Finding patients abroad and directing them to a healthcare institution requires a health tourism intermediary authorization certificate; selling air tickets, hotel accommodation, tours or transfers in the company’s own name requires a travel agency (TURSAB) operating license. Where treatment, accommodation and transfer are sold as a single package at a single price, both certificates are required together. The certificate obligation is determined not by the company’s trade name or by the headings used in its contracts, but by how the activity is actually carried out.
What determines the certificate obligation?
Companies operating in the health tourism field encounter two separate regulatory regimes. The international health tourism authorization certificate under Ministry of Health legislation governs intermediary activity between a foreign patient and a healthcare institution. The travel agency operating license under Law No. 1618 on Travel Agencies and the Association of Travel Agencies governs the sale of travel services. The two certificates are not interchangeable; where a single activity contains both elements, each element is subject to its own certificate regime.
Which activities require the health tourism authorization certificate?
The decisive test is whether the company acts as an intermediary between the foreign patient and the healthcare institution. Sourcing patients from abroad and directing them to a hospital is the core activity within this scope. Obtaining treatment quotations, arranging appointments, handling patient admission and organising the treatment process also fall within health tourism intermediation and require the authorization certificate. Where these activities are carried out on their own — that is, where the company does not additionally sell tickets, accommodation or tours — no travel agency license is sought.
Which activities require the travel agency (TURSAB) license?
The decisive test here is whether the company sells travel services in its own name. The following activities constitute travel agency activity and require an operating license:
- Selling an air ticket in the company’s name, collecting the fare, or providing a reservation service
- Selling hotel accommodation in the company’s own name, pricing it, or acting as intermediary against commission
- Organising a tour or travel programme
- Selling tickets, accommodation, tours or transfers in the company’s own name through a website
These activities do not, on their own, require a health tourism authorization certificate. However, where the same company also directs a foreign patient to a healthcare institution and organises the treatment, the health tourism authorization certificate must be obtained in addition to the travel agency license.
Which activities do not require a certificate on their own?
Corporate promotion directed at a hospital or healthcare institution, general advertising, market research and brand consultancy do not require a certificate. However, where the advertising activity in practice turns into finding patients, collecting patient applications or directing patients to a particular hospital, the activity takes on the character of health tourism intermediation and the authorization certificate becomes necessary.
The same applies to translation services. Written or oral translation supplied independently does not require a certificate; where translation is provided as part of finding patients and organising treatment, the health tourism authorization certificate is required.
Operating a hotel or accommodation facility likewise falls outside both certificates. Facility operation calls not for a TURSAB license but for permits relating to the facility itself, such as a tourism establishment certificate and a workplace opening and operating permit. Where the hotel operator also directs foreign patients to healthcare institutions, a health tourism authorization certificate must be obtained for that activity.
When are both certificates required together?
Selling treatment, accommodation and transfer as a single package at a single price is the typical case in which both certificates are sought together. Because the package contains treatment organisation and patient referral, the health tourism authorization certificate is required; because accommodation and transfer are sold as one package at one price, the travel agency license is required.
What if travel services are outsourced to a TURSAB-licensed agency?
A model frequently used in practice is for the company to confine itself to patient intermediation and to have accommodation and transfer services performed by a TURSAB-licensed travel agency. Under this model the company does not need to obtain a travel agency license in its own name; however, the contract, the collection and the invoice relating to the travel service must be issued by the licensed agency. The health tourism authorization certificate obligation continues for as long as the company carries on finding patients and organising treatment. Where customers are merely referred to the agency and no intermediation in the healthcare service takes place, the health tourism certificate is not sought either.
Certificate requirements by activity
| Activity | Health tourism authorization certificate | Travel agency (TURSAB) license |
|---|---|---|
| Finding patients abroad and directing them to a hospital | Required | Not required |
| Organising treatment between the patient and the hospital | Required | Not required |
| Corporate advertising and market research only | Not required* | Not required |
| Translation services only | Not required* | Not required |
| Selling air tickets in the company’s own name | Not required* | Required |
| Selling hotel reservations in the company’s own name | Not required* | Required |
| Organising tours or excursions | Not required* | Required |
| Selling travel services online in the company’s own name | Not required* | Required |
| Selling treatment + accommodation + transfer as one package at one price | Required | Required |
| Having accommodation and transfer performed by a TURSAB-licensed agency | Required where patient intermediation exists | Not required (contract, collection and invoice remain with the agency) |
| Operating a hotel or accommodation facility | Not required* | Not required; a tourism establishment certificate is required |
* Where finding patients, collecting patient applications or organising treatment is added to the activity, the health tourism authorization certificate becomes separately necessary.
Frequently asked questions
Who is required to obtain the health tourism authorization certificate?
Companies that source patients from abroad, direct patients to a healthcare institution or organise the treatment process are required to obtain the health tourism intermediary authorization certificate.
Does a company that sells only air tickets and accommodation need a health tourism certificate?
No. Where the subject of the sale is limited to tickets, accommodation or tours, the travel agency license is sufficient. If the company also carries out patient referral and treatment organisation, the health tourism authorization certificate is required as well.
Which certificates are required if treatment, accommodation and transfer are sold as one package at one price?
Both certificates are required together. The treatment organisation within the package is subject to the health tourism authorization certificate, and the sale of accommodation and transfer at a single price is subject to the travel agency license.
Must companies providing advertising and marketing services obtain a certificate?
Where only corporate promotion, market research and brand consultancy are carried out, no certificate is required. Where the advertising activity in practice turns into finding patients or collecting patient applications, the health tourism authorization certificate is required.
If accommodation and transfer are handled by a licensed agency, do we need our own TURSAB license?
No; however, the contract, the collection and the invoice for the travel service must be issued by the TURSAB-licensed agency. The health tourism authorization certificate obligation continues for the patient intermediation activity.
Which certificate applies if a hotel operator enters health tourism?
Facility operation calls for a tourism establishment certificate and a workplace permit. Where the hotel operator also directs foreign patients to healthcare institutions, a health tourism authorization certificate must be obtained as well.
This article has been prepared for general information purposes. Because the certificate obligation may vary according to how the activity is actually carried out and according to the current state of the legislation, specific cases require separate assessment.
For further information, please contact us.
