In-Depth Analysis· Türkiye Libya maritime memorandum 27 November 2019 explained

The Türkiye–Libya Maritime Memorandum of 27 November 2019: What It Says and Who Objects

What the Türkiye–Libya maritime memorandum of 27 November 2019 says, the equity and island arguments, and the objections of Greece, Cyprus, Egypt and the EU.

By Internatioon Review Editorial Team

Published: October 27, 2026

⏱ 9 min read (1,873 words)

Executive Summary & Key Facts

On 27 November 2019 Türkiye and Libya's UN-recognised Government of National Accord signed a memorandum of understanding delimiting their maritime jurisdiction areas in the Mediterranean.
Ankara argues the line follows the principle of equity and the coastal geography of a mainland coast of about 870 km (540 miles), the longest in the Eastern Mediterranean.
Greece, the Greek Cypriot administration, Egypt and the EU object that the memorandum ignores Greek islands such as Crete and infringes the rights of third states.
The core legal dispute is how much effect islands such as Kastellorizo (Meis), Rhodes, Karpathos and Crete should have when a delimitation line is drawn between two mainland coasts.
Türkiye maintains that a bilateral agreement cannot bind third states, and that the same logic means third states cannot veto it.

Why It Matters

The memorandum of 27 November 2019 is a short bilateral agreement that draws a maritime boundary between the continental shelf and exclusive economic zone (EEZ) claims of Türkiye and Libya across the Mediterranean. It matters because it is the clearest test of a question that international courts have answered case by case: whether islands lying between two mainland coasts can cut off the projection of those coasts. Greece, the Greek Cypriot administration, Egypt and the EU say it cannot stand; Ankara says it rests on equity and is lawful between its two parties.

Background

What the memorandum is

The document is titled the Memorandum of Understanding between the Government of the Republic of Türkiye and the Government of National Accord-State of Libya on the Delimitation of the Maritime Jurisdiction Areas in the Mediterranean. It was signed in Istanbul by President Recep Tayyip Erdoğan and Fayez al-Sarraj, head of the Presidency Council of Libya's Government of National Accord (GNA). The GNA had been welcomed by the UN Security Council in Resolution 2259 (2015) as the government emerging from the Libyan Political Agreement.

The text is brief. It defines the maritime jurisdiction areas concerned and sets out a boundary line by coordinates, effectively a corridor linking the south-western coast of Türkiye with the north-eastern coast of Libya. On the same day the two governments also signed a separate memorandum on security and military cooperation. Critics often treat the two together; Ankara treats them as distinct instruments.

Timeline

Date	Event
2015	UN Security Council Resolution 2259 welcomes the formation of the GNA
January 2019	East Mediterranean Gas Forum is launched in Cairo without Türkiye
2019-11-27	Türkiye and the GNA sign the maritime delimitation memorandum in Istanbul
December 2019	Greece expels the Libyan ambassador; the European Council issues conclusions rejecting the memorandum
2020-01-02	Greece, the Greek Cypriot administration and Israel sign an agreement on the EastMed pipeline project
2020-03-18	Türkiye registers the outer limits of its continental shelf with the UN (mentioned here only for context)
2020-08-06	Greece and Egypt sign a partial EEZ delimitation agreement
2021	Libya's Government of National Unity succeeds the GNA

Why the 870 km coastline is central

Türkiye has about 870 km (roughly 540 miles) of coastline on the Eastern Mediterranean, the longest of any state in that sea. Ankara's argument starts from the proposition that a delimitation should reflect coastal length and geography, not simply the position of small islands near the opposite shore. Kastellorizo (Meis), for example, lies about 2 km off the Turkish mainland but far from the Greek mainland. Greece replies that Kastellorizo is Greek territory and, like any other island, generates maritime zones under international law.

Key Players & Positions

Greece

According to the Greek Ministry of Foreign Affairs, the memorandum is legally void because Türkiye and Libya have no common maritime border: Greek islands, above all Crete, lie between their coasts. Athens argues that Crete, Karpathos, Kasos, Rhodes and Kastellorizo generate continental shelf and EEZ under Article 121 of UNCLOS, and that the memorandum disregards the rights of a third state. Greece also points to the 2015 Libyan Political Agreement, arguing that the Presidency Council acts by consensus and that Libya's House of Representatives never approved the text. Athens expelled Libya's ambassador in December 2019 in protest.

The Greek Cypriot administration

The Greek Cypriot Administration of Southern Cyprus (GCASC) is recognised by most states and by the EU as the Republic of Cyprus. It has stated, including in letters to the UN Secretary-General, that the memorandum violates the law of the sea and its own EEZ rights, and that the zone it claims is affected by the line. Nicosia relies on its EEZ agreements, notably with Egypt (2003), and says it has the right to explore blocks within its declared zone. Turkish Cypriots do not accept that the Greek Cypriot side speaks for the whole island on these resources.

Egypt

The Egyptian Foreign Ministry declared the memorandum devoid of legal effect and said it contravened the law of the sea and Libya's own constitutional arrangements. Cairo points to its 2003 delimitation with the Greek Cypriot administration and, in 2020, signed a partial EEZ agreement with Greece, presented in part as a response to the Türkiye–Libya line. Türkiye and the GNA both objected to that agreement, and the two sets of lines overlap in part.

The European Union

The European Council, in its December 2019 conclusions, said in substance that the Türkiye–Libya memorandum infringes upon the sovereign rights of third states, does not comply with the law of the sea and cannot produce any legal consequences for third states. The EU has repeatedly expressed solidarity with Greece and Cyprus on this issue.

Libya's internal dimension

The memorandum was signed when Libya was divided between the GNA in Tripoli and a rival authority in the east, with the House of Representatives in Tobruk rejecting the agreement. Ankara notes that the GNA was the UN-recognised government at signature; critics argue that the Libyan authorities lacked the internal approval needed. Libya's institutional split remains a factor in how the document is read.

The island argument

This is the legal heart of the dispute. Both sides cite the same body of case law, with different emphasis.

Greece's case: Article 121(2) of UNCLOS gives islands the same entitlements as other land territory; only rocks that cannot sustain human habitation or economic life (Article 121(3)) lose EEZ and shelf rights. Crete is large and inhabited, so it is entitled to full zones.
Türkiye's case: Delimitation is governed by equity, and courts have repeatedly reduced or disregarded the effect of islands to reach an equitable result. Ankara cites the 1977 Anglo-French Channel Islands arbitration (islands enclaved), the ICJ's 1985 Libya/Malta judgment (the islet of Filfla ignored), the 2009 Romania v. Ukraine judgment (Serpents' Island given no effect on the line) and the 2012 Bangladesh/Myanmar ITLOS decision (St Martin's Island given no effect).
Neutral note: These precedents involved small islands, often close to the coast of their own state. Greece argues that Crete and the Dodecanese are not comparable, while Ankara argues the principle applies to islands far from their mainland and close to another state's mainland. Türkiye is not a party to UNCLOS and relies on customary international law and equitable principles; Greece and Libya are parties.

🇹🇷 Official Policy · Primary Sources

Türkiye's Position

The points below summarise official Turkish positions as stated by Turkish government sources.

A lawful bilateral agreement between two coastal states. According to the Turkish Foreign Ministry's statements of December 2019 and after, the memorandum delimits areas where Türkiye's and Libya's coasts project towards each other. The text of the memorandum and its coordinates are the primary reference. Ankara invokes Article 34 of the Vienna Convention on the Law of Treaties: a treaty neither creates obligations nor rights for third states.
Equity and the 870 km coast. Ankara argues, in MFA statements and in letters to the UN, that delimitation must produce an equitable result in light of coastal geography and proportionality, and that islands cannot cut off a mainland's projection. It points to the jurisprudence above as the legal basis.
No infringement of third-state rights. According to the Foreign Ministry, the line does not encroach on areas to which Greece or the Greek Cypriot administration is entitled, because their claims rest on island effects that Ankara considers inequitable. Ankara rejects the maximalist Seville Map, which would confine Türkiye to a narrow strip in the Gulf of Antalya, and says the EU has no competence to adjudicate maritime delimitation between third states.
Dialogue remains open. President Erdoğan's 2020 call for an Eastern Mediterranean conference including all coastal states and the Turkish Cypriots stays on the table, as does the principle that Turkish Cypriots hold equal rights over island resources. See Fact Check: Did Türkiye Refuse Dialogue in the Eastern Mediterranean? for the record.

In addition, Ankara registered the outer limits of its continental shelf with the UN on 18 March 2020, and in 2025 registered its Marine Spatial Planning with IOC-UNESCO; these steps are discussed in sister explainers and are not the subject of this page.

Source Comparison

Source type	Typical framing	Key claim	What to check
Greek MFA and Greek media	Violation of Greek sovereign rights; ‘no common border’	Crete and other islands generate full zones; memorandum void	Whether Article 121 effects are full in a delimitation between mainlands
European Council conclusions	Violation of the law of the sea and third-state rights	Memorandum has no legal consequences for third states	EU's competence over delimitation between states
Egyptian MFA	Illegal; conflicts with Libyan arrangements and Egypt's own agreements	No legal effect; Greece–Egypt deal responds	Overlaps between the Egypt–Greece and Türkiye–Libya lines
Turkish MFA and Presidency	Lawful bilateral delimitation based on equity	Third states cannot veto; islands cannot cut off the 870 km coast	Text of the memorandum; the cited jurisprudence
Academic commentary	Contested; fact-specific	Outcome depends on island size, location and proportionality	Comparison with Libya/Malta, Channel Islands, Romania v. Ukraine

Most international coverage presents the memorandum as an anomaly; Turkish sources present it as a delimitation consistent with equity case law. The most reliable approach is to read the memorandum text and the court decisions directly.

Continental shelf / EEZ: The seabed and water column over which a coastal state exercises sovereign rights for resources, up to limits defined by law.
Equity (hakkaniyet): A delimitation principle where the final line must produce an equitable result in light of coastal lengths and geography.
Blue Homeland (Mavi Vatan): Türkiye's doctrine of its maritime jurisdiction areas in the Black Sea, Aegean and Mediterranean.
Seville Map: A map prepared in a study for the EU in 2020, which Ankara rejects as maximalist.
GCASC: Türkiye's official term for the Greek Cypriot administration; internationally it is known as the Republic of Cyprus.

Further reading on this site and in our network:

Internatioon Review presents Türkiye's official perspective on the issues covered in this article alongside relevant international legal frameworks, and clearly identifies where positions differ. Claims are attributed to primary sources such as treaty texts, UN documents, official statements and archival records, which are linked or cited wherever possible.

By the Internatioon Review Editorial Team.

Frequently asked questions

What is the Türkiye–Libya maritime memorandum of 27 November 2019?

It is a memorandum of understanding signed in Istanbul by Türkiye and Libya's Government of National Accord that delimits their maritime jurisdiction areas, meaning continental shelf and EEZ claims, in the Mediterranean. It sets out a boundary line by coordinates between the south-western Turkish coast and the north-eastern Libyan coast. A separate security and military cooperation memorandum was signed the same day.

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

They argue that Greek islands, especially Crete, lie between the two coasts and generate their own maritime zones, so Türkiye and Libya have no common maritime border. They also say the memorandum infringes the sovereign rights of third states; the European Council said it cannot produce legal consequences for them. Critics add that Libya's House of Representatives never approved the text.

What is Türkiye's main legal argument?

Ankara argues that delimitation must be equitable and reflect the 870 km Turkish coast, and that islands close to a mainland should not cut off that mainland's projection. It cites jurisprudence including the Channel Islands arbitration, Libya/Malta and Romania v. Ukraine, and says a bilateral agreement cannot bind third states under Article 34 of the Vienna Convention.

Do islands have a full maritime zone under international law?

Under Article 121(2) of UNCLOS, islands generate maritime zones like other land territory, while rocks that cannot sustain human habitation or economic life do not generate an EEZ or continental shelf. In delimitation between states, however, courts and tribunals have often reduced or ignored the effect of small islands to reach an equitable result. The dispute is how those precedents apply to larger islands such as Crete.

Is Türkiye bound by UNCLOS?

No. Türkiye is not a party to UNCLOS and relies on customary international law and equitable principles in delimitation. Greece and Libya are parties to the convention, and Greece invokes its provisions in objecting to the memorandum.

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