Şantiye-M 8 Triggers 2026: Which Project Hits Which?

Since the Şantiye-M digital inspection system run by Turkey's Ministry of Environment, Urbanization and Climate Change came into force in 2024, the most frequent question asked by contractors, site managers and project leads has been: "Is my project in scope or not?" As of 2026, the threshold criteria have stabilised and the sector is in its second year of compliance.

This guide examines the 8 thresholds that trigger Şantiye-M coverage, one by one. For each threshold we cover the definition, which projects fall in or out, reporting frequency and the sanctions for non-compliance. We also cover threshold intersections, the position of out-of-scope projects, and AECKraft's role as a preparation-layer (not as an accredited reporting vendor).

For the foundational mechanics of Şantiye-M and accredited vendors, see our Şantiye-M 2026 Software Compliance pillar article; this piece builds on that foundation and zooms into the 8 thresholds.

What Is Şantiye-M and How Does the Threshold System Work?

Şantiye-M is a centralised digital platform developed by Turkey's Ministry of Environment to collect real-time data from construction sites. Projects meeting certain criteria must transmit daily, weekly and monthly site data (worker check-ins, OSH incidents, progress photos, material consumption, environmental measurements) to Ministry servers.

The gating mechanism is an 8-threshold criteria set. If a project meets any single threshold, it is automatically in scope. If none are met, the project is out of scope of Şantiye-M's portal reporting — but not out of scope for OSH, Building Inspection Law (4708), or zoning regulations.

The thresholds operate on "OR" logic — meeting Threshold 1 is equivalent to meeting Threshold 3 for the purpose of triggering scope. However, when multiple thresholds are met, Ministry audits evaluate each threshold's specific criteria.

Threshold 1: Residential Projects Over 5,000 m²

The most common threshold encountered in the sector. All residential projects with a total gross floor area exceeding 5,000 m² under a single building permit are automatically in scope. The square-metre calculation includes all independent units (apartments, shops, common areas) — not just the net area of apartments.

Examples:

• 20-unit apartment building, 120 m² each, 6 floors = 2,400 m² → Out of scope
• 40-unit, 130 m² each, 10 floors = 5,200 m² → In scope
• 3-block site, each block 2,500 m² → total 7,500 m² → In scope if under a single permit
• Same parcel, 2 separate permits of 4,000 m² + 3,000 m² → Each permit separate; both out of scope (but Ministry may apply consolidated evaluation)

Reporting frequency: Daily worker check-ins, weekly progress photos, monthly structural system report. Concrete pour days require 24-hour advance notification.

Sanction: Non-compliance under Threshold 1 can lead to permit suspension under Building Inspection Law; occupancy permit (iskân) issuance is delayed. In 2026, average penalty range is reported at TRY 250,000-500,000.

Threshold 2: Public Investment Projects (Any Scale)

Unlike private sector thresholds, Threshold 2 has no minimum size. All construction projects tendered or executed by public agencies (ministries, municipalities, state-owned enterprises, universities including foundation universities) are in scope — regardless of size. Even a 200 m² village headman office is included.

Examples:

• Municipal village school (300 m²) → In scope
• New university campus laboratory (800 m²) → In scope
• Highway agency service building renovation → In scope (if treated as new construction for area calculation)
• TOKİ (Mass Housing Authority) projects → In scope (also triggers Threshold 1, so dual-threshold)

Public projects have a particularity: Şantiye-M compliance is an essential clause in tender documents. Non-compliance directly triggers progress-payment freeze. Our construction contract types article details the enforcement clauses in public contracts.

Reporting frequency: Daily; with mandatory data flow integration with the EKAP (public procurement platform).

Threshold 3: High-Rise Buildings (30 m+)

Any building with a height exceeding 30 metres from ground to roof — regardless of function (residential, office, hotel, hospital) — falls under Threshold 3. 30 metres approximates a 10-storey residential building, but since floor heights vary, the measure is in metres.

Examples:

• 9-storey residential, 3.5 m each = 31.5 m → In scope
• 12-storey residential, 2.8 m each = 33.6 m → In scope
• 8-storey office, 3.8 m each = 30.4 m → In scope
• 5-storey plaza, 5 m each = 25 m → Out of scope (from Threshold 3; may still trigger m² thresholds)

Special criteria for Threshold 3: additional OSH notifications for crane movement logs, digital tracking of high-altitude work permits, hourly wind speed measurements.

Sanction: Non-compliance in 30 m+ buildings is treated as "missing structural report" — occupancy permit is denied. Penalties are 2-3x those of Threshold 1.

Threshold 4: City Hospital PPP Projects

City hospitals built under Public-Private Partnership (PPP) form a distinct Şantiye-M threshold. These projects are large-scale (typically 200,000-1,000,000 m²), strategically important and subject to joint inspection by Ministry of Health and Ministry of Environment.

Examples:

• Ankara Bilkent City Hospital (operating, 1,062,000 m²) — reference example
• Istanbul Başakşehir City Hospital — reference example
• Under construction: Diyarbakır City Hospital, Trabzon City Hospital → In scope

Threshold 4's distinguishing feature: health-specific data flows (medical gas lines, operating room technical specifications, isolation systems) must also be reported via Şantiye-M. A standard hospital (e.g., 100-bed state hospital) does not fall under Threshold 4 but under Threshold 2 (public investment).

Sanction: PPP contract enables the Ministry to delay rent payments — millions of liras per day of loss for the contractor.

Threshold 5: Rail System Structures

Metro, light rail (tram), commuter rail, high-speed train (YHT) lines and their associated stations, depots, workshops, and switching areas fall under Threshold 5. No length or area minimum applies; any rail infrastructure construction is automatically in scope.

Examples:

• New Istanbul metro lines (e.g., Kabataş-Mecidiyeköy) → In scope
• Ankara YHT station renovation → In scope
• Bursa tram line extension (even 1 km) → In scope
• Private factory internal forklift rail (industrial) → Out of scope (not public rail transit)

Special criterion of Threshold 5: dual approval process with TCDD (state railways) and Ministry of Transport. Site reports are sent in parallel to both Environment and Transport ministry portals.

Threshold 6: Bridges and Tunnels (50 m+ Span)

If a road or rail bridge has any single span exceeding 50 metres, or a tunnel exceeds 50 metres in total length, Threshold 6 applies. This threshold is designed specifically for infrastructure and engineering structures.

Examples:

• Black Sea coastal road viaduct with 80 m span → In scope
• Urban pedestrian bridge (35 m span) → Out of scope
• Slope tunnel (220 m length) → In scope
• Highway overpass (40 m span) → Out of scope (from Threshold 6; but if public, falls under Threshold 2)

Threshold 6 projects upload geological measurements, fill compaction tests, post-tensioning records and hydrostatic pressure readings daily. Known as the most data-intensive of all thresholds.

Threshold 7: Industrial Buildings (10,000 m²+)

Industrial-use structures (factory, production plant, logistics warehouse, cold storage, OSB-internal manufacturing facility) with total enclosed area exceeding 10,000 m² trigger Threshold 7. Designed specifically to bring Turkey's growing production and logistics sectors under Ministry oversight.

Examples:

• Automotive supplier plant (12,000 m²) → In scope
• E-commerce fulfilment centre (35,000 m²) → In scope
• OSB-internal textile facility (8,500 m²) → Out of scope
• Cold storage (15,000 m²) → In scope

Special criterion: environmental measurements (air emissions, noise levels, wastewater samples) reported weekly. Threshold 7 frequently overlaps with Threshold 8 (EIA).

Sanction: Operating permit (faaliyet izni) issuance is delayed; in OSB facilities, electricity-water connections may be suspended.

Threshold 8: All Projects Requiring Environmental Impact Assessment (EIA)

All projects listed in EIA Regulation Annex 1 or Annex 2 — regardless of building type or size — that require an EIA report fall under Threshold 8. This is the broadest threshold; the sector-wide rule is "if in doubt, check Threshold 8."

Examples:

• Mining quarries (any scale) → In scope
• Hydroelectric power plant (HPP) → In scope
• Wind power plant → In scope
• Dam, reservoir, irrigation project → In scope
• Organised Industrial Zone (OSB) infrastructure works → In scope
• Waste disposal facility → In scope
• Thermal power plant → In scope

Threshold 8 Şantiye-M data flows not only to the Ministry of Environment but also to the EIA Monitoring Commission — making this the most strictly inspected threshold.

Sanction: Cancellation of EIA compliance certificate — meaning the project is effectively halted. In 2026, two wind power projects and one mining quarry were temporarily shut down for this reason.

Threshold Intersections: What If a Project Hits Multiple Thresholds?

In practice, most projects hit multiple thresholds simultaneously. Examples:

• 10,000 m² public housing (TOKİ): Threshold 1 (5,000+ m²) + Threshold 2 (public investment)
• 30-storey plaza office (35,000 m²): Not Threshold 1 (not residential) + Threshold 3 (height) — Threshold 1 applies only to residential
• City hospital (800,000 m², 40 m tall): Threshold 2 + Threshold 3 + Threshold 4
• HPP project (100 m dam body): Threshold 6 (span/height) + Threshold 8 (EIA)

When thresholds intersect, a single Şantiye-M file is opened — no separate filings required. However, Ministry audit evaluates the criteria of each triggered threshold. For example, in the city hospital case, EKAP integration (T2), crane/wind logs (T3), and medical acceptance tests (T4) must all be flowing into the system.

Practical advice: At project start, run a compliance analysis and document which thresholds you hit in a tabular form. This provides a clear reference for both your internal team and Ministry audit. Our construction project management guide includes a detailed project-start checklist example.

Are Out-of-Scope Projects Automatically Exempt from Compliance?

One of the most misunderstood points in the sector. A project that does not meet any of the 8 thresholds (e.g., a 3,000 m² small private apartment) is exempt from Şantiye-M real-time digital reporting; but not exempt from other legal obligations:

• OSH (Law 6331): Worker check-in records, OSH expert reports, training records must be maintained.
• Building Inspection Law (4708): Building inspection firm appointed, periodic controls performed, progress payments approved manually.
• Zoning Law (3194): Permit, occupancy, condominium registration processes proceed normally.
• SGK and OSH-KATİP: These systems operate independently of Şantiye-M and are mandatory for every site.

Out-of-scope does not mean "unrecorded"; it just means no real-time data transmission to the Ministry's central portal. This distinction is why many small contractors view Şantiye-M as unnecessary bureaucracy — but the Ministry plans to lower thresholds in 2027, at which point 3,000 m² residential projects will also enter scope.

For firms migrating from Excel to digital systems, our Excel-to-AECKraft migration guide simplifies this preparation phase.

AECKraft's Role in the Şantiye-M Preparation Process

Important clarification: AECKraft is not a Şantiye-M vendor accredited by the Ministry of Environment. It does not transmit data directly to the Şantiye-M API — official reports must be filed through a Ministry-accredited vendor. What AECKraft provides is a preparation and document management layer:

• Document archive: EIA reports, structural drawings, architectural drawings, contracts, progress-payment files — all centralised with version control.
• Photo management: Timestamped, GPS-tagged site photo archive; bulk export to accredited vendors when needed.
• Audit trail: All document changes, who-when-what records; ready for Ministry audit in report format.
• KVKK-compliant Turkey data residency: All data stays within Turkey's borders.
• Excel/CSV export: Standard format output to build a data bridge with your accredited vendor.
• Progress-payment tracking module: Internal progress-payment calculations; manual export to external accounting systems.

So AECKraft serves as the digital back-office of the preparation phase in Şantiye-M compliance. Official vendor selection and Ministry reporting is a separate process; AECKraft acts as the source system feeding data into that process.

For a demo, visit the contact page; for package details, see pricing page. 14-day free trial — no credit card required.

Conclusion

The 8 thresholds of Şantiye-M are the gateway to Turkey's construction digital inspection process. Correctly assessing whether your project falls in scope is the first step in both legal compliance and budget planning. As of 2026, the most commonly hit thresholds are 1 (residential area) and 8 (EIA), while the most strictly inspected are 4 (city hospitals) and 8 (EIA).

A practical recommendation: at project start, run a 30-minute compliance analysis and document the thresholds you hit in tabular form. This small investment prevents months-long compliance crises later. If you combine the threshold analysis with the scoring matrix suggested in our construction software selection criteria article, you'll be ready for vendor selection too.

Frequently Asked Questions

If I have a 5,000 m² residential project and split it into two separate permits, do I escape Threshold 1?

Technically yes, but since 2025 the Ministry has the authority to apply consolidated evaluation when "single parcel + single contractor + single consultant" conditions exist. Permit-splitting alone is not a guarantee; if the same investor is found to be building the same site under two separate permits, Threshold 1 scope can be applied retroactively.

Is the zero-square-metre threshold for public investment (Threshold 2) really applicable?

Yes, public projects have no minimum area floor. Even a 100 m² library is in scope. The only exception is simple maintenance work with a contract value below TRY 500,000; these are outside Şantiye-M but remain registered in EKAP.

Is the 30 m height measured in floors or metres?

Metres. Vertical distance from ground level to under-eaves. A 9-storey building can be 31 m, while a 10-storey building can be 28 m; what matters is the metric measurement.

Does a regular state hospital (not a city hospital) fall under Threshold 4?

No. Threshold 4 covers only city hospitals built under PPP. Classic state hospital construction is evaluated under Threshold 2 (public investment); and if tall, Threshold 3 also kicks in.

Does even a 1 km tram extension fall under Threshold 5?

Yes, rail systems have no length threshold. Even a 100 m extension is in scope. The reason is the Ministry of Transport's strategic infrastructure classification.

Is there a large-capacity mine that doesn't require EIA?

In practice, no. EIA Annex 1 covers virtually all mining activities. Even in Annex 2 categories where "EIA may be required, project-specific," the Ministry usually finds it required. So mine + Threshold 8 = almost automatic scope.

If I don't meet any threshold, can I still register voluntarily with Şantiye-M?

Voluntary registration is possible and increasingly preferred by large contractors in 2026. Advantages: no surprises if thresholds drop in the future, "Şantiye-M experienced" scoring bonus in public tenders. Disadvantages: additional operational load and accredited vendor licence cost.

If a project meets both Threshold 1 and Threshold 3, is the penalty doubled?

No. A single Şantiye-M file is opened, and the penalty is calculated on a single amount. However, the penalty is determined by the highest-risk threshold the project meets. For example, in a T1+T3 combination, T3's (high-rise) penalty schedule applies.