Data protection & privacy laws in Turkey (2026)

Annual inflation-linked revaluation pushed the maximum per-violation fine to TRY 17,092,242 — the highest since the law's enactment — with the full fine band for data-security failures now running TRY 256,000–17,092,242, reflecting Turkey's standard statutory revaluation mechanism.

The Personal Data Protection Board approved a data-sharing arrangement between the Directorate General of Migration Management and UNHCR — the first formal authorization under the June 2024 cross-border transfer regime — establishing the template for international data flows with intergovernmental organizations.

The KVKK Authority concluded a nationwide audit of data-controller registry compliance and imposed cumulative fines of approximately TRY 504 million on domestic and foreign organizations — including public bodies — for failure to register with or notify VERBİS, marking a decisive shift from guidance to active enforcement.

Implementing rules for the overhauled Article 9 of Law 6698 were published in Official Gazette No. 32598, detailing adequacy decisions, standard contractual clauses (SCCs), and binding corporate rules (BCRs), and requiring controllers to notify the Board within five business days of executing SCCs.

The most significant reform of Law 6698 since enactment took effect, replacing the consent-only cross-border transfer rule with a GDPR-aligned three-tier mechanism (adequacy decision → SCCs/BCRs → Board authorisation) and introducing expanded lawful bases for processing special-category data.

The Board imposed TRY 1.95 million on WhatsApp for conditioning continued app access on acceptance of a 2021 policy update that bundled data-sharing with Meta, ruling that tying service to explicit consent violates KVKK's requirement that consent be freely given.

In Decision No. 2019/104 the Board fined Facebook TRY 1.65 million — the first major fine against a global tech platform under KVKK — for failing to implement adequate technical safeguards that allowed third-party apps to access ~300,000 Turkish users' photos via an API bug, and for delayed notification to the Authority.

The secondary legislation establishing the mandatory online Data Controllers Registry (VERBİS) took effect, requiring data controllers above prescribed thresholds to register before processing personal data — creating Turkey's central compliance infrastructure and the basis for subsequent enforcement sweeps.

After all nine Board members were appointed, Turkey's independent supervisory authority (Kişisel Verileri Koruma Kurumu) began accepting complaints, opening investigations, and publishing guidance — completing the institutional enforcement framework required by Law No. 6698.

Turkey's first comprehensive data-protection statute was published in the Official Gazette, establishing data-subject rights, lawful bases for processing, obligations on controllers and processors, and the independent Personal Data Protection Board — modelled on EU Directive 95/46/EC and enacted weeks before the EU finalised GDPR.