What Is Complementary Health Insurance in Türkiye?
A private health product that meets, within the policy scope and terms, the extra fees added on top of what Turkish social security pays, plus certain expenses social security does not cover at all.
Complementary health insurance (Tamamlayıcı Sağlık Sigortası, or TSS) meets, within the policy scope and terms, the extra fees added to treatment already funded by Turkish social security (SGK), together with certain expenses SGK does not fund. It is aimed at people already covered by SGK who want the private-hospital top-up to be predictable.
What the Product Actually Is
The legal frame sits in article 18 of the Private Health Insurance Regulation (Özel Sağlık Sigortaları Yönetmeliği). That article states that complementary and supplementary health insurance products are written under the Regulation, and sets out what they may meet under two headings.
Those two headings also draw the boundary of the policy. The first applies where SGK is already paying something; the second covers expenses SGK does not fund at all but which the policy has taken on. Which item falls under which heading is set out in the insurer's special conditions.
The Regulation was amended by an instrument published in the Official Gazette on 20 October 2025, which entered into force on 1 January 2026. The rules on the lifetime renewal guarantee, waiting periods and portability between insurers were renewed for contracts written after that date, and this article follows that framework.
RYL Sigorta Aracılık Hizmetleri is an insurance agency. We prepare quotations from the insurers we act for; the policy is issued and any indemnity is paid by the insurance company.
- Extra charges added to expenses already met by SGK in Türkiye for a person covered by general health insurance
- Expenses incurred in Türkiye that SGK does not meet for that person
- The insurer may add optional cover for long-term care arising from dependency, for healthcare abroad and related costs, and for interpreting services
- No deductible may be applied to the first heading, so a threshold that excludes small extra charges cannot be written into that part of the cover
Where Social Security and the Policy Meet
They meet at the extra fee known as ilave ücret. Article 73 of Law No. 5510 allows contracted healthcare providers other than public ones, including foundation universities, to charge the patient on top of the tariff set by the Healthcare Pricing Commission. The President is empowered to set the ceiling for that extra fee, up to twice the tariff, and SGK sets the applicable rates within that ceiling. Because the rates change, no figure is quoted here; the current rate should be checked at source.
The Healthcare Implementation Communiqué (Sağlık Uygulama Tebliği) narrows the power further: an extra fee may only be charged by SGK-contracted foundation universities and by second and third level private healthcare providers. The Communiqué also requires the provider to obtain the written consent of the patient or a relative before delivering the service; without that consent no extra fee may be claimed afterwards.
The chain breaks in the same article. Except in emergencies, SGK does not pay for healthcare bought from a provider it has no contract with. If SGK pays nothing, there is no balance to complete. The whole logic of a complementary policy therefore rests on the hospital holding an SGK contract.
A Contracted Hospital Means Two Separate Contracts
This is the point most often misread. Saying a hospital is contracted describes not one agreement but two independent ones: the hospital's contract with SGK, and the hospital's agreement with the particular insurer. The first makes SGK pay its share; the second lets the policy settle directly with the hospital.
The two do not always coexist at the same hospital. Before buying cover, the question is not only whether the hospital appears on the insurer's network list but also whether its SGK contract is still running. Both can change during the year, so confirming them before treatment is the most practical safeguard.
| Situation | SGK contract | Insurer agreement | Practical outcome |
|---|---|---|---|
| Both in place | Yes | Yes | SGK pays its share and the extra fee can be met within the policy scope and limits |
| SGK contract only | Yes | No | SGK pays its share, but the hospital sits outside the direct-settlement network; collection and reimbursement follow the special conditions |
| Insurer agreement only | No | Yes | Outside emergencies SGK pays nothing, so no extra fee arises and the top-up logic does not engage |
| Neither | No | No | The whole cost stays with the patient |
When the Policy Does Not Engage
A complementary policy closes a gap. Where there is no gap there is nothing to close. The Healthcare Implementation Communiqué forbids charging an extra fee for certain services and to certain people; in those areas the policy adds nothing, because the patient is not charged an extra fee in the first place.
A further limit has applied since 1 January 2026. A paragraph added to article 18 of the Regulation provides that the co-payments patients owe under article 68 of Law No. 5510 may not be taken on as cover or paid by private insurers. Items such as the consultation co-payment and the outpatient medicine co-payment can no longer be written into a policy.
One more subtlety concerns services SGK does not fund at all. Under the Communiqué, what a provider charges for such a service is not an extra fee. Cover for it can only come through the second heading of the Regulation and the insurer's special conditions, and should not be expected to follow from the extra-fee benefit.
- Emergency care: stabilisation within 24 hours is the rule in the emergency department, and no extra fee may be charged during that period. The patient must be told in writing, against signature, that the emergency has ended and that further procedures will attract an extra fee
- Intensive care services
- Burn treatment
- Cancer treatment: radiotherapy, chemotherapy and radioisotope therapy
- Care given to newborns
- Organ, tissue and stem cell transplantation services
- People receiving an honorary pension, a pension under Law No. 2330, a war disability pension or a pension under Law No. 3713, and their dependants, from whom no extra fee may be taken
- SGK co-payments, which since 1 January 2026 may not be covered or paid by private insurers
How Waiting Periods Work
The Regulation defines a waiting period as the time that must pass before a condition or special situation expressly named in the policy comes within cover. The insurer may impose waiting periods, but the durations and the conditions they apply to must be stated clearly in the contract.
The 20 October 2025 amendment narrowed the practice considerably. A waiting period may be applied only in the first insurance period, and separately for each benefit offered in the policy. Where the policy is renewed within the same plan, no waiting period applies in later periods. Time already served is also preserved when the insured moves to another insurer.
The definition of renewal is decisive here. The Regulation treats a contract as renewed when it is renewed within one month following the policy expiry date. Miss that one-month window and the contract is not a renewal, which puts the accrued position in doubt. Diarising the expiry date matters for that reason.
| Scenario | What happens to the waiting period |
|---|---|
| First policy | May be applied only in the first insurance period, per benefit |
| Renewal within the same plan | Not applied in later periods |
| Change of insurer after the period is served | The new insurer applies none, save for special cases determined by the regulator |
| Change of insurer before the period is served | Time served with the previous insurer is deducted from the new insurer's period |
| Change of plan | Not re-applying waiting periods depends on remaining insured under the same plan |
Does a Complementary Policy Carry the Lifetime Renewal Guarantee?
It can, and the duty to offer it now extends to complementary products. Article 7 of the Regulation obliges the insurer to offer contracts containing a lifetime renewal guarantee (ömür boyu yenileme garantisi) to anyone who has not yet turned 60 and wants either private health insurance or a complementary or supplementary product under article 18. The policyholder may then choose a contract with or without the guarantee.
The conditions for earning the guarantee are capped as well. A contract may not set assessment conditions harsher than being insured continuously under the same plan for three years, disregarding gaps of up to one month between renewal dates, with total claims paid over that period staying below 80% of total premiums received.
An insurer may not present a different undertaking under the name of a renewal guarantee, or in a way that creates that impression. Where a contract carries no guarantee, that must be written plainly on the policy. The list of insureds who have earned the guarantee is kept by the Insurance Information and Monitoring Centre (Sigorta Bilgi ve Gözetim Merkezi), which a new insurer queries on a transfer. The detail is set out in the private health insurance article.
An Agency View: Before the Policy Is Bound
Most complaints about complementary cover come from misplaced expectations rather than from the cover itself. Two recur: assuming the policy will work at a hospital with no SGK contract, and reading the policy's silence in the emergency department as a defect when in fact no extra fee was charged there at all. Both follow from how the legislation is built, not from a flaw in the policy.
What we do as RYL Sigorta Aracılık Hizmetleri is prepare quotations from the insurers we act for and set the special conditions side by side so the differences are visible. The policy is issued, and any indemnity paid, by the insurance company. You can reach us through the quotation form for health lines.
Before that conversation, the checklist is short.
- Whether the hospitals actually used hold both an SGK contract and a place on the insurer's network list
- Whether the conditions and special situations subject to a waiting period are named clearly in the contract
- Whether the policy carries a lifetime renewal guarantee, and whether that is stated plainly on the policy
- That the plan scope, the benefit limits and the insured's share of costs are written on the policy
- That a claim event must be notified to the insurer in writing within eight days
- That all claims arising from the insurance contract are subject to a two-year time bar
- That where more than one policy covers the same expense, the cost is shared between insurers in proportion to their cover
- That under the Health Insurance General Conditions notices may be given either to the insurer's head office or to the agency that intermediated the contract
Frequently Asked Questions
Is complementary health insurance the same as private health insurance?
No. A complementary policy targets the extra charges added to expenses SGK already funds, plus certain expenses SGK does not fund, and its mechanics depend on an SGK payment existing. Private health insurance is built independently of SGK, and the benefits follow directly from the policy plan.
Is complementary cover useful if I am not covered by SGK?
The product is built around a person covered by general health insurance. If SGK pays nothing, no extra fee arises for the policy to complete. For people outside general health insurance, private health insurance offers a more suitable framework.
Will a complementary policy pay my consultation and medicine co-payments?
It cannot. A paragraph added to the Private Health Insurance Regulation, in force since 1 January 2026, prohibits private insurers from covering or paying the co-payments owed under article 68 of Law No. 5510.
Does the policy respond in an emergency?
Stabilisation within 24 hours is the rule in the emergency department, and no extra fee may be charged for services given in that window, so no gap arises for the policy to close. The patient must then be told in writing, against signature, that the emergency has ended and that further procedures attract an extra fee. Those later procedures are assessed under the policy.
Does the waiting period restart at every renewal?
It does not. A waiting period may be applied only in the first insurance period for each benefit, and not in later periods where the policy is renewed within the same plan. Once the period has been served, a new insurer applies none, save for special cases determined by the regulator.
Sources
- Private Health Insurance Regulation (consolidated text)
- Official Gazette — amendment to the Private Health Insurance Regulation, 20.10.2025
- SEDDK — press release on the new era in private health insurance
- Law No. 5510 on Social Insurance and General Health Insurance
- Social Security Institution Healthcare Implementation Communiqué
- SEDDK — Health Insurance General Conditions
This article is for information only; the scope of cover is set by the policy’s specific and general terms.
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