of Türkiye (hereinafter Turkey), the government has subjected non-Muslim religious minorities to legal and cultural discrimination. The Turkish government is now using state laws to override international agreements, leading to the slow eradication of all foreign Christians in Turkey.

The purpose of this report is to draw attention to the rapidly increasing ill-treatment of foreign Christians through unjustified means and encourage stricter enforcement of the preexisting international agreements that guarantee fundamental human rights.

This report provides a brief demographic overview of Christian groups in Turkey, discusses the laws designed to protect the rights of these groups, and summarizes cases that highlight the variety of outcomes Christians face when bringing their cases before the Turkish National Court and the European Court of Human Rights (ECtHR).

2. Christian Population in Turkey: Sharp Decline, Foreigners at Risk

Out of the approximately 86.3 million citizens of Turkey, less than 0.3% are Christian.[1] This number plummeted from around 20% in the early 20^th century to less than 0.3% today.[2] Despite the Christian population consisting of a variety of denominations, the Turkish government has only officially recognized three religious minorities: Armenian Apostolic Orthodox Christians, Greek Orthodox Christians, and Jews.[3] Limiting the recognition of religious minorities to only three groups has allowed the Turkish government to dismiss any responsibility for upholding the rights of other groups who are also minorities.[4]

Additionally, Turkey hosts an array of foreigners. In 2025, the U.N. Migration group recorded 4.1 million foreigners in Turkey, approximately 1 million of whom possess residence permits and 3 million of whom are refugees seeking international protection.[5] No official data documents the religious composition of the foreigners residing in Turkey.

Between 2019 and 2024, 132 foreign Christians were expelled from Turkey after having received an entry ban code, and the number of Christians expelled rises to 303 if one includes the 52 spouses and 119 minor children who had to leave in order not to separate their families.[6] In recent years, cases criticizing such expulsions have been brought before the highest courts of Turkey as well as international institutions with greater frequency.[7] Beginning with the arrest of Pastor Andrew Brunson in 2016, foreign Christians have experienced arbitrary punishments for participating in Christian activities that are otherwise considered legal in Turkey.[8]

Some notable cases before the ECtHR include Cox v. Turkey (2010), M.B. and Others v. Turkey (2010), Bremner v. Turkey (2015). One case is currently pending before the ECtHR (Kenneth Wiest v. Turkey), around twenty cases have been submitted (including Rachel and Mario Zalma, David and Pamela Wilson, David Byle[9]), and two cases have not yet been brought before the ECtHR (Amanda Jolyn Krause and Others, Joy Subasiguller). There have been no equivalent measures against foreign Muslim missionaries.[10]

3. Who are the Foreign Christians Targeted by Turkey?

The foreign Christians targeted by Turkey are primarily Protestant missionaries and church leaders, but also lay-person believers, spouses of Turkish citizens, and refugees who have converted to Christianity. These individuals come from various national backgrounds—including Americans, South Koreans, Germans, Australians, Canadians, and Iranians—and often play active roles in Christian communities across Turkey.

3.1 Western Missionaries and Church Workers

Since the 2016 coup attempt, Turkey has intensified its use of migration and security laws to monitor and restrict foreigners, with Christian missionaries and pastors increasingly branded as potential threats. This securitization, combined with rising nationalism and hostility toward religious minorities, has led to a marked increase in the expulsions of foreign Christians. Many were long-term residents who had lived peacefully in Turkey for years, often raising families there. These individuals have been:

Placed under entry bans (notably via the N-82 restriction code),
Labeled as threats to public order and security without concrete evidence,
Denied legal remedies in Turkish courts.

3.2 Spouses of Turkish Citizens

Even foreign spouses of Turkish Christians are not spared. One notable case is Joy Subasiguller, an American woman married to a Turkish Protestant pastor and mother of three Turkish children, who was deported without formal charges. These cases demonstrate how Turkey leverages certain people’s status as “foreigners” to target Christian families and pressure Turkish citizens involved in church life.

3.3 Refugees Converted to Christianity

Christian converts from Iran, Afghanistan, and other Muslim-majority countries are also targeted. These individuals seek asylum in Turkey due to religious persecution in their home countries. Contrary to the treatment of Muslim refugees, Christian refugees in Turkey often face[11]:

Hostile or uninformed attitudes from officials during refugee interviews,
Questions challenging or dismissing the legitimacy of their conversion,
Deportation, in violation of the principle of non-refoulement under international law, as many of these converts risk execution, imprisonment, or torture upon return to their home countries.[12]

4. Legal Framework Used to Expel Foreign Christians from Turkey and Undermine Domestic Christianity

4.1 Turkish Immigration Law: N-82 and G-87 Restrictions

Law No. 6458 on Foreigners and International Protection, adopted in 2013, provides the Turkish authorities with broad discretion to restrict the presence of foreigners.[13] Articles 7, 15, 32, 33, and 45 stipulate that any foreigner deemed a threat to “public order or safety” may be denied a visa, refused entry, stripped of existing residence permits, and barred from obtaining long-term residence.[14] In practice, these provisions have become powerful tools to curtail the activities of Christian foreigners under the guise of national security.

Two codes are systematically used to enforce these restrictions.[15] The G-87 code is applied where the authorities merely suspect that an individual poses a danger to national security.[16] While most “G” codes relate to proven criminal activity, G-87 rests solely on intelligence “data” from the National Intelligence Organization (Millî İstihbarat Teşkilatı, MIT). No corroborating evidence is required. Once imposed, it triggers immediate deportation and an automatic entry ban.

The N-82 code functions differently but with equally severe consequences. It requires foreigners to obtain prior authorization before re-entering Turkey. Formally, individuals can apply to the Directorate General of Migration Management for permission. In reality, applications are consistently denied, transforming the restriction into a de facto permanent ban.[17] Thus far, no case has resulted in successful reentry: every rejection has led to indefinite exclusion.

The scale of the policy underscores its systematic nature. Between 2019 and 2024, 132 Protestants reported receiving entry ban codes. Nearly all were issued under the N-82 code. Individuals who received the code more than five years ago and attempted to re-enter Turkey as tourists have also been turned back, demonstrating that this “temporary” measure in fact functions as a potential lifetime ban. A smaller number of Protestants, although having no criminal record, no investigations against them, and no evidence presented in court, have been assigned the G-87 code, which in other countries is reserved for individuals engaged in terrorism, armed conflict, or violent extremism.

Although Turkish law ostensibly provides for administrative appeals and judicial review, these remedies are hollow. The decisive evidence—classified MIT reports—is never disclosed to the individual or their lawyers. Courts, instead of scrutinizing these secret files, defer blindly to the executive. This mechanism deprives defendants of any possibility to contest the allegations against them and constitutes a flagrant violation of due process. It also nullifies the right to an effective remedy under international human rights law, including Articles 6 §1 and 13 of the ECHR, and Article 1 of Protocol No. 7 in the case of expulsions.

These codes have been widely deployed against foreign Christians who had lived peacefully in Turkey for years, often married to Turkish citizens and raising children there. Their only “offense” was to engage in lawful religious or community work. Branded as security threats without evidence, they have been expelled or excluded in ways that devastate their families and congregations. Such branding deeply wounds not only those affected but the community as a whole.

4.2 Systematic Expulsions as a Tool to Undermine Domestic Christianity

The expulsions of foreign Christians are not random administrative acts but form part of a deliberate strategy. By systematically and only targeting pastors, missionaries, and lay leaders, the Turkish authorities are striking at the structural heart of Protestant communities. Many churches in Turkey rely heavily on foreign Christians for pastoral leadership, theological training, and community support. Removing them leaves congregations leaderless, vulnerable, and more easily intimidated.

This strategy also sends a calculated warning to Turkish citizens who have converted to Christianity or who maintain ties with foreign believers. The underlying message is unmistakable: Christianity is foreign, illegitimate, and dangerous. By designating foreign pastors as threats to national security, the authorities stigmatize not only their activities but also the Turkish Christians who worship and serve alongside them.

The logic underpinning this approach is profoundly troubling. If foreign Christians are accused of committing “crimes” against Turkey, with whom could they possibly be committing them? Inevitably, suspicion is cast on the domestic Protestant community. This fosters an atmosphere of intimidation in which local believers fear surveillance, harassment, and even criminalization simply for exercising their faith in fellowship with foreigners.

The consequences extend far beyond the targeted individuals. In 2025, Turkish law continued to prohibit the training of Christian clergy or establishing institutions for religious education. Yet the right to train and appoint religious leaders is one of the core pillars of freedom of religion or belief (Article 9 of the ECHR). Lacking this right, the Protestant community has improvised fragile solutions: apprentice-style training, small-scale seminars, sending students abroad, or relying on the support of foreign clergy. As these foreigners are increasingly deported or denied entry, even these makeshift structures collapse, leaving congregations without qualified leadership.

The human cost of this policy is devastating. Many of those expelled or banned had lived in Turkey for decades, raising families and contributing peacefully to their communities. When one family member suddenly receives an N-82 or G-87 code, family unity is torn apart, leaving spouses and children in legal and emotional limbo. In some cases, even when courts ordered the revocation of codes or the renewal of residence permits, the authorities refused to comply, cancelling documents or reimposing bans. Families were forced to appeal to the Constitutional Court, and when denied justice there, to turn to the European Court of Human Rights.

This dual dynamic—forced, discriminatory, and unlawful expulsions on the one hand, silent attrition on the other—is eroding Protestant Christianity in Turkey from within. The following cases demonstrate how Turkey has used the N-82 and G-87 codes to target foreign Christians, with measures that are arbitrary in law and devastating in effect.

5. Justice Denied in Turkish Courts

5.1 Amanda Jolyn Krause and Others (2024)

On 15 February 2024, the Constitutional Court of Turkey delivered its judgment in Amanda Jolyn Krause and Others (App. No. 2019/40761), concerning nine Protestant foreigners from the United States, Germany, and Australia.[18] All had lived legally in Turkey with residence permits until they were flagged with the N-82 code, based on undisclosed reports from the National Intelligence Organization (MIT). The MIT systematically regards any non-Turkish member of the Protestant community in Turkey as a spy.[19] This N-82 code led to the refusal of residence permit renewals, deportation orders, or denial of visas when applicants tried to re-enter Turkey.

The main activities cited were participation in Protestant gatherings, missionary work, and in some cases attendance at the 2019 Family Conference organized by the Association of Protestant Churches, with the participation of 120 individuals, primarily from the United States, Germany, and the United Kingdom. None of the applicants were charged with any criminal offenses, and no criminal investigations were ever initiated against them.

The applicants claimed violations of freedom of religion (Article 24 of the Constitution; Article 9 ECHR), freedom of assembly (Article 34 of the Constitution; Article 11 ECHR), private and family life (Article 20 of the Constitution; Article 8 ECHR), the right to a fair trial (Article 36 of the Constitution; Article 6 §1 ECHR), the right to an effective remedy (Article 40 of the Constitution; Article 13 ECHR), the procedural safeguards in expulsion (Article 1 of Protocol No. 7), and the prohibition of discrimination (Article 10 of the Constitution; Article 14 ECHR). They argued that they had never been informed of the concrete allegations against them and that missionary activity is lawful in Turkey.

The majority rejected these claims. It reasoned that, since the applicants had not been prevented from worship while in Turkey, their freedom of religion had not been interfered with; accordingly, this part of the application had to be declared inadmissible as supposedly ill-founded. On the right to an effective remedy, it held that judicial review before administrative courts was sufficient, even though the decisive intelligence reports were never disclosed to the applicants or their counsel. Crucially, the Court relied on the doctrine of state sovereignty in immigration and national security matters, holding that Turkey has a broad discretionary power to admit or exclude foreigners. By elevating sovereignty to this level, the Court effectively placed Turkey outside the law in the sense that international and constitutional protections become inapplicable whenever the state invokes security.

Out of 13 judges sitting, nine issued dissents. Six of them, including President Zühtü Arslan, considered that the applicants’ rights had been violated. They underlined that peaceful missionary activity and conference attendance are forms of religious expression protected by both the Constitution and the ECHR, and cannot be assimilated to a public order threat without concrete evidence. For them, freedom of religion requires not only the right to worship privately but also the right to participate in collective religious life, including evangelism. They further argued that judicial remedies are illusory when courts cannot examine the evidence and the applicants cannot know the accusations. They also stressed that effective judicial protection demands adversarial proceedings, where intelligence reports must be subject to genuine scrutiny, not accepted blindly. The dissenting opinions do not dispute that restrictions may be placed on missionary activities under certain circumstances involving threats to public order and security. However, in such cases, public authorities are expected to demonstrate the reality of the threat, with relevant and sufficient justification.

By contrast, three other judges dissented in a more restrictive direction, arguing that even the complaints on effective remedy should have been declared inadmissible. This shows that the Court was fractured not only between protection and restriction, but also on the very possibility of constitutional review.

The importance of the Krause case lies precisely in this sharp divide. While the majority opinion entrenches a doctrine of absolute sovereignty, placing Turkey beyond the reach of substantive constitutional guarantees, the dissents lay down a principled reasoning that aligns with Strasbourg jurisprudence. They show that within Turkey’s highest court there is recognition that denying access to evidence and equating lawful religious activity with security threats is incompatible with both the Constitution and the ECHR. These dissenting opinions therefore provide a solid basis for an appeal before the European Court of Human Rights, where the applicants can argue violations of Articles 9 and 13 ECHR and Protocol No. 7 on the strength of arguments already articulated by the Court’s own President and senior judges.

5.2 Dave and Pamela Wilson

David and Pamela Wilson had lived in Turkey for 35 years when they found they were unable to reenter Turkey after returning from a trip to the U.S.[20] David’s ministry in Turkey consisted of door-to-door evangelism, including sharing Gospel messages and invitations to Bible studies.[21] The couple had previously avoided multiple deportation attempts, but after a trip back to the U.S. in February 2019, authorities at the Istanbul airport told the couple they had both deportation and entry bans imposed on them. Their case is currently pending before the ECtHR.

5.3 Rachel and Mario Zalma

Rachel and Mario Zalma moved to Istanbul in 2009 to support a new Christian church. The couple became heavily invested in the church and local communities by providing English classes and childcare. In 2019, the Zalmas attended the family Conference of the Association of Turkish Protestant Churches, and soon after, authorities stopped them at the airport during their attempt to visit family in the United Kingdom. By June 2020, the government had enforced N-82 travel bans on both Rachel and Mario. The Zalmas then returned to England of their own accord and are now seeking international intervention through the ECtHR.

5.4 David Byle

David Byle is an American Canadian who lived in Istanbul for 19 years, where he raised his five children. He was accused of undermining state security because he testified to his Christian faith in a public space. Byle and his family frequently shared their faith and often received positive feedback. Authorities initially arrested Byle in 2016. He was temporarily granted the ability to stay in the country until the results of the case were delivered; however, he faced further arrest in 2018 when he was given a deportation order to leave the country within 15 days. This second arrest occurred just one day after the release of another American pastor, Andrew Brunson. Even though missionary work is not illegal in Turkey, Byle’s counsel for his petition before the ECtHR declared that his missionary work was “at the heart of the authorities’ decision to expel and ban him.”[22]

5.5 Expulsion of Spouses of Turkish Nationals: Subasiguller Case

Joy Subasiguller is the American wife of Turkish pastor Lutfu Subasiguller.[23] In June of 2020, Joy was given a deportation order and travel ban without justification. At the time of her deportation order, Joy was not actively involved in the church as she was a stay-at-home mother of her three children, the youngest of whom was less than a year old.

Joy had been living in Turkey with her husband and children for 10 years at the time of her arrest. Her husband and her three children are Turkish citizens. The government used her status as a foreign national against her husband, a Turkish Christian leader, to aid in the process of ridding the country of Christians. In imposing a travel ban on Joy, the government forced a Turkish protestant pastor out of his home country. Lutfu was forced to choose between preserving the unity of his family and continuing his ministry in Turkey. Joy and her husband are aware of many others who face similar restrictions but refrain from sharing their stories in hopes of protecting their safety.

This phenomenon further reveals the depth of Erdogan’s aims to eliminate the influence of Christianity in Turkey. The fear of the concept of “Christianization” that the Turkish government coined in the case of Pastor Andrew Brunson is not limited to Western missionaries, but also Turkish pastors who have close relationships with foreigners.

6. Seeking Redress Before the ECtHR

6.1 Cox v. Turkey (2010)

The applicant in this case is a US citizen who lived and studied in Turkey for several years, starting in 1972.[24] In 1984, she started working at a university in Southern Turkey. In 1985, the applicant told her students that Turks had expelled and massacred Armenians. The Ministry of Interior Affairs later deported her from Turkey. Several years later, the applicant returned to Turkey in 1989 and was arrested while distributing leaflets against the film The Last Temptation of Christ.

During and after the applicant’s expulsion from Turkey, the Ministry of the Interior allegedly compiled classified reports about the applicant containing phrases such as “the applicant who works as a missionary in our country” and “the applicant who was put under surveillance following her attendance at a service in a Protestant church in Turkey.” Because the applicant did not submit a copy of these reports to the court and provided no further evidence to substantiate her claim, the ECtHR found it more appropriate to focus solely on violations of freedom of expression (Article 10 of the ECHR).

The court concluded that the expulsion was not “necessary in a democratic society” and therefore Turkey had violated the applicant’s freedom of expression. The Court held that Turkey must pay the applicant EUR 12,000 for non-pecuniary damages. According to Turkey’s Action Report, this amount was paid in November 2010.

6.2 Bremner v. Turkey (2015)

In 1997, the applicant appeared on footage taken by a hidden camera for a television documentary concerning “foreign peddlers in religion.”[25] The applicant arranged a meeting with the person who owned the hidden camera after he responded to an advertisement regarding free Christian literature.

That same year, the public prosecutor brought proceedings against the applicant, claiming he had insulted God and Islam in the footage. The applicant was found not guilty and sued the director of the documentary for damages. The court dismissed the claim, finding the subject of the documentary a topic of public opinion.

The ECtHR found a violation of the applicant’s right to respect for private and family life (Article 8 of the ECHR) and that the state must pay EUR 7,500 for non-pecuniary damages.

6.3 Wiest v. Turkey (pending)

Kenneth Wiest had been living in Turkey for 34 years, working as a missionary with his wife and three children, who were each born and raised in Turkey.[26] In 2019, Wiest was returning home from a trip abroad when he discovered a travel ban preventing his entry into Turkey. The Turkish government accused Wiest of being a threat to national security despite no evidence being presented against him. He was also never given a fair trial to defend himself.

Following his failed attempts to reenter the country, Wiest requested prior authorization and then attempted to challenge the rejection of such requests before the domestic courts, both without success. Wiest brought a case before the ECtHR in which he accused the Turkish government of violating his right to private life (Article 8 of the ECHR) and not providing an effective domestic remedy (Article 13 of the ECHR). The Wiest case is still pending before the ECtHR. The ECLJ submitted its written observations in November 2024.[27]

7. Expulsion of foreign Christian Converts

7.1 Violations of Non-Refoulement and Persecution upon Return

Alongside the expulsions of Western missionaries and long-term residents, Turkey has also targeted foreign Christian converts, particularly from Iran and Afghanistan. These cases carry a specific gravity: unlike Western nationals, who may continue their lives safely in their countries of origin after deportation, converts from Muslim-majority states face severe persecution upon return. In Iran and Afghanistan, conversion from Islam is considered apostasy and may lead to imprisonment, torture, or even execution.

Turkey’s Law No. 6458 on Foreigners and International Protection incorporates the principle of non-refoulement, prohibiting the return of any person to a country where their life or freedom would be at risk on account of religion.[28] Despite this, Iranian and Afghan converts have repeatedly been subjected to deportation orders, detention in removal centers, or coercion to leave “voluntarily.” Protestant associations in Turkey report that asylum officers frequently display hostility towards converts, questioning the sincerity of their faith and treating their conversion as illegitimate.

This contradiction must also be viewed in the broader refugee context. After Iran, Turkey hosts the largest number of refugees in the world—approximately 3.1 million. Of these, about 2.8 million are Syrians who have been granted temporary protection status. The remainder includes international protection holders from Iraq, Afghanistan, Iran, and Ukraine. Following the outbreak of the Syrian civil war in 2011, the Turkish government became obligated to provide temporary protection to all Syrians arriving in its territory.[29] While these Muslim refugees are welcomed officially as “brothers” and benefit from collective protection, Christian converts from neighboring states face suspicion, administrative obstacles, and forcible removal.

Such expulsions not only breach domestic law but also Turkey’s obligations under the 1951 Refugee Convention, its 1967 Protocol, and the European Convention on Human Rights. Multiple cases before the ECtHR have condemned Turkey’s deportation of Iranian Christians as a violation of the non-refoulement principle. Article 4 of Law No. 6458 states clearly that no person shall be returned to a place where they risk “torture, inhuman or degrading punishment or treatment, or where his or her life or freedom would be threatened on account of race, religion, membership of a particular social group, or political opinion.” Unlike Western Christians, who may be deported without risk of physical persecution, Iranian and Afghan converts are entitled to stronger protection under international refugee law, precisely because their lives and freedom are directly at risk upon return.

The emblematic case of M.B. and Others v. Turkey illustrates these dangers and represents one of the clearest condemnations by the European Court of Human Rights of Turkey’s failure to respect the principle of non-refoulement in relation to Christian converts.

7.2 M.B. and Others v. Turkey (2010)

One emblematic case concerning Christian converts is M.B. and Others v. Turkey, decided by the European Court of Human Rights.[30] The four applicants were a married couple and their two children who had fled Iran to Turkey because of threats linked to political and religious persecution. Initially, their asylum claim was dismissed because the UNHCR did not recognize them as refugees.

After moving to Istanbul, the family converted to Christianity and became active in the local Protestant church. Their conversion quickly brought them into conflict with the Iranian authorities: the children were refused admission to the Iranian Consulate School in Istanbul, and evidence emerged that the father had already been imprisoned in Iran in 1991 for non-compliance with religious practices. In 2008, the UNHCR finally recognized the family as refugees in Ankara, noting that the Iranian authorities were aware of their conversion and that they faced a well-founded risk of persecution if returned to Iran.

Despite this recognition, the Turkish authorities continued to treat the family as irregular migrants. When they applied for residence permits in Hakkari in May 2008, the police questioned their movements and discovered that the father and son had traveled to Iran illegally with falsified passports in order to smuggle Farsi Bibles. On 30 July 2008, the family was deported to Iran.

Remarkably, the applicants managed to re-enter Turkey the very next day and applied once more to the UNHCR office in Ankara. The UNHCR confirmed that their refugee status remained valid. They sought suspension of the deportation order and applied for new residence permits, but their situation remained precarious.

The ECtHR delivered a clear judgment:

It held that deporting the family to Iran would violate Article 3 ECHR (prohibition of torture, inhuman or degrading treatment), given the real risk of persecution they faced as Christian converts.
It found a violation of Article 13 ECHR (right to an effective remedy), because the applicants had no adequate legal avenue in Turkey to challenge their deportation on these grounds.
It considered that no separate issue arose under Article 2 ECHR (right to life), as the Article 3 violation already encompassed the life-threatening risks.
The Court dismissed the applicants’ claim for just satisfaction.

This case illustrates the gravity of deporting Christian converts. Unlike Western Christians, who may continue their lives safely after expulsion, Iranian converts risk imprisonment and torture upon return. The judgment demonstrates that Turkey’s practice of deporting converts directly conflicts with its obligations under the principle of non-refoulement enshrined in both domestic law (Law No. 6458) and the Convention. It also underscores the structural weakness of remedies in Turkey: even recognized refugees with clear evidence of risk could not obtain protection through the national system and had to rely on Strasbourg to secure their rights.

8. International Protections for Christian Foreigners in Turkey

8.1 The Treaty of Lausanne

The Treaty of Lausanne, signed in 1923 by several nations—including the Ottoman Empire, France, Italy, Japan, the United Kingdom, Greece, and Romania—continues to play an exceptional role in Turkey.[31] It remains the sole international legal framework invoked by the Turkish state that defines the rights of non-Muslim minorities. One of the Treaty’s key objectives was to ensure the protection of the civil and religious rights of these communities. However, in practice, Turkey limits its application to three officially recognized groups: Armenians, Greeks, and Jews.[32] This selective recognition, based on a restrictive interpretation of the Treaty, effectively excludes other Christian denominations from legal minority status. The Turkish government argued that these religions were the groups established during the Ottoman Era, ignoring any additional evidence that other religions existed.[33]

Section III of the Treaty discusses the treatment of non-Muslim religious minorities in Turkey.[34] Article 38 of the Treaty specifies that the Turkish government will provide “full and complete protection of life and liberty to all inhabitants of Turkey without distinction of birth, nationality, language, race or religion.” Article 38 also says that these rights should not be “incompatible with public order and good morals.”

8.2 The European Convention on Human Rights and the International Covenant on Civil and Political Rights

In addition to the Treaty of Lausanne, Turkey is bound by two major international human rights instruments that guarantee freedom of religion and protection against arbitrary expulsions: the European Convention on Human Rights (ECHR) and the International Covenant on Civil and Political Rights (ICCPR).

Turkey has ratified the ECHR without reservation. Article 9 protects freedom of thought, conscience, and religion, including the right to worship, teach, and practice one’s faith individually or collectively. The law may only limit this right in cases necessary for the protection of public safety, order, health, morals, or the rights of others. Article 8 protects the right to respect for private and family life, and Article 10 protects freedom of expression. In addition, Article 6 §1 guarantees the right to a fair trial, Article 13 ensures the right to an effective remedy, and Article 1 of Protocol No. 7 provides procedural safeguards in the event of expulsion of foreign nationals. These provisions are often invoked by foreign Christians challenging entry bans, deportations, and surveillance measures that affect their ability to practice their faith, maintain family unity, and access judicial protection.

Turkey is also a party to the ICCPR, which similarly guarantees religious freedom under Article 18 and the rights of minorities under Article 27. However, Turkey has issued a reservation to Article 27, stating that it will interpret this provision in light of its Constitution and the Treaty of Lausanne. As a result, minority protections are limited to only three officially recognized groups—Greeks, Armenians, and Jews—thereby excluding other Christian communities.

According to the UN Human Rights Committee’s General Comment No. 23, however, minority status does not depend on official recognition. The principle of self-identification is fundamental to minority rights, and the Turkish reservation is therefore inconsistent with the object and purpose of Article 27.

In practice, despite these formal commitments, Turkey routinely invokes vague national security or public order justifications to restrict the rights of foreign Christians, often without meaningful judicial oversight. As a result, the protections offered by the ECHR and the ICCPR remain largely theoretical for many individuals affected by entry bans, expulsions, or harassment based on their religious identity.

9. Recommendations to Protect Religious Freedom for Christians in Turkey

9.1 The Turkish Government Has to Protect the Religious Freedom of Foreign Nationals

This requires adopting clear and specific legal provisions, and ensuring their consistent, evidence-based enforcement in line with international standards. This need is underscored by the case of Amanda Jolyn Krause and Others v. Turkey, in which the Constitutional Court upheld the use of administrative sanctions—such as entry bans and residence permit refusals—against individuals solely for attending Christian conferences or engaging in missionary activity.

In that case, the majority opinion found such activities sufficient to justify restrictions based on public order or safety, despite the absence of concrete evidence.[35] Several dissenting judges strongly criticized the vague and arbitrary nature of this reasoning. One dissenting opinion warned that, unless allegations linking missionary activity to public disorder, espionage, or terrorism are supported by specific and credible evidence, such restrictions risk violating fundamental rights. The opinion referenced the ECtHR judgment in Religious Organization of Jehovah’s Witnesses in the RA v. Armenia (App. No. 41817/10, 22 March 2022, §§74–81),[36] which held that religious proselytism is not inherently unlawful and cannot be restricted without a legitimate and evidenced justification.

In line with this standard, Turkey must ensure that any measures taken against foreign Christians are based on verifiable evidence and accompanied by procedural guarantees, including the right to be heard and access to the underlying case file. Without such safeguards, victims may be entitled to seek redress before the ECtHR—as the applicants in the Krause case potentially could—given the concerns expressed by multiple judges about the lack of legal justification provided.

9.2 The Council of Europe Has to Hold Turkey Accountable for Systemic Violations of Religious Freedom

Turkey’s growing pattern of non-compliance with judgments of the ECtHR, particularly in matters concerning freedom of religion and the expulsion of Christian foreigners, requires a coordinated and firm response from the Council of Europe.

Relevant judgments must be placed under enhanced supervision by the Committee of Ministers, with detailed and time-bound action plans requested from the Turkish authorities. These should include legal reforms, procedural safeguards against arbitrary expulsions, and the effective implementation of judicial remedies.

Civil society organizations should be encouraged to submit evidence of ongoing violations through Rule 9.2 submissions, which allow NGOs to inform the Committee of Ministers about a state’s failure to implement a judgment. This mechanism is crucial in building political and institutional pressure for compliance.

In cases of persistent refusal to execute binding judgments, the Council of Europe should consider launching infringement proceedings under Article 46§4 of the European Convention on Human Rights, holding Turkey accountable before the ECtHR for systemic non-execution.

Furthermore, the Parliamentary Assembly of the Council of Europe (PACE) should make use of both its general institutional powers[37] and the specific mechanisms available under the Monitoring Procedure, which has been formally applied to Turkey since 2017. This procedure was reactivated due to serious concerns about the deterioration of human rights, democratic governance, and the rule of law, particularly in the aftermath of the failed coup attempt of July 2016.

In this context, the Assembly should be encouraged to:

Request the drafting of a thematic report focused on violations of religious freedom and the expulsion of foreign Christians from Turkey;
Invite President Erdogan or senior Turkish officials to provide clarifications before the Assembly;
Send a fact-finding delegation to regions with significant missionary or minority Christian presence;
Initiate dialogue on broadening the interpretation of the Treaty of Lausanne to include additional Christian minority groups;
Publicly signal its readiness to apply political measures or sanctions, including the suspension of voting rights, should Turkey persist in violating its obligations under the European Convention on Human Rights.

Only sustained, coordinated, and multi-level pressure will be capable of ensuring that Turkey complies with the binding authority of the ECtHR and its core commitments as a member of the Council of Europe.

9.3 The European Union Has to Leverage Its Political and Financial Instruments to Defend Religious Freedom in Turkey

As a candidate country to the European Union, Turkey remains subject to enhanced scrutiny under the enlargement framework, particularly regarding the rule of law, human rights, and the protection of minorities. Although accession negotiations have stalled, the EU retains significant leverage through its political dialogue and financial assistance mechanisms.

In this context, the European Union should take proactive steps to promote religious freedom and the rights of Christian communities—both Turkish nationals and foreign residents—by using the instruments at its disposal.

It should, in particular:

Condition pre-accession funding under IPA III (2021–2027) on measurable progress in protecting freedom of religion and belief, including the cessation of arbitrary expulsions targeting foreign Christians;
Document violations of religious freedom in its annual Turkey Progress Reports and Human Rights and Democracy Reports, with specific attention to unrecognized Christian minorities and restrictions on missionary activity;
Raise these concerns systematically in EU–Turkey bilateral frameworks, such as Association Council meetings and human rights dialogues, calling for legal recognition of all Christian denominations historically present in Turkey;
Support civil society actors and faith-based NGOs through the European Instrument for Democracy and Human Rights (EIDHR) and other thematic funding lines, particularly those documenting hate crimes, expulsions, or restrictions on worship;
Encourage the EU Special Envoy for the promotion of freedom of religion or belief outside the EU to visit Turkey and meet with representatives of both recognized and unrecognized Christian communities;
Invite the European Parliament to adopt a resolution explicitly addressing violations of religious freedom in Turkey and calling for safeguards for foreign nationals facing arbitrary deportation on religious grounds.

Only through coordinated diplomatic pressure, consistent monitoring, and conditional financial support can the European Union contribute to protecting religious freedom in Turkey and ensure that its candidate status translates into concrete human rights obligations.

10. How the ECLJ Defends Persecuted Christians in Turkey

10.1 In General

In response to the gross treatment of foreign Christians in Turkey, the ECLJ denounced their persecution in the October 2024 Universal Periodic Review of Turkey at the United Nations Human Rights Council.[38] The ECLJ has also submitted observations in several cases concerning violations of the rights of ethnically Turkish Christians by the Turkish government, such as Fener Rum Patrikligi v. Turkey, Arnavutkoy Rum Ortodoks Taksiarhi Kilisesi Wakfi v. Turkey, Arhondoni v. Turkey, and Mavrakis v. Turkey.

10.2 The Andrew Brunson Case: Symbol of Religious Repression in Turkey

The ECLJ has a long history of aiding foreign nationals in Turkey, perhaps most notably, through its work with pastor Andrew Brunson. Pastor Brunson was openly serving as a pastor of the Izmir Resurrection Church when he was arrested and accused of “dividing and separating [Turkey], by means of Christianization.” The government categorized this accusation as a form of terrorism.[39] Brunson was held for an extended period without formal charges or trial. Instead, he was held in prison under harsh conditions, and used as a bargaining piece that the Turkish government exploited for over two years.

At the time of his arrest, Pastor Brunson had lived in Turkey, openly serving in a church leadership position, for 23 years. In 2016, Pastor Brunson was called into a local police station, where he thought he would finally get approval for his long-term residence permit. Instead, he was informed that he was being deported and that there was an arrest warrant saying the Brunson family should be held until they could be deported.

In a speech before the European Parliament, Pastor Brunson stated, “[My] view is that they did plan to deport us initially, but then somebody decided to hold on to us. I think the goal was to intimidate other religious workers in the country and have them self-deport because, up until then, no missionary had been imprisoned in Turkey, and so a number of people did leave the country after that because it was a new cost to factor into their decision-making: what are they willing to risk.”

The ECLJ, the ACLJ, and the United States government collaborated in their effort to return Pastor Brunson and his family to safety.[40] On 12 October 2018, Pastor Brunson was released to the United States, where he currently safely resides with his wife and children.

10.3 ECLJ Intervention in the Kenneth Wiest Case at the ECtHR

In November 2024, the ECLJ submitted written observations to the European Court of Human Rights in the case of Kenneth Wiest v. Turkey, highlighting the systematic targeting of foreign Christians through entry bans and deportations.[41] The submission underscored how such measures reflect a broader pattern of religious discrimination against Christian missionaries and converts in Turkey.

While Wiest invoked several provisions of the Convention, including Articles 6, 8, 9, 13, and 14, the ECLJ invited the ECtHR to more specifically examine the application under Articles 9 and 14. In addressing the suitability of Article 9, the ECLJ discussed the precedence set by the case of Nolan and K. v. Russia and Corley and others v. Russia in which the court analyzed similar situations through the lens of religious freedom.

The ECLJ also argued that Wiest’s application relates to a structural problem of Turkey’s treatment of foreign Christians that parallels the structural problems in Russia, which were made apparent in the aforementioned cases. The ECLJ provided further evidence and nuance regarding the methodology the ECtHR should use in determining the outcome of Wiest’s case.

11. Conclusion: Ending the Systematic Persecution of Foreign Christians in Turkey

For over a century, the Turkish government has been draining its country of both ethnic and foreign Christians. The most recent trend can be observed in the treatment of foreign missionaries who are arbitrarily marked with deportation and entry bans. The livelihoods of peaceful individuals who have created families within Turkey are eradicated alongside their hope to peacefully reside amongst Turkish nationals.

The Council of Europe, the European Union, and the U.N. must hold Turkey to both national and international standards by requiring the enforcement of existing laws that mandate evidentiary justification for the charging of crimes and the opportunity for the accused to provide a defense.

12. Frequently asked questions

12.1 What is the legal status of foreign Christians in Turkey?

Foreign Christians in Turkey face increasing legal insecurity despite the country's official commitments to human rights. Under Turkish Law No. 6458 on Foreigners and International Protection, foreign nationals may be denied entry, deported, or refused residence permits if deemed a “threat to public order.” While missionary activity is not illegal in Turkey, Christian foreigners—particularly Protestants—are often targeted for religious activities.

Turkish authorities use vague accusations and secret intelligence reports to justify bans, frequently without due process or evidence. Unlike Muslim foreigners or refugees, Christian residents—including those married to Turkish citizens—are disproportionately subjected to expulsions and entry bans. This de facto discrimination undermines freedom of religion and contradicts Turkey’s obligations under the European Convention on Human Rights.

12.2 What are N-82 and G-87 travel bans?

The N-82 and G-87 codes are Turkish administrative restrictions used to expel or ban foreign nationals from entering the country.

The N-82 code requires prior authorization for re-entry into Turkey, typically imposed on Christian missionaries or foreign spouses of Turkish Christians. Though technically temporary, in practice, these bans often become indefinite.
The G-87 code is even more severe, indicating a supposed “threat to national security” based on undisclosed intelligence, used to justify deportation and permanent entry bans.

These codes are rarely supported by evidence and frequently violate procedural rights, especially for foreign Christians targeted for their peaceful religious activities. They are at the heart of growing concerns about religious persecution in Turkey and are being challenged before Turkish courts and the European Court of Human Rights.

12.3 What international laws protect Christians in Turkey?

Several international legal instruments formally protect the rights of Christians in Turkey, although enforcement remains inconsistent due to vague claims of national security or public order.

The Treaty of Lausanne (1923) guarantees full civil and religious rights to non-Muslim minorities. However, Turkey limits its application to three officially recognized groups: Greeks, Armenians, and Jews, thereby excluding most other Christian denominations, particularly Protestants, Syriacs, and converts.

Beyond Lausanne, Turkey is a State Party to the European Convention on Human Rights (ECHR), which applies to all individuals under its jurisdiction, including foreign nationals.

Freedom of thought, conscience, and religion is protected (Article 9);
Private and family life, as well as protection against discrimination, are also guaranteed (Articles 8 and 14).

These provisions have been invoked in numerous cases before the European Court of Human Rights (ECtHR) challenging deportations, entry bans, and restrictions on Christian activity.

Turkey is also bound by the International Covenant on Civil and Political Rights (ICCPR), which protects religious freedom (Article 18) and minority rights (Article 27). However, Turkey has issued a reservation to Article 27, stating it will interpret the provision in light of its Constitution and the Treaty of Lausanne. This limits protections to officially recognized minorities only.

According to the UN Human Rights Committee, minority status does not depend on official recognition. The principle of self-identification is essential, and Turkey’s restrictive interpretation is inconsistent with the object and purpose of Article 27.

12.4 Who are the victims of religious persecution in Turkey?

Victims of religious persecution in Turkey include both foreign Christian missionaries and refugees who converted to Christianity, particularly from Iran. Many of these individuals have lived in Turkey for years, married Turkish citizens, and integrated with local churches. Notable cases involve Americans, Germans, Australians, and Iranian converts who have been deported or banned from Turkey under vague accusations of "missionary activity" or "threat to public order."

Examples include Pastor Andrew Brunson, the Zalma family, Kenneth Wiest, and Joy Subasiguller. The common denominator is Christian identity, not criminal conduct. These expulsions are arbitrary and often carried out without trial, violating fundamental human rights and targeting peaceful religious expression.

12.5 How is the ECtHR responding to Turkey’s persecution of foreign Christians?

The European Court of Human Rights (ECtHR) is increasingly addressing Turkey’s persecution of foreign Christians. Several ongoing and concluded cases—such as Cox v. Turkey, Bremner v. Turkey, and M.B. and Others v. Turkey—highlight violations of the right to private and family life (Article 8), freedom of religion (Article 9), and effective remedy (Article 13). The ECtHR has already ruled in favor of some Christian applicants, ordering compensation and declaring Turkey’s actions unjustified.

More recent cases, such as Kenneth Wiest v. Turkey, are pending, with the European Centre for Law and Justice (ECLJ) submitting legal observations. These proceedings aim to expose the systemic nature of Turkey’s discrimination and force compliance with international human rights standards.