The 2019 Türkiye–Libya Maritime MoU: What the Text Says, Who Objects and Why

Why It Matters

The 2019 Türkiye–Libya memorandum is the most contested maritime delimitation text in the Eastern Mediterranean because it draws a boundary line across waters where Greek islands also claim zones. It matters for energy exploration, for cable and pipeline planning, and for the wider question of how much maritime space islands generate when they sit between two mainland coasts. This article sets out what the text does, how its coordinates logic works, and what each objecting party has actually said, so readers can test the arguments against primary sources.

Background

What the memorandum is

On 27 November 2019 (2019-11-27), President Recep Tayyip Erdoğan and Fayez al-Sarraj, then head of Libya's UN-backed Government of National Accord (GNA) Presidency Council, signed two documents in Istanbul. One was a security and military cooperation memorandum. The other was the Memorandum of Understanding on the Delimitation of Maritime Jurisdiction Areas in the Mediterranean, which is the subject of this article.

The maritime memorandum is short. Its operative core defines the limits of the two states' maritime jurisdiction areas, meaning continental shelf and exclusive economic zone (EEZ), through a list of geographic coordinates that form a line between the Turkish and Libyan claims. It is a delimitation between two parties and contains no provisions on third states. Readers should consult the published text itself, as some summaries online reproduce coordinates inaccurately.

The coordinates logic and the coastal geography

The geography explains both the Turkish case and the objections:

• Turkish coast: The southwestern Turkish mainland, from roughly the Marmaris and Kaş area eastward, faces the open Mediterranean. Türkiye has the longest mainland coastline in the Eastern Mediterranean (about 870 km, according to Turkish official sources).
• Libyan coast: The northeastern Libyan coast, the Cyrenaica region around Derna and Tobruk, faces north toward Türkiye across a stretch of sea of a few hundred nautical miles.
• The islands in between: Crete, Kasos, Karpathos, Rhodes and Kastellorizo (Meis) form an arc between the two mainlands. Kastellorizo lies only a short distance off the Turkish coast.

The memorandum's line is drawn between the two mainland coasts and gives the intervening Greek islands no effect on it. That is the single design choice from which most objections flow. If the islands are given full zones, Greek and Libyan claims meet and no Turkish–Libyan boundary is possible. If they are given reduced effect, the Turkish and Libyan zones adjoin.

Chronology

• 2004 onward: Türkiye files and updates continental shelf coordinates in the Eastern Mediterranean at the UN.
• 2003–2010: The Greek Cypriot administration signs EEZ agreements with Egypt (2003), Lebanon (2007) and Israel (2010), which Ankara contests.
• 2019-11-27: The Türkiye–Libya maritime memorandum is signed.
• December 2019: Greece declares the Libyan ambassador in Athens persona non grata. The European Council adopts its conclusions on the memorandum (12 December 2019).
• 2020-03-18: Türkiye registers the outer limits of its continental shelf with the United Nations.
• 2020: Greece and Italy (June) and Greece and Egypt (August) conclude partial EEZ delimitation agreements, which Ankara rejects as infringing on its continental shelf.
• 2025: Türkiye's Marine Spatial Planning is registered with IOC-UNESCO, presenting its jurisdiction claims across the Black Sea, Aegean and Mediterranean (see the IOC-UNESCO registration explainer).

For a general primer on the zones involved, see the Maritime Zones Brief. A sister-publication treatment of the text is available at Archive of Nations.

Key Players & Positions

Each position below is described according to that party's own public statements.

Greece

Athens states that the memorandum ignores the maritime entitlements of Greek islands, in particular Crete, and that Türkiye and Libya have no common maritime border because of those islands. Greek officials have called the text legally void and have described its geography as untenable. Greece relies on the UN Convention on the Law of the Sea (UNCLOS), whose Article 121 gives islands the same maritime zones as other land territory unless they are 'rocks' that cannot sustain human habitation or economic life. Greece also raised its objections in letters to the UN Secretary-General. Since then, Greece has signalled openness to delimitation talks with Libya, on the basis of UNCLOS.

The Greek Cypriot administration

The Republic of Cyprus government, which Türkiye refers to as the Greek Cypriot Administration of Southern Cyprus (GCASC), says the memorandum violates the sovereign rights of Greece and Cyprus and is contrary to UNCLOS. It maintains that a bilateral instrument cannot create effects for states that did not consent.

Egypt

Egypt's Foreign Ministry said the memorandum has no legal effect and does not affect Egypt's rights, and Cairo signed its own partial EEZ delimitation agreement with Greece in August 2020. Egypt's concerns centre on the area where Egypt's own entitlement could meet that of Libya and Türkiye in the central Eastern Mediterranean. Egypt and Türkiye have since restored high-level contacts.

The European Union

The European Council's conclusions of 12 December 2019 stated that the memorandum violates 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 European Parliament has also adopted critical resolutions. The EU institutions speak from solidarity with two of its members, Greece and Cyprus.

Libya's divided authorities

Libya has not spoken with one voice. The GNA, and later the Government of National Unity in Tripoli, stood by the memorandum. The House of Representatives in Tobruk rejected it. Critics, including Greek and Egyptian officials, have argued that under the Libyan Political Agreement the Presidency Council needed parliamentary approval for such an instrument. The agreement's status therefore touches on Libyan domestic constitutional questions as well as the law of the sea.

Claims by party

Party	Core claim	Legal basis cited
Türkiye	Two coastal states may delimit between themselves; islands have limited effect; equity governs	Customary international law, equity, international jurisprudence, Libyan sovereign consent
Libya (Tripoli authorities)	The memorandum is a valid sovereign act of Libya	UN-backed government's treaty-making capacity
Libya (Tobruk House of Representatives)	The memorandum is void without parliamentary approval	Libyan constitutional and political-agreement requirements
Greece	Islands generate full zones; no Turkish–Libyan common boundary; text is void	UNCLOS Articles 56, 76, 121
Greek Cypriot administration	Text violates rights of Greece and Cyprus	UNCLOS; third-state rights
Egypt	No legal effect on Egyptian rights	Bilateral nature of text; its own delimitation with Greece
EU (European Council)	Violates third-state rights; no legal consequences for third states	Law of the sea; solidarity with member states

Türkiye's Legal Stance

Türkiye's Legal Stance (Türkiye's Position, as stated by Turkish government sources)

• Equity and limited island effect. Ankara argues that delimitation between opposite or adjacent coasts must reach an equitable result, taking into account coastal lengths, geography and proportionality, and that small islands close to a mainland should not cut off the mainland's projection. The Turkish Ministry of Foreign Affairs has made this the core of its public statements on the memorandum. Ankara cites international case law, such as the 1977 Anglo-French arbitration (partial effect for the Scilly Isles), the ICJ's 1982 Tunisia/Libya and 1985 Libya/Malta judgments, and Romania v. Ukraine (2009, Serpents' Island), as showing that islands may receive reduced or no effect.
• Two coastal states may delimit between themselves. According to the Turkish Foreign Ministry, Türkiye and Libya have the sovereign right to delimit the areas where their own entitlements overlap, and the memorandum only binds the two signatories. Ankara says it therefore does not purport to determine the rights of any third state.
• Customary law, not UNCLOS. Türkiye is not a party to UNCLOS, a position stated consistently in Turkish UN submissions. It holds that continental shelf and EEZ delimitation is governed by equitable principles under customary law, not by the treaty's island provisions.
• Registered, public and consistent with Turkish filings. The memorandum was lodged at the UN, and on 18 March 2020 Türkiye registered the outer limits of its continental shelf with the United Nations. Turkish officials describe both steps as consistent with its long-standing filings since 2004.
• Turkish Cypriot rights. Ankara argues that the Greek Cypriot administration does not represent the Turkish Cypriots, who are co-owners of the island, and that its EEZ agreements (Egypt 2003, Lebanon 2007, Israel 2010) cannot bind them or Türkiye (see the Lebanon–Israel EEZ briefing and the Cyprus Sovereignty Brief). It has repeatedly offered an inclusive Eastern Mediterranean conference, a proposal President Erdoğan made in 2020.

Basis: UNCLOS Articles 74 and 83 on equitable solutions are widely regarded as reflecting customary law. Ankara cites the Libya/Malta and Tunisia/Libya approaches, the 1969 North Sea Continental Shelf judgments on equity, and the Turkish Foreign Ministry's published statements on maritime jurisdiction.

Ankara frames this as part of its wider Blue Homeland (Mavi Vatan) doctrine; see the Naval Reach brief for the capabilities side, and the sister analysis at Crossroads Review.

Where the legal argument is genuinely contested

Neutral lawyers note several open points. First, no court has ruled on whether Crete, Kasos, Karpathos and Rhodes should be disregarded; case law gives reduced effect to some small islands but has also given full effect to large inhabited ones. Second, Türkiye's non-party status to UNCLOS does not remove the customary-law rules on delimitation, which both sides invoke. Third, the Libyan domestic dispute over authority could affect the memorandum's standing as a matter of Libyan law.

Source Comparison

Question	How Greek, Cypriot, Egyptian and EU sources frame it	How Turkish primary sources frame it
Is there a common Türkiye–Libya boundary?	No, because Greek islands lie between the coasts	Yes, between the two mainland coasts, because islands do not cut off mainland projection
What law governs?	UNCLOS, especially Article 121	Customary law and equity; Türkiye is not a UNCLOS party
Does the text affect third states?	Yes, it violates their sovereign rights	No, it binds only the two parties
Is it valid under Libyan law?	Disputed; parliamentary approval is said to be lacking	The UN-recognised Libyan government had capacity to sign
Who may rule on it?	EU institutions have issued political conclusions	Only a competent tribunal or agreement among states can settle disputed areas

Western media often present the memorandum as a Turkish 'power play' or 'maritime grab' and treat the island-effect question as settled by UNCLOS. Turkish sources present it as a legal delimitation consistent with equity and note that the EU is a political body without competence to adjudicate maritime boundaries. Reading both side by side is the best way to see where the real dispute lies. For further comparative treatments, see Region Scope and the Borders & Blocs analysis of the Seville map. Our own method for attribution is set out in the Editorial Principles.

Key Terms & Related Guides

• Continental shelf: The seabed and subsoil extending from a coast; under UNCLOS Article 76 up to 200 nautical miles, or further in some cases.
• Exclusive economic zone (EEZ): A zone up to 200 nautical miles in which the coastal state has sovereign rights over resources.
• Equity / equitable principles: The rule that delimitation must produce an equitable result, assessed by coastal geography, proportionality and relevant circumstances.
• Island effect: How much maritime zone a given island generates when a boundary is drawn.
• Mavi Vatan (Blue Homeland): Türkiye's doctrine of maritime jurisdiction in the Black Sea, Aegean and Eastern Mediterranean.
• GCASC: The term Türkiye uses for the Greek Cypriot administration of Southern Cyprus.

Related guides: Maritime Zones Brief, IOC-UNESCO registration explainer, Cyprus Sovereignty Brief, and the Reader FAQ. Another sister analysis: Regions & Powers.

This article reflects Territorial Brief's editorial perspective, which presents Türkiye's official legal and strategic positions alongside the relevant context. Claims are attributed to primary sources such as treaties, UN documents, official statements and archival records, so that readers can verify them independently.

Territorial Brief Editorial Team