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Ankara Reopens the “Grey Zones” Dispute: Turkey Challenges Greek Sovereignty Over Aegean Islets

Ankara Reopens the “Grey Zones” Dispute: Turkey Challenges Greek Sovereignty Over Aegean Islets
Turkey is using Greece’s new Special Spatial Framework for Tourism to revive claims over islands and rocky formations it says were “not ceded to Greece by international treaties” — a dispute that goes far beyond tourism and reaches into the heart of the “Blue Homeland” strategy

A seemingly technical Greek decision on tourism planning has, within hours, turned into a new geopolitical dispute between Athens and Ankara.

Reacting to Greece’s Special Spatial Framework for Tourism, Turkey has revived one of its most sensitive and controversial claims in the Aegean: that there are “geographical formations whose sovereignty was not ceded to Greece through international treaties.”

The wording does not mean that Ankara is claiming that all Aegean islands are non-Greek. That would be inaccurate.

It does, however, mean something extremely serious: Turkey is formally reiterating its long-standing “grey zones” doctrine, under which it disputes Greek sovereignty over certain islets and rocky formations.

And that position has now once again appeared in an official Turkish Foreign Ministry statement.

The phrase that set alarm bells ringing in Athens

Turkish Foreign Ministry spokesperson Öncü Keçeli said the Greek tourism framework:

“will have no legal consequences for Turkey in the context of the interconnected Aegean issues between the two countries, including certain geographical formations whose sovereignty was not ceded to Greece through international treaties.”

This is effectively a repetition of the position Ankara voiced in July 2025 over Greece’s marine parks.

At the time, the Turkish Foreign Ministry used almost identical language, referring to “islands, islets and rocks” whose sovereignty, in Turkey’s view, had not been transferred to Greece.

So this is not a one-off rhetorical flare-up.

It is a standing strategic position of the Turkish state.

Turkey is turning a domestic Greek planning decision into a sovereignty dispute

Greece’s Special Spatial Framework is an internal planning instrument governing tourism development, land use, carrying capacity and environmental protection.

Turkey, however, is seeking to attach an external geopolitical dimension to it.

Its argument is that because the framework covers island and maritime areas in the Aegean, it cannot have consequences for Turkey in areas where Ankara believes unresolved disputes exist.

For Athens, this is precisely the problem.

Turkey is attempting to widen the agenda of Greek-Turkish disputes well beyond the delimitation of the continental shelf and Exclusive Economic Zone.

What does the Treaty of Lausanne actually say?

The legal framework is considerably more specific than Turkey’s broad formulation suggests.

Article 12 of the 1923 Treaty of Lausanne confirmed Greek sovereignty over major eastern Aegean islands including Lemnos, Samothrace, Lesbos, Chios, Samos and Ikaria, subject to the treaty’s specific exceptions.

The same article provides that, unless otherwise stipulated, islands lying within three miles of the Asiatic coast remain under Turkish sovereignty.

In other words, Lausanne did not leave an undefined sovereignty vacuum across the Aegean.

It established a legal framework.

And what about the Dodecanese?

The Dodecanese were transferred to Greece under the 1947 Paris Peace Treaty, when Italy ceded sovereignty over the islands to Greece.

This forms a central part of Athens’ response to the “grey zones” theory: sovereignty over the islands and their dependent islets has been regulated through international treaties and cannot simply be reopened decades later through unilateral reinterpretation.

Turkey takes a different view.

It argues that certain smaller formations were either not expressly named or not specifically transferred.

That argument forms the legal basis of Ankara’s “grey zones” doctrine.

The real issue is not tourism

No serious observer believes this dispute is fundamentally about hotel zoning or tourism investment.

Turkey’s reaction follows a much deeper strategic logic.

Any Greek administrative act that:

defines areas,

regulates activity,

creates marine parks,

authorises energy infrastructure,

or organises economic use in island or maritime space

can be interpreted by Ankara as an indirect assertion of Greek jurisdiction.

That is why Turkey responds.

From marine parks to tourism planning: the same pattern

The same dynamic played out in 2025 over Greece’s marine parks in the Aegean.

Turkey argued then that the establishment of the parks could not affect its positions on Aegean disputes and again referred to formations whose sovereignty it claimed had not been transferred to Greece.

Now the same vocabulary has resurfaced over tourism planning.

Tomorrow, the issue could involve submarine cables, offshore wind farms or other infrastructure.

That suggests Ankara is systematically building a record of objections, ensuring that none of these Greek acts can later be interpreted as having been tacitly accepted by Turkey.

“Do not weaponise the environment,” Ankara says

Turkey also accused Greece of attempting to use “universal values”, such as environmental protection, for political purposes.

It deployed the same argument in the marine parks dispute.

Athens’ position is fundamentally different: carrying out administrative and environmental responsibilities within Greek territory is an inherent sovereign right and does not require the consent of another country.

That exposes the deeper conflict between the two sides:

Athens sees an exercise of sovereignty. Ankara sees an attempt to create faits accomplis.

Turkey also invokes the Law of the Sea

The Turkish statement argues that unilateral actions should be avoided in enclosed or semi-enclosed seas such as the Aegean and Mediterranean and says international maritime law encourages cooperation between coastal states, including on environmental issues.

The reference is notable because Turkey is not a party to the UN Convention on the Law of the Sea, UNCLOS.

Greece has ratified the Convention and maintains that it exercises the rights deriving from it.

This does not mean every principle of the Law of the Sea is irrelevant to Turkey — many provisions are widely regarded as customary international law.

But it illustrates just how deep the disagreement is over interpretation.

The Athens Declaration enters the dispute again

Perhaps even more strikingly, Turkey concluded its statement by invoking the Athens Declaration on Friendly Relations and Good-Neighbourliness of December 7, 2023, arguing that the two countries should pursue a sincere and comprehensive approach based on international law, equality and good-neighbourly relations.

That recreates the familiar paradox of recent Greek-Turkish relations.

Athens and Ankara say they want calm.

They maintain open channels.

They speak about cooperation.

And yet they still disagree over what the disputes themselves actually are.

Greece considers the principal legal dispute to be the delimitation of the continental shelf and EEZ.

Turkey speaks of a much broader collection of “interconnected Aegean issues”.

That broader agenda includes sovereignty.

This is Athens’ real red line

For Greece, sovereignty over Greek islands is not a negotiable issue.

That fundamentally distinguishes it from maritime delimitation.

The delimitation of an EEZ or continental shelf can, under certain conditions, be negotiated or referred to international adjudication.

Greek sovereignty is not treated by Athens as an unresolved bilateral dispute.

That is why every revival of the “grey zones” narrative generates such concern.

Imia/Kardak still casts a long shadow

The theory of grey zones acquired real geopolitical significance after the 1996 Imia/Kardak crisis.

Since then, Turkey’s position has extended beyond Imia itself to a wider group of small geographical formations in the Aegean.

That is what makes the latest statement important.

It is not merely a generic diplomatic protest.

It is a repetition of a strategic sovereignty challenge that has, in the past, brought Greece and Turkey close to armed confrontation.

And behind it all stands the “Blue Homeland”

The Turkish statement must also be read in the wider context of the Mavi Vatan — “Blue Homeland” — doctrine.

That doctrine treats the maritime spaces around Turkey as central arenas of strategic competition.

EEZs.

Continental shelves.

Islands.

Energy infrastructure.

Marine parks.

Subsea cables.

These are no longer viewed as separate technical files.

They are increasingly folded into a single concept of maritime power.

Why now?

The timing is also significant.

The Eastern Mediterranean is entering another period of diplomatic and strategic activity.

The Greece-Cyprus electricity interconnector is moving forward.

French investment group Meridiam has entered the Great Sea Interconnector project.

Greece is strengthening its military capabilities.

Greek-Libyan technical talks on maritime delimitation continue.

And another Mitsotakis-Erdoğan meeting may take place in the coming months.

In such an environment, both sides are trying to lock in their positions before the next major diplomatic phase.

Ankara wants one thing to remain absolutely clear

Turkey does not want the period of relative calm in Greek-Turkish relations to be interpreted as abandonment of its older claims.

That is why it responds whenever it believes Athens is taking an administrative step that could carry legal or political weight in the Aegean.

Calm does not mean settlement.

The latest dispute over tourism planning makes that unmistakably clear.

The real message has nothing to do with hotels or tourism zones

It concerns who has the right to decide in the Aegean.

Greece’s answer is: the sovereign state, within its territory and areas of jurisdiction, in accordance with international law.

Turkey’s answer is that unresolved issues remain and cannot be bypassed through “unilateral actions”.

And that is where the most dangerous phrase in Greek-Turkish relations returns once again:

“grey zones.”

The fact that it has resurfaced not over a military exercise, but over a tourism planning framework, reveals the deeper problem in the relationship:

almost any technical issue in the Aegean can still be transformed, within hours, into a question of sovereignty.

Source: pagenews.gr

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