The 2019 Türkiye–Libya Maritime MoU: What It Says, What Egypt and Greece Argue, and Why It Matters

Why It Matters

The 27 November 2019 Türkiye–Libya memorandum is the first agreement to delimit part of the continental shelf and exclusive economic zone (EEZ) between the two mainland coasts across the Eastern Mediterranean. It matters because it challenges the idea that Greek islands, such as Crete, Rhodes and Kastellorizo, automatically close off Türkiye's projection into the open sea. It has also become a reference point in the wider contest over energy routes, pipelines and undersea cables.

This guide sets out what the text does, how Greece, the Greek Cypriot administration, Egypt and the EU object, and what Ankara argues. It closes with a short horizon outlook.

Background

What was signed and where

The Memorandum of Understanding on the Delimitation of Maritime Jurisdiction Areas in the Mediterranean was signed in Istanbul on 27 November 2019. President Recep Tayyip Erdoğan signed for Türkiye. Fayez al-Sarraj, Chairman of the Presidency Council of Libya's Government of National Accord (GNA) in Tripoli, signed for Libya. A separate memorandum on security and military cooperation was signed the same day. The two texts are legally distinct, though they are often discussed together.

The maritime text establishes a boundary line defined by geographic coordinates. The line runs between Türkiye's south-western coast and Libya's north-eastern coast. It crosses waters where Greek islands (Crete, Kasos, Karpathos, Rhodes and Kastellorizo/Meis) lie between the two mainland shores. Those islands are what the dispute is about.

Geography and the equity argument

Türkiye has about 870 km (540 miles) of Eastern Mediterranean coastline, the longest of any state in that sea. The legal question is how much weight small and distant islands should carry when a boundary is drawn between two large mainland coasts that face each other.

Ankara relies on the principle of equity, established in delimitation case law and customary law:

• North Sea Continental Shelf (ICJ, 1969) established that delimitation should be effected on equitable principles.
• Anglo-French Continental Shelf arbitration (1977) gave the Scilly Isles reduced effect.
• Libya/Malta (ICJ, 1985) took proportionality between coastal lengths into account.
• Romania v. Ukraine (ICJ, 2009) gave Serpents' Island no effect on the boundary line.

Greece and the Greek Cypriot administration cite the same body of law but draw different conclusions, as the next section explains.

Timeline

Date	Event
2004 onward	Türkiye begins submitting Eastern Mediterranean continental shelf coordinates to the UN
21 September 2011	Türkiye–TRNC Continental Shelf Delimitation Agreement signed
27 November 2019	Maritime memorandum signed with the GNA in Istanbul
6 December 2019	Greece expels the Libyan ambassador in Athens in protest
12 December 2019	European Council conclusions criticise the memorandum
18 March 2020	Türkiye registers its continental shelf outer limits with the UN
6 August 2020	Greece and Egypt sign a partial EEZ delimitation agreement
12 June 2025	Türkiye's Marine Spatial Planning is registered with IOC-UNESCO

For the wider context of Türkiye's coordinates, see the Crossroads Review explainer on Blue Homeland and the legal text analysis at Archive of Nations.

Key Players & Positions

Greece

The Greek Foreign Ministry holds that the memorandum is void with respect to Greece. It argues that Türkiye and Libya have no common maritime boundary without taking Crete and the other islands into account. Athens maintains that islands generate a continental shelf and an EEZ under Article 121(2) of UNCLOS, the 1982 UN Convention on the Law of the Sea, just as any other land territory does. Greece also contends that the memorandum disregards its sovereign rights. Greece expelled Libya's ambassador in December 2019 and later wrote to the UN Secretary-General.

The Greek Cypriot administration

The Greek Cypriot administration (the Republic of Cyprus, in EU usage) says the memorandum violates its own EEZ rights and international law. Ankara's counterposition is that the administration does not represent Turkish Cypriots, who are co-owners of the island and hold equal rights over its offshore resources. See Turkish Cypriot Hydrocarbon Proposals of 2011, 2012 and 2019.

Egypt

Egypt's Foreign Ministry stated that the memorandum has no legal effect on third states. It also questioned whether the Tripoli-based Presidency Council had the authority to conclude such a text under the Libyan Political Agreement of 2015. Cairo's practical concern is protecting the maritime space it considers its own, including space defined in its 2003 agreement with the Greek Cypriot administration and in the 2020 agreement with Greece. Türkiye objects to the 2003 agreement because it overlaps with Türkiye's continental shelf.

The European Union

The European Council's conclusions of 12 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. Turkish officials answer that the EU is not a party to any Turkish delimitation dispute and has no competence to adjudicate it.

Libya's internal divisions

The House of Representatives in the east of Libya rejected the memorandum in 2019. Authorities in Tripoli have defended it. Subsequent governments in Tripoli have continued to engage with Ankara. In October 2022 Türkiye and the Tripoli-based government signed a separate hydrocarbon exploration memorandum, which Greece and Egypt also criticised. Who speaks for Libya remains the most significant uncertainty for the memorandum.

Summary of positions

Actor	Core objection or stance	Primary source type
Greece	Islands have full maritime entitlements; memorandum ignores them	Foreign Ministry statements, letters to the UN
Greek Cypriot administration	Violation of EEZ and sovereign rights	Foreign Ministry statements
Egypt	No effect on third states; doubts about GNA authority	Foreign Ministry statements, UN communications
EU	Infringes third-state rights; contrary to the law of the sea	European Council conclusions, 12 December 2019
Türkiye	Equitable delimitation between mainland coasts; valid agreement	MFA statements, UN registration
Libyan east	Memorandum rejected	House of Representatives statements

🇹🇷 Strategic Doctrine · Primary Sources

Türkiye's Position — Türkiye's Strategic Doctrine

Ankara's argument rests on law, geography and the legitimacy of the Libyan party.

• Equity and mainland coasts. According to the Turkish Foreign Ministry, delimitation in the semi-enclosed Eastern Mediterranean must produce an equitable result. Turkish officials argue that small islands lying close to Türkiye's coast, but far from the Greek mainland, cannot cut off the maritime projection of the country with the longest coastline in the area. They cite the ICJ and arbitral practice above. The Fact Check on this subject is at Do Greek Islands Cancel Türkiye's Continental Shelf and Maritime Projection?.
• Valid agreement between two coastal states. Ankara argues that two states with opposite coasts are entitled to conclude a delimitation agreement, and that the agreement binds only its parties and does not alter third-state rights. In Ankara's view, areas where Greek or Egyptian claims overlap remain to be settled through negotiation, not through unilateral assertion.
• Legitimacy of the Libyan counterpart. Türkiye notes that UN Security Council Resolution 2259 (2015) welcomed the formation of the Government of National Accord under the Libyan Political Agreement, and that Ankara concluded the text with the UN-recognised government of the time.
• Legal position independent of UNCLOS. Türkiye is not a party to UNCLOS and has long objected to some of its provisions, including the Article 121 regime for islands. Ankara asserts that customary law and equity govern delimitation. It rejects the maximalist Seville Map which, in its view, confines Türkiye to a narrow strip in the Gulf of Antalya. See The Global Anatomy on the Seville Map.
• UN registration and the Turkish Cypriot dimension. Türkiye registered its continental shelf outer limits with the UN on 18 March 2020 and set out its maritime position in its Marine Spatial Planning, registered with IOC-UNESCO on 12 June 2025. Ankara states that no arrangement can be lasting if it excludes Türkiye and the TRNC, and it continues to cite President Erdoğan's 2020 call for an Eastern Mediterranean conference that would include all coastal states and the Turkish Cypriots.

The legal and historical basis combines the equity case law cited above, the customary-law argument and the Turkish Cypriot co-ownership thesis. Related analysis is at Borders & Blocs.

Source Comparison

The framing of the memorandum differs sharply by source type.

Aspect	Many Western and EU sources	Turkish primary sources
Basic description	An illegitimate or provocative deal disregarding islands	A bilateral delimitation between two coastal states
Role of islands	Full entitlement, including Crete	Limited or no effect where they distort an equitable result
Libyan authority	Disputed; contested by the eastern parliament	Concluded with the UN-recognised GNA
Law of the sea	UNCLOS Articles 121, 74 and 83	Customary law, equity and proportionality
Role of the EU	Entitled to express solidarity with members	Not competent to adjudicate delimitation
Cause of tension	Turkish unilateralism	Exclusion of Türkiye and Turkish Cypriots

Readers should compare the texts themselves. The text of the memorandum, the UN communications and the European Council conclusions are all public. Neutral overviews are also available at Regions & Powers. Our Editorial Principles explain how primary sources are used.

Horizon Outlook

Near term. The memorandum is likely to remain contested. The 2022 Tripoli hydrocarbon deal showed that exploration steps will keep drawing Greek and Egyptian protests. Cable and pipeline surveys near Crete and Kasos, such as those for the Great Sea Interconnector, are where friction is most likely to resurface.

Medium term. Two developments matter. First, the degree of unity in Libya: ratification or recognition by a unified Libyan authority would strengthen the memorandum, while continued eastern rejection would feed the arguments of its critics. Second, the state of Türkiye's maritime dialogue with Greece and Egypt, which have improved since 2023, though without any settlement of the maritime question.

Long term. The most durable outcomes would be negotiated delimitations or a regional conference of the kind Ankara proposes, or a judicial route accepted by all parties. Scenario analysis is in Horizon Scan: Three Scenarios for the Eastern Mediterranean Through 2030. The Cyprus dimension, which shapes who sits at any table, is discussed in Cyprus Horizon.

Key Terms & Related Guides

• Continental shelf: the seabed and subsoil extending from a state's coast, over which it holds sovereign rights for resources.
• EEZ (exclusive economic zone): a zone extending up to 200 nautical miles (about 370 km) from the baseline in which a coastal state holds rights over resources.
• Equity principle: the rule that delimitation should yield an equitable result, taking account of coastal geography and proportionality.
• Blue Homeland (Mavi Vatan): Türkiye's doctrine on its maritime jurisdiction areas in the Black Sea, Aegean and Mediterranean.
• Seville Map: a 2000s study prepared for the EU that Ankara rejects as a maximalist Greek and Greek Cypriot thesis.
• GNA: Libya's Government of National Accord, the Tripoli-based authority recognised by the UN in 2015 and in office in 2019.

Related guides: About The Political Horizon, Frequently Asked Questions: Sources, Method and Perspective, and the Region Scope explainer. Rules on islands and delimitation are applied by courts case by case, so outcomes elsewhere may differ.

The Political Horizon presents Türkiye's official perspective and legal positions alongside analysis of the wider strategic picture, and says so openly to its readers. Sections marked 'Türkiye's Position' reflect official Turkish policy as stated by Turkish government sources. Claims on Türkiye's doctrines are attributed to primary sources such as official statements, treaty texts, UN documents and state archives. Published by The Political Horizon Editorial Team.