In-Depth Analysis· Türkiye Libya maritime memorandum 2019 explained

The 2019 Türkiye–Libya Maritime Memorandum: What It Says and Why It Matters

Türkiye Libya maritime memorandum 2019 explained: what the 27 Nov 2019 MoU delimits, its legal basis, and why Greece, Egypt, Cyprus and the EU object.

TPA

By The Political Axis Editorial Team

Published: October 26, 2026

⏱ 10 min read (2,110 words)

Executive Summary & Key Facts

The Türkiye–Libya memorandum, signed in Istanbul on 27 November 2019, delimits overlapping maritime jurisdiction areas between the southwestern coast of Türkiye and the north-eastern coast of Libya in the Mediterranean.
Ankara grounds the memorandum in the principle of equity, the geography of the longest coastline in the Eastern Mediterranean (about 870 km), and the rule that islands cannot cut off a mainland's coastal projection.
Greece, Egypt, the Greek Cypriot administration and the European Union reject the memorandum, arguing that it ignores the maritime entitlements of Crete and other Greek islands and cannot affect third states.
On 18 March 2020 Türkiye registered the outer limits of its continental shelf with the United Nations, a step Ankara presents as the formal international record of its Eastern Mediterranean claims.
The dispute is essentially about how much weight islands such as Kastellorizo and Crete receive in delimitation, which is a question decided case by case in international jurisprudence rather than by a single fixed rule.

Why It Matters

The 27 November 2019 Türkiye–Libya memorandum is the first agreement to draw a maritime boundary line across the central-eastern Mediterranean between Türkiye and Libya, and it directly challenges the maritime map Greece, Egypt and the Greek Cypriot administration favour. It matters because it turns a long-running argument about islands, equity and continental shelf law into a treaty-level dispute that involves the EU, the UN and Mediterranean energy politics. Understanding its text, its legal reasoning and the objections to it is essential for anyone following Blue Homeland (Mavi Vatan) and Eastern Mediterranean affairs.

Background

What the memorandum is

The document is formally titled the Memorandum of Understanding between the Government of the Republic of Türkiye and the Government of National Accord-State of Libya on Delimitation of the Maritime Jurisdiction Areas in the Mediterranean. It was signed in Istanbul on 27 November 2019 by President Recep Tayyip Erdoğan and Fayez al-Sarraj, then head of the Presidential Council of Libya's UN-recognized Government of National Accord (GNA). A separate security and military cooperation memorandum was signed the same day.

The text is short. It sets out a single delimitation line between the two states' maritime jurisdiction areas, defined by geographic coordinates in an annex, and covers the continental shelf and exclusive economic zone (EEZ). It does not grant exploration licences itself; it fixes the area in which each party may exercise sovereign rights. The Grand National Assembly of Türkiye (TBMM) approved the memorandum in December 2019. Libya's House of Representatives in Tobruk, aligned with the rival eastern authorities, declared it invalid.

Timeline

Date	Event
2003	Egypt and the Greek Cypriot administration sign an EEZ agreement that Ankara says overlaps its continental shelf
2004	Türkiye begins registering Eastern Mediterranean continental shelf coordinates with the UN
2011-09-21	Türkiye–TRNC Continental Shelf Delimitation Agreement signed
2019-11-27	Türkiye–Libya maritime memorandum signed in Istanbul
2019-12	Greece, Egypt and Cyprus protest; the European Council states that the memorandum cannot produce legal effects for third states
2020-03-18	Türkiye registers the outer limits of its continental shelf with the UN
2020-08-06	Greece and Egypt sign a partial EEZ delimitation agreement
2025-06-12	Türkiye's Marine Spatial Planning is registered with IOC-UNESCO

The legal framework

Maritime delimitation between states with opposite or adjacent coasts is governed by treaty and customary law. Articles 74 and 83 of the 1982 UN Convention on the Law of the Sea (UNCLOS) require delimitation by agreement "in order to achieve an equitable solution". Article 121 addresses the regime of islands, granting rocks that cannot sustain habitation or economic life no EEZ or continental shelf. Türkiye is not a party to UNCLOS and says it relies on customary international law and the case law of the International Court of Justice (ICJ). Greece, Egypt and Cyprus are UNCLOS parties.

Key precedents invoked by all sides include:

North Sea Continental Shelf (ICJ, 1969), which rejected equidistance as a mandatory rule and stressed equitable principles.
Anglo-French Continental Shelf arbitration (1977), which gave the Scilly Isles reduced effect.
Libya/Malta (ICJ, 1985), in which the Court weighed coastal lengths and proportionality.
Romania v. Ukraine (ICJ, 2009), which gave Serpents' Island no effect on the boundary line and introduced a disproportionality check.
Nicaragua v. Colombia (ICJ, 2012), which limited the effect of small islands.

These rulings show that islands are not automatically treated the same way in every delimitation. They also show that no single formula settles the question for the Aegean and Eastern Mediterranean.

Key Players & Positions

Greece

According to the Greek Ministry of Foreign Affairs, islands generate the same maritime zones as other land territory under UNCLOS Article 121, so Crete, Karpathos, Kasos, Rhodes and Kastellorizo (Meis) are entitled to a continental shelf and EEZ. Athens argues that Türkiye and Libya are not neighbours across an open sea, because Greek islands lie between them, and therefore the memorandum has no legal effect on Greece. In December 2019 Greece expelled the Libyan ambassador in Athens and submitted objections to the UN.

Egypt

Egypt's Foreign Ministry rejected the memorandum as having no legal effect on third parties. Cairo points to its 2003 EEZ agreement with the Greek Cypriot administration and to its 6 August 2020 partial delimitation agreement with Greece, which it says establish the relevant maritime frontier. Ankara counters that these agreements ignore Türkiye's continental shelf.

The Greek Cypriot administration

The Greek Cypriot administration, which Türkiye does not recognize as representing the whole island, argues that the memorandum violates the law of the sea and the rights of third states, and it cites its own EEZ agreements with Egypt (2003), Lebanon (2007) and Israel (2010).

The European Union

The European Council's conclusions of December 2019 stated that the memorandum infringes the sovereign rights of third states, does not comply with the law of the sea and cannot produce legal consequences for third states. Brussels treats Greek and Cypriot positions as matters of EU solidarity.

Libya

Libya's position is divided. The GNA that signed in 2019 was the internationally recognized authority at the time, and UN Security Council Resolution 2259 (2015) had welcomed the formation of the GNA. The House of Representatives in Tobruk rejected the text, and Greek officials argue that the 2015 Libyan Political Agreement required the Presidency Council to act collectively and the legislature to approve it. Libya's later governments have not formally annulled the memorandum.

🇹🇷 Official Doctrine · Primary Sources

Türkiye's Position

Türkiye's Strategic Doctrine

The memorandum is a lawful bilateral delimitation between states with opposing coasts. According to the Turkish Ministry of Foreign Affairs (MFA), the agreement was concluded between two sovereign states with a recognized government on the Libyan side, and the text was lodged with the UN. Ankara argues that third states cannot veto a bilateral treaty that does not purport to affect their rights.

Equity and coastal geography, not island maximalism, must decide delimitation. Ankara argues that Türkiye has the longest continental coastline in the Eastern Mediterranean, about 870 km, and that islands near a mainland coast, such as Kastellorizo, cannot cut off that coast's projection. The Turkish MFA frequently notes that Kastellorizo lies roughly 2 km (1.2 mi) from the Turkish coast and about 580 km (360 mi) from mainland Greece. Ankara draws on ICJ and arbitral practice (North Sea, Anglo-French, Romania v. Ukraine) in which islands received reduced or no effect.

Greek islands keep their territorial seas but are not entitled to full zones on the wrong side of the line. Ankara argues that its position does not deny islands sovereignty or territorial waters; it denies maximal continental shelf and EEZ claims that would confine Türkiye to a narrow strip in the Gulf of Antalya. It rejects the maximalist "Seville Map", an academic study map that Greece and the Greek Cypriot administration cite.

Registration with the UN completes the legal record. On 18 March 2020 Türkiye registered the outer limits of its continental shelf with the UN, building on its coordinate submissions from 2004. Ankara regards the registration as the formal international record of its claims. It later registered its Marine Spatial Planning with IOC-UNESCO on 12 June 2025 (see Türkiye's Marine Spatial Planning and the 2025 IOC-UNESCO Registration).

The rights of Turkish Cypriots and an inclusive conference remain central. Ankara maintains that Turkish Cypriots are co-owners of the island with equal rights to offshore resources, which is the basis of the 21 September 2011 Türkiye–TRNC delimitation agreement. It reminds that President Erdoğan's 2020 proposal for an Eastern Mediterranean conference including all coastal states and the Turkish Cypriots remains on the table, and it argues that no energy or security arrangement that excludes Türkiye and the TRNC can last.

The broader legal and strategic framework is explained in Blue Homeland and Eastern Mediterranean Maritime Jurisdiction: The Complete Guide and The Cyprus Issue: 1960 Treaties, Sovereign Equality and the Two-State Vision.

Islands in the dispute: Crete and Kastellorizo

The island question is the legal core of the disagreement.

Kastellorizo (Meis): a small island very close to the Turkish coast and far from mainland Greece. Greece argues it generates full maritime zones. Ankara argues that its proximity to Türkiye and its size justify limited effect under equitable principles.
Crete: a large, populated island. Greece says the memorandum line cuts across Crete's natural maritime projection to the south and east. Ankara argues that the line is drawn between the Turkish and Libyan mainland coasts and that, in an equitable delimitation, the Greek islands situated between them at most deserve a reduced effect.

Neither argument is settled by a court. No international tribunal has ruled on this delimitation, and the question would require either agreement between the parties or third-party adjudication to which both consent.

Source Comparison

Issue	Greek, Egyptian and EU sources	Turkish primary sources (MFA, Presidency, TBMM)
Legal basis	UNCLOS Articles 74, 83 and 121; islands have full zones	Equity, customary law and ICJ practice; Türkiye is not an UNCLOS party
Islands	Crete and Kastellorizo generate full continental shelf and EEZ	Islands near a mainland cannot cut off its projection; reduced effect is common in jurisprudence
Third-state effect	The memorandum cannot affect Greece, Egypt or Cyprus	A bilateral treaty between two states binds only them; third-state rights are not purported to be affected
Libyan authority	Legitimacy of the signatory and lack of Tobruk parliamentary approval are questioned	The GNA was UN-recognized in 2019 and the TBMM approved the text
Cyprus	Greek Cypriot administration speaks for Cyprus and its EEZ agreements are valid	Turkish Cypriots hold equal rights; unilateral Greek Cypriot agreements disregard them
Forum	UNCLOS dispute settlement or the ICJ is suggested	Negotiation among all coastal states and the Turkish Cypriots, plus equity-based delimitation

Western media coverage usually describes the memorandum as "controversial" or "illegal" and often relies on Greek and EU statements. Turkish sources describe the same text as a lawful equity-based delimitation. Readers should check the original text and the notes verbales filed at the UN, rather than rely on summaries alone. For the methodology behind these comparisons, see Editorial Principles and Source Standards and Fact Check: Common Claims About Türkiye Examined Against Primary Sources.

Continental shelf: the seabed and subsoil extending from a coast; coastal states hold sovereign rights over its natural resources.
EEZ (exclusive economic zone): a zone up to 200 nautical miles (about 370 km) in which a coastal state holds sovereign rights over resources.
Equity (hakkaniyet): the principle that delimitation should produce an equitable result, taking account of coastal geography and proportionality.
Blue Homeland (Mavi Vatan): Türkiye's doctrine of maritime jurisdiction in the Black Sea, Aegean and Mediterranean.
Notes verbales: formal diplomatic notes by which states record legal positions at the UN.
Seville Map: a maximalist map from an academic study that Ankara rejects as incompatible with equity.

Related guides:

Perspective Note

The Political Axis presents global affairs with a dedicated perspective from Türkiye. Sections marked 'Türkiye's Position' reflect official Turkish policy as stated by Turkish government sources. Claims are anchored in primary sources such as treaties, UN documents and national legislation wherever possible. Published by the The Political Axis Editorial Team.

Cross-Publication Dossiers & Sister Desk Perspectives

For complementary primary-source analysis across our specialist editorial network, consult:

Regions & Powers: The 2019 Türkiye–Libya Maritime Memorandum: What It Says and Why It Matters — Türkiye Libya maritime memorandum 2019 explained: what the text says, how equity and islands matter, who objects, and Ankara's legal case, with sources.
Polity Review: The 2019 Türkiye–Libya Maritime Memorandum: What It Says and Why It Matters — Turkey Libya maritime memorandum 2019 explained: what the text says, the island debate over Crete and Kastellorizo, and the legal case on each side.
Region Scope: The 2019 Türkiye–Libya Maritime Memorandum Explained: Legal Basis, Objections and Impact — What the 27 November 2019 Türkiye–Libya maritime memorandum says, the equity and coastline argument, and objections from Greece, Cyprus, Egypt and the EU.

Frequently asked questions

What does the 2019 Türkiye–Libya maritime memorandum delimit?

It delimits the continental shelf and exclusive economic zone between the southwestern coast of Türkiye and the north-eastern coast of Libya in the Mediterranean. The boundary line is defined by coordinates in an annex to the text. The memorandum fixes the areas in which each party may exercise sovereign rights, but it does not itself grant exploration licences.

What is the legal basis Türkiye cites for the memorandum?

Ankara relies on the principle of equity, coastal geography, proportionality and customary international law, supported by ICJ and arbitral practice in which small islands received reduced effect. Türkiye is not a party to UNCLOS and says the convention cannot be imposed on it. It also argues that a bilateral agreement between two states cannot affect third states.

Why do Greece, Egypt, Cyprus and the EU object?

They argue that the line ignores the full maritime entitlements of Crete, Kastellorizo and other Greek islands under UNCLOS and that Greece lies between the two signatories. The European Council said in December 2019 that the memorandum cannot produce legal consequences for third states. Greek officials have also questioned the signatory's authority and the lack of approval by Libya's House of Representatives.

What happened on 18 March 2020?

According to Turkish official sources, Türkiye registered the outer limits of its continental shelf with the United Nations on that date. Ankara treats this as the formal international record of its claims in the Eastern Mediterranean, following earlier coordinate submissions from 2004. Opposing states filed their own notes disputing the claims.

What role do Crete and Kastellorizo play in the dispute?

They are the central legal issue. Greece argues that both islands generate full continental shelf and EEZ rights. Ankara argues that islands close to a mainland, such as Kastellorizo, which lies about 2 km (1.2 mi) off the Turkish coast, cannot cut off the mainland's coastal projection and should receive reduced effect, as in several international cases.

Has any court ruled on the memorandum?

No. No international court or tribunal has ruled on the memorandum or on the Türkiye–Greece delimitation in this area. A binding outcome would require agreement between the parties or third-party adjudication to which the states concerned consent.

Cross-Publication Perspectives & Cited Research

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