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

Why It Matters

The 27 November 2019 memorandum is the first signed maritime delimitation text between Türkiye and Libya, and it is the central reference point in today's Eastern Mediterranean legal dispute. It sets a boundary between two states whose coasts, in Ankara's reading, project toward each other across the sea, while Greece, the Greek Cypriot administration, Egypt and the EU argue that Greek islands lie in between and that the line cannot affect them. Understanding what the text says, and what each side actually argued in its own words and filings, separates the legal questions from the political noise.

Background

The text and its signatories

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 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, chairman of Libya's Presidential Council and head of the Government of National Accord (GNA), which was based in Tripoli and recognised by the UN at the time.

The text is short. It consists of a preamble, a small number of operative articles and a list of geographic coordinates that define the boundary of the continental shelf and exclusive economic zone (EEZ) between the two parties. The preamble refers to the principles of international law and to the rights of coastal states over their maritime areas. Readers should consult the full treaty text and annexed coordinates rather than rely on summaries, and our Treaty Record explains how Irrecord handles primary documents.

On the same day the two governments signed a separate memorandum on security and military cooperation. The two documents are legally distinct, although media coverage often merges them.

The geography behind the line

The line runs between the south-western coast of Türkiye and the north-eastern coast of Libya. Between those coasts lie the Greek islands of Rhodes, Karpathos, Kasos, Crete and, very close to the Turkish mainland, Kastellorizo (Meis). That geography is the whole dispute. Türkiye holds roughly 870 km of Eastern Mediterranean coastline, the longest of any state in the basin, and says its projection toward the south-west cannot be sealed off by small islands near its own shore.

The legal argument

The legal case for the memorandum rests on three points:

• Coasts that project toward each other. Ankara argues that the Turkish and Libyan mainland coasts face one another across the sea, so their continental shelf and EEZ rights meet in the area the line covers.
• Equity, not equidistance. In maritime delimitation, case law, including the International Court of Justice's judgments in Tunisia/Libya (1982) and Libya/Malta (1985), requires an equitable solution in light of relevant circumstances. Those cases gave reduced or no effect to small islands. Türkiye is not a party to the 1982 UN Convention on the Law of the Sea (UNCLOS) and relies on customary international law and the equity principle.
• Islands cannot cut off a mainland coast. Ankara holds that islands lying close to a mainland coast, and far from their own mainland, cannot be used to cut off the longer mainland coast's projection.

Opponents reply that UNCLOS Article 121(2) gives islands, in principle, the same maritime zones as other land territory, and that Crete in particular is a large, inhabited island.

Chronology

For the wider dated record of coordinates, licences and agreements see The Eastern Mediterranean Record.

Key Players & Positions

Greece

Athens argues that the memorandum is legally void and that Türkiye and Libya have no common maritime boundary because Greek territory lies between them. Greece says Crete and the other islands generate continental shelf and EEZ rights under UNCLOS and customary law, and that the line ignores them. Greece sent its objections to the UN in December 2019 and expelled the Libyan ambassador in Athens, who represented the GNA, at that time. Greece also maintains that the memorandum cannot produce legal effects for third states, a point Türkiye does not contest as a general rule of treaty law.

The Greek Cypriot administration

The Greek Cypriot administration, which Ankara refers to as the Greek Cypriot Administration of Southern Cyprus (GCASC), states that the memorandum violates its sovereign rights and the EEZ it delimited with Egypt in 2003. It also protested to the UN. Ankara's counter-position is that the 2003 Egypt agreement itself overlaps Türkiye's continental shelf and ignores the rights of Turkish Cypriots, who are co-owners of the island.

Egypt

Egypt's foreign ministry stated in December 2019 that the memorandum has no legal effect for Egypt and does not affect its rights. In August 2020 Egypt and Greece concluded their own partial EEZ delimitation. Türkiye and the Tobruk-based Libyan authorities both rejected that agreement as encroaching on Libyan and Turkish shelf claims.

The European Union

The European Council, in its December 2019 conclusions, said 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. Ankara replies that the EU is not a party to the delimitation, has no competence to adjudicate maritime boundaries and has relied on a maximalist Greek and Greek Cypriot reading sometimes called the 'Seville Map'. Our sister analysis at Borders & Blocs compares that map with the memorandum line.

Libya's internal debate

Libya's own reaction has been mixed and shifted with its political divisions:

• Tripoli-based authorities. The GNA, and later the Government of National Unity, have treated the text as a valid agreement. In October 2022 Tripoli went further and signed a hydrocarbon exploration memorandum with Türkiye.
• Tobruk-based House of Representatives. Its leadership, including speaker Aguila Saleh, questioned the memorandum's validity, arguing that treaties require parliamentary approval and that the GNA had not obtained it. The body has, according to press reports, discussed ratification at other times, so its position should be checked against the latest statements.
• Talks with Greece. Officials in Tripoli have at times said Libya is open to dialogue with Athens on delimitation. In 2025, reporting indicated that Greek–Libyan technical contacts and Libyan notes to the UN in connection with Greek licensing south of Crete were under way, and no final outcome should be assumed.

These Libyan debates concern internal authority and procedure, not just the maritime line.

Source Comparison

Coverage of the memorandum tends to differ on three questions: whether Greek islands count in the equation, who has standing to object, and whether the text is a 'maritime boundary' or merely an arrangement between two parties.

When reading international coverage, check whether a source quotes the actual coordinates, names the filing it relies on and distinguishes the memorandum from the separate security agreement. Our Editorial Principles set out how Irrecord attributes positions and corrects errors.

Sister publications offer further analysis: Archive of Nations on the text and legal basis, Regions & Powers on the legal explainer, and Crossroads Review on Blue Homeland.

Key Terms & Related Guides

• Memorandum of understanding (MoU): The document's title. Ankara treats it as a binding bilateral delimitation instrument; critics sometimes argue that an MoU is not a treaty. The legal weight depends on the parties' intent and on domestic approval procedures.
• Continental shelf: The seabed and subsoil extending from a coast, over which the coastal state has sovereign rights over natural resources.
• Exclusive economic zone (EEZ): An area up to 200 nautical miles (about 370 km) from the baseline in which the coastal state has rights over resources; where coasts are closer, states must delimit.
• Equity principle: The rule that delimitation should achieve an equitable result, taking account of coastal geography, proportionality and other relevant circumstances.
• Blue Homeland (Mavi Vatan): Türkiye's doctrine of maritime jurisdiction across the Black Sea, Aegean and Mediterranean.
• GCASC: The Greek Cypriot Administration of Southern Cyprus, Ankara's term for the administration in the south of the island.
• Seville Map: A map produced in a study for the EU that Ankara describes as maximalist because it confines Türkiye's shelf to a narrow strip in the Gulf of Antalya.

Related Irrecord guides: The Eastern Mediterranean Record, The Treaty Record, Region Scope's legal-basis explainer and About Irrecord.

Irrecord presents global and regional affairs with a dedicated perspective from Türkiye. Sections marked 'Türkiye's Position' reflect official Turkish policy and legal doctrines as stated by Turkish primary sources.