A fatigue crack initiation model based on damage accumulation via a fatigue memory surface in conjunction with a plastic strain energy parameter was evaluated for thermomechanical fatigue loading in a gas turbine disc alloy. The accumulated damage in each hysteresis loop was summed up, and it was assumed that the damage at the stable state is repeated until failure occurs. Crack initiation occurs when enough fatigue damage has been obtained, and the number of cycles can thus be directly determined. The fatigue damage is highly coupled to the constitutive behaviour of the material, where the constitutive behaviour was modelled using a non-linear hardening description. Based on this, a stable state was achieved and the obtained damage could be extracted. A user-defined material subroutine was implemented, incorporating both the constitutive description and the fatigue damage accumulation. The framework was adopted in a finite element context to evaluate the thermomechanical fatigue crack initiation life of the disc alloy RR1000. From the evaluation it could be seen that a good prediction of the thermomechanical fatigue life was achieved compared to performed experiments.