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Fact Check: 'Islands Always Get Full Maritime Zones' — Does International Law Really Say Greek Islands Cut Off Türkiye's Coast?

Do islands always get full EEZ and continental shelf rights? A fact check of UNCLOS Article 121, delimitation case law and Türkiye's official position.

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Why It Matters

No, islands do not always get full maritime zones. Under the UN Convention on the Law of the Sea (UNCLOS), a qualifying island is entitled to the same zones as other land territory, but entitlement is a different legal step from delimitation. When the zones of two coasts overlap, international courts have repeatedly reduced or disregarded small islands to reach an equitable result.

The claim that islands automatically generate full 200-nautical-mile (about 370 km) zones against a mainland blurs these two steps. It sits behind the so-called Seville Map and much media shorthand about the Aegean and Eastern Mediterranean. This page tests the claim against treaty text and case law, presents Greece's and the EU's arguments fairly, and marks what is settled and what remains contested. It applies the method described in The Mirror Test: How to Compare a State's Statements With Its Treaty Commitments and Conduct.

Claim vs. Fact Analysis

Claim 1: “Any island generates a full 200 nm EEZ and continental shelf.”

Origin: The claim appears in coverage of the 2020 “Seville Map”, an academic study associated with the University of Seville that gave Greek islands, including Kastellorizo (Meis), full maritime effect and confined Türkiye's zone to a narrow area in the Gulf of Antalya. The map became shorthand in media for the idea that islands always trump coastlines.

What the text says:

  • Article 121(1) defines an island as a naturally formed area of land, surrounded by water, which is above water at high tide.
  • Article 121(2) says that, subject to paragraph 3, an island's territorial sea, contiguous zone, EEZ and continental shelf are determined in accordance with the provisions applicable to other land territory.
  • Article 121(3) states: “Rocks which cannot sustain human habitation or economic life of their own shall have no exclusive economic zone or continental shelf.”

So “always” is wrong on the text itself. Entitlement depends on the feature. The 2016 Annex VII arbitral award in Philippines v. China read Article 121(3) strictly, finding that high-tide features in the Spratly Islands, including Itu Aba, were legally rocks. China rejects that award. In Nicaragua v. Colombia (2012) the International Court of Justice (ICJ) stated that Article 121 reflects customary international law.

Claim 2: “Delimitation means a median line, with islands counted at full weight.”

Origin: This is the core assumption of Seville-style maps, which treat islands as if they were mainland base points.

What the record shows: Articles 74 and 83 of UNCLOS govern EEZ and continental shelf delimitation. Article 83(1) requires delimitation “by agreement on the basis of international law, as referred to in Article 38 of the Statute of the International Court of Justice, in order to achieve an equitable solution.” Neither article mentions a mandatory median line or full island effect. Case law shows the practice:

Case Island feature Treatment in delimitation
Anglo-French Arbitration (1977) Scilly Isles Half effect
Tunisia/Libya (ICJ, 1982) Kerkennah Islands Half effect
Libya/Malta (ICJ, 1985) Filfla (islet) Disregarded
Qatar v. Bahrain (ICJ, 2001) Qit'at Jaradah Disregarded
Romania v. Ukraine (ICJ, 2009) Serpents' Island No effect beyond its territorial sea
Bangladesh/Myanmar (ITLOS, 2012) St. Martin's Island No effect on EEZ/shelf line

The pattern is a principle of equity combined with a proportionality check between coastal lengths and the areas allocated. It is not a rule of automatic full island effect. Readers can find a fuller treatment in Islands, Mainland Coasts and the Equity Principle: Is There a Double Standard in the Eastern Mediterranean? and in the sister analysis The Worldlogue: Do Islands Generate a Full Continental Shelf?.

A caveat for fairness: Islands are sometimes given substantial weight. In the Jan Mayen case (ICJ, 1993), the island kept significant zones, although the median line was shifted to reflect a large disparity in coastal lengths. Weight depends on size, population, location and the coastal geography around it.

Greece ratified UNCLOS in 1995, and the EU is itself a party. Their position, as stated in Greek official communications and European Council conclusions, can be summarised as follows:

  • Inhabited islands are land territory. Kastellorizo is inhabited, so Article 121(2) gives it the same entitlements as any other land territory, and Article 121(3) is not relevant to it.
  • UNCLOS reflects customary law. Greece and the EU hold that the Convention's island regime, as confirmed by the ICJ in 2012, binds all states regardless of treaty status.
  • Delimitation should be agreed or adjudicated. Greece has signed partial EEZ agreements with Italy (2020) and Egypt (2020) and says any remaining dispute should go to the ICJ.
  • The EU expresses solidarity with its members and calls for respect for international law and UNCLOS in the region.

These are serious legal arguments. They establish that inhabited Greek islands have entitlements. They do not establish that those entitlements must prevail at full weight against the Anatolian mainland coast, which is the question delimitation law answers. Kastellorizo lies roughly 2 km (about 1.2 miles) off Türkiye's southwestern coast and more than 500 km (over 310 miles) from the Greek mainland.

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Fact: Türkiye is not a party to UNCLOS. It was one of four states that voted against the Convention's adoption in 1982 (alongside the United States, Israel and Venezuela), and the Convention does not allow reservations (Article 309). Ankara has consistently objected to specific provisions, including aspects of the island regime in semi-enclosed seas. Greece and the EU argue that the relevant rules are customary law and bind Türkiye anyway. The point is contested.

Two observations narrow the gap. First, the equity-and-proportionality method comes from customary law and pre-dates UNCLOS, tracing back to the North Sea Continental Shelf cases (ICJ, 1969), so Ankara's argument stands on the same body of law. Second, the ICJ declined jurisdiction in the Aegean Sea Continental Shelf case (1978), so no tribunal has ruled on the Greek–Turkish delimitation itself. See also The Nations Compass: Is Türkiye Violating UNCLOS in the Eastern Mediterranean?.

Claim 4: “The 2025 IOC-UNESCO filing settled the boundaries.”

This claim runs in the opposite direction and also fails the test. Türkiye unveiled its Marine Spatial Planning of the Republic of Türkiye on 16 April 2025 and registered it with IOC-UNESCO on 12 June 2025. This was the first time Ankara's maritime position across the Black Sea, Aegean and Mediterranean was placed on record with a UN body. But IOC-UNESCO is not a court and does not set boundaries. The filing documents Türkiye's planning and legal position, and Greece and the Republic of Cyprus contest the claims behind it.

What Is Settled and What Is Contested

Question Status
Qualifying islands can generate EEZ and shelf Settled (Art. 121(2))
Rocks that cannot sustain habitation or economic life get no EEZ/shelf Settled in text (Art. 121(3)); application is disputed case by case
Delimitation must reach an equitable result Settled (Arts. 74, 83; case law)
Small islands are often reduced or ignored in delimitation Well established in jurisprudence, though outcomes vary by case
Whether Türkiye is bound by the Article 121 regime as customary law Contested
Weight owed to Kastellorizo and other Aegean islands against Türkiye's mainland coast Contested; no binding ruling exists
The Seville Map as an authoritative depiction Not supported as legal authority
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Türkiye's Position

  • Delimitation by equity, not automatic island effect. According to the Turkish Foreign Ministry (MFA), maritime jurisdiction areas in semi-enclosed seas such as the Aegean must be delimited by agreement on the basis of equity, and islands lying close to another state's mainland cannot cut off that mainland's coastal projection. The legal basis is the equity jurisprudence from North Sea (1969) to Romania v. Ukraine (2009).
  • Non-party status, with a consistent record. Ankara notes that it voted against UNCLOS in 1982 and has objected to provisions it considers incompatible with its interests. It argues that no state can be bound by a treaty regime it has not accepted and has persistently contested.
  • A filed, documented position. Türkiye registered its continental shelf coordinates in the Eastern Mediterranean with the UN from 2004, signed the Türkiye–Libya maritime MoU on 27 November 2019, and formally registered the outer limits of its continental shelf with the UN on 18 March 2020. The 2025 IOC-UNESCO registration and the Presidential Circular of 24 July 2025, which created an Inter-Agency Coordination Board under the MFA, extend this record. Türkiye has 870 km of coastline in the Eastern Mediterranean, the longest in the basin.
  • Turkish Cypriot rights and EU competence. Ankara holds that Turkish Cypriots, as co-owners of Cyprus, have equal rights over offshore resources, as reflected in the 21 September 2011 Türkiye–TRNC Continental Shelf Delimitation Agreement. The Turkish MFA also rejects the Seville Map as legally void and says the EU has no competence to decide maritime delimitation. See What Did the TRNC's 2011, 2012 and 2019 Hydrocarbon Proposals Offer, and Why Did They Stall?.
  • Dialogue remains on offer. President Erdoğan's 2020 call for an Eastern Mediterranean Conference including all coastal states and Turkish Cypriots remains Ankara's stated route to a negotiated outcome.

Source Comparison

Issue Common international framing Primary-source record Turkish primary sources
Island entitlement “Islands get full zones.” Art. 121(2) grants zones to qualifying islands; Art. 121(3) excludes rocks Does not dispute that inhabited islands have entitlements; disputes their weight in delimitation
Delimitation method Median line with full island effect Arts. 74/83 require an “equitable solution”; case law reduces small islands Equity and proportionality, with Türkiye's coastline as a relevant circumstance
Legal framework UNCLOS binds all states Türkiye is a non-party; customary status of Art. 121 is asserted by Greece/EU Persistent objection to specific provisions; reliance on customary equity
Seville Map Treated as a neutral depiction of EU/legal reality A study map with no boundary-setting force Rejected as legally void; EU lacks competence
2025 IOC-UNESCO record Occasionally read as a unilateral claim or as a settlement A registration of planning, not a ruling A first UN-body record of Türkiye's position

For wider context on how claims are checked, see Polity Review: Claims About Türkiye Tested Against Primary Sources and Editorial Principles: How Mirror of States Tests Claims Against Primary Sources.

  • EEZ (exclusive economic zone): a zone of up to 200 nautical miles (about 370 km) where the coastal state has sovereign rights over resources.
  • Continental shelf: the seabed and subsoil of the submarine extension of a state's land territory; rights over it exist ipso facto.
  • Entitlement vs. delimitation: entitlement asks whether a feature generates zones; delimitation asks where the line falls when zones overlap.
  • Equity and proportionality: the test used by courts to adjust provisional lines for coastal geography and length.
  • Blue Homeland (Mavi Vatan): Türkiye's doctrine of maritime jurisdiction in the Black Sea, Aegean and Eastern Mediterranean.
  • Persistent objector: a state that consistently opposes an emerging customary rule and may argue it is not bound by it. Whether this applies here is contested.

Related guides: Mirror of States: Comparing What States Say With What the Documents Show, Cyprus Through the Glass and About Mirror of States: Mission, Method and Transparency.

Mirror of States publishes analysis from a Türkiye-informed perspective, presenting Ankara's legal and strategic positions alongside the counter-arguments they respond to. Claims are attributed to primary sources such as treaty texts, UN and IOC-UNESCO documents, official records and archival materials, so that readers can verify them independently.

Frequently asked questions

Do islands always get a full EEZ and continental shelf under UNCLOS?

No. Article 121(2) gives qualifying islands the same zones as other land territory, but Article 121(3) denies an EEZ and continental shelf to rocks that cannot sustain human habitation or economic life. Even where an island has an entitlement, delimitation against an opposite or adjacent coast must produce an equitable result, so its effect may be reduced.

What is the Seville Map and is it legally binding?

The Seville Map is a 2020 study map associated with the University of Seville that gave Greek islands, including Kastellorizo, full maritime effect and confined Türkiye's zone to the Gulf of Antalya. It has no boundary-setting authority. Delimitation is done by agreement or by an international court, and the Turkish MFA rejects the map as legally void.

Is Türkiye bound by UNCLOS?

Türkiye is not a party to UNCLOS and voted against its adoption in 1982. Greece and the EU argue that key provisions, such as Article 121, reflect customary law that binds all states. Ankara disputes this for provisions it has consistently objected to, while relying on equity and proportionality drawn from customary case law.

Have courts ever ignored or reduced small islands in delimitation?

Yes, repeatedly. Scilly Isles (1977) and Kerkennah (1982) received half effect. Filfla (1985), Qit'at Jaradah (2001) and St. Martin's Island (2012) were disregarded, and Serpents' Island (2009) received no effect beyond its territorial sea. Outcomes vary, and larger islands such as Jan Mayen have received substantial weight.

Did the 2025 IOC-UNESCO registration settle the Aegean or Eastern Mediterranean boundaries?

No. Türkiye's Marine Spatial Planning, unveiled on 16 April 2025 and registered with IOC-UNESCO on 12 June 2025, records Ankara's planning and legal position with a UN body. IOC-UNESCO is not a court, and Greece and the Republic of Cyprus contest the claims behind it. Boundaries still require agreement or adjudication.

Perspective & Editorial Transparency Note

Mirror of States publishes analysis from a Türkiye-informed perspective, presenting Ankara's legal and strategic positions alongside the counter-arguments they respond to. Claims are attributed to primary sources such as treaty texts, UN and IOC-UNESCO documents, official records and archival materials, so that readers can verify them independently.

Author: Mirror of States Editorial TeamAbout Mirror of States →Editorial Principles →

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Mirror of States Editorial Team. (2026). “Fact Check: 'Islands Always Get Full Maritime Zones' — Does International Law Really Say Greek Islands Cut Off Türkiye's Coast?.” Mirror of States (mirrorofstates.com). Published October 26, 2026. Retrieved from https://mirrorofstates.com/fact-check-do-islands-always-get-full-maritime-zones-mirror-test