Information technology law in Turkey is the body of legislation governing how digital systems, personal data, online content, electronic commerce and software are regulated, and it is now anchored by four statutes: Law No. 7545 on Cybersecurity, Law No. 6698 on the Protection of Personal Data, Law No. 5651 on Internet Publications, and Law No. 6563 on the Regulation of Electronic Commerce.
Most foreign companies encounter this field the same way. Something operational happens first. A hosting decision, a group-wide data platform, a marketplace listing, a security incident at a vendor. The legal question arrives afterwards, usually from a Turkish employee who has read a notification requirement and cannot tell whether it applies to the company or not.
Which Turkish laws actually apply to a company that runs technology here? More than most expect, and the boundary is not the company’s sector. Law No. 7545 reaches into cyberspace generally rather than into a defined industry, Law No. 6698 follows the personal data wherever it is processed, and Law No. 6563 attaches to the way goods and services are sold online rather than to what is being sold. The companies most exposed to Turkey’s newest technology statute are frequently the ones that do not consider themselves technology companies at all.
What actually changed recently? The single largest change is the Cybersecurity Law. It was adopted on 12 March 2025 and entered into force on 19 March 2025 upon publication in the Official Gazette (Resmî Gazete) No. 32846. It created a Cybersecurity Directorate (Siber Güvenlik Başkanlığı), established a Cybersecurity Board as the senior policy organ, and attached administrative fines that reach into the hundreds of millions of Turkish lira, alongside new criminal offences.
How does a foreign company know whether it is in scope? By looking at connectivity rather than at sector classification. The Law covers information systems connected directly or indirectly to the internet, to electronic communication networks or to computer networks, and the persons operating within that environment. A logistics company with a customer portal, a manufacturer with a remote maintenance link and a bank all sit inside the same perimeter.
When do the numbers stop being reliable? Sooner than the published articles suggest. Several thresholds in this field are fixed in the statute and revised every year, which is why a page that quotes a 2022 figure with confidence is usually quoting something that no longer exists. The electronic commerce thresholds, for instance, are recalculated annually from the trade registry data and announced on the Ministry’s website by February. The safe approach is to know the mechanism and check the current figure, not to memorise a number.
⚖️ Which Turkish statutes apply to a technology operation, and who enforces them?
Four statutes carry most of the weight, and each has a different regulator, which means a single incident can generate three separate compliance obligations at once.
Law No. 7545 on Cybersecurity is administered by the Cybersecurity Directorate. Law No. 6698 on the Protection of Personal Data is administered by the Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu) and its Board. Law No. 5651 on Internet Publications operates largely through the Information and Communication Technologies Authority (Bilgi Teknolojileri ve İletişim Kurumu) and the criminal judgeships of peace. Law No. 6563 on Electronic Commerce sits with the Ministry of Trade (Ticaret Bakanlığı).
The practical consequence of that fragmentation shows up during incidents. A breach affecting customer records can simultaneously trigger a cybersecurity notification obligation, a personal data breach assessment, and, where the company operates a marketplace, questions from a third regulator. Companies that have mapped their obligations to a single framework, usually GDPR inherited from a European parent, tend to discover the gap at the worst possible moment.
There is also a jurisdictional point that surprises groups with a light Turkish footprint. None of these statutes is limited to companies incorporated in Turkey. Obligations attach to activity, to data, to systems and to the offering of services, which means a foreign entity without a Turkish subsidiary can still fall inside more than one of them.
⚖️ What did the Cybersecurity Law No. 7545 change?
It created Turkey’s first horizontal cybersecurity framework, replacing an arrangement that had previously been handled through sectoral regulation and ministerial circulars.
The Law was adopted by the Grand National Assembly on 12 March 2025 and entered into force on 19 March 2025 with its publication in the Official Gazette No. 32846. Its stated purpose is to prepare private persons and bodies of a public nature in Turkey for cyber attacks originating internally and externally.
Three structural changes matter for foreign companies. The first is institutional: the Cybersecurity Directorate now consolidates technical functions including threat analysis, penetration testing, malware analysis and incident response, and the Cybersecurity Board sits above it as the senior decision-making organ on strategy and policy. The second is the sanction architecture, which combines administrative fines with imprisonment for specified offences. The third is the scope, which is discussed separately below because it is the provision that most often catches companies by surprise.
What the Law did not do is replace the personal data regime. Cybersecurity obligations under Law No. 7545 and data protection obligations under Law No. 6698 run in parallel, are enforced by different authorities, and are not satisfied by a single compliance programme. A company that has completed a data inventory and appointed a contact person has addressed one of the two, not both.
⚖️ The scope problem: why the Law reaches companies that are not technology companies
The Cybersecurity Law defines its perimeter by connectivity rather than by industry, and that single drafting choice pulls in most of the commercial economy.
The Law covers all information systems connected directly or indirectly to the internet, to electronic communication networks or to computer networks, together with those operating in the environment formed by the networks linking them, which is to say those present in cyberspace. Almost everyone falls inside that description.
Consider what this means in practice for three companies that would not describe themselves as being in the technology sector. A textile manufacturer with a supplier portal and networked production machinery is in scope. A hotel group with a booking engine and a property management system is in scope. A freight forwarder with an electronic tracking interface for customers is in scope. None of them has a chief information security officer, and all three now carry obligations whose breach is measured in millions of lira.
The mismatch this creates is organisational rather than legal. Cybersecurity obligations in these companies sit with an IT manager who reports to a finance director, has no legal budget line, and learns about the requirement through a vendor newsletter. Legal exposure accumulates in a part of the organisation that has no mechanism for escalating it.
Foreign parents add a second layer. Where the Turkish subsidiary’s systems are administered from a group data centre abroad, the obligations still attach locally, but the ability to comply, to open systems for inspection, to produce documentation, to implement measures, depends on decisions taken in another country. That gap has to be closed contractually inside the group before an inspection makes it visible.
Not sure whether your Turkish operation falls inside the Cybersecurity Law?
A scope assessment usually takes one working session and tells you which of the four statutes actually attach to your systems.
⚖️ Obligations and penalties under Law No. 7545
The Law attaches administrative fines in bands, and the highest band is reserved for acting without a required approval rather than for a security failure.
Where persons providing services, collecting or processing data through information systems fail to perform their duties and responsibilities, an administrative fine of between 1 million and 10 million Turkish lira applies. Where an approval of the Directorate is required and has not been obtained, the fine ranges from 10 million to 100 million Turkish lira. Where those subject to inspection fail to keep the relevant devices, systems, software and hardware open to inspection within the periods given, or fail to provide and maintain the infrastructure necessary for the inspection, the fine ranges from 100,000 to 1 million Turkish lira.
For commercial companies, one of these bands is calculated differently. Where the obligations concerned are not performed by commercial companies, the fine may reach up to 5 per cent of the gross sales revenue shown in the independently audited annual financial statements, and may not be less than 100,000 Turkish lira. A revenue-linked ceiling changes the risk calculation for a large group in a way that a fixed lira band does not.
Repetition is treated explicitly. Where it is established that one of the administrative offences defined in the Law has been committed more than once before an administrative sanction decision is issued, a single fine is imposed on the person concerned and increased, without exceeding twice the amount. Where a benefit has been obtained or loss caused, the fine may not be less than three times and not more than five times that benefit or loss.
Criminal liability sits alongside the fines. Failure to provide information, documents, software, data or hardware requested by the competent authorities and inspectors, or obstruction of their provision, carries imprisonment and a judicial fine. Carrying out activity without the approvals, authorisations or permits required under the Law also carries imprisonment and a judicial fine. Breach of the confidentiality obligation, unauthorised sharing or offering for sale of personal data or data within the scope of critical public services in cyberspace, and creating or disseminating false cybersecurity data all carry imprisonment.
Payment and appeal follow a defined route. Administrative fines imposed by the Directorate are paid within one month of notification. Fines not paid within that period and which have become final are collected by the tax offices under Law No. 6183 on the Procedure for the Collection of Public Receivables. Administrative fine decisions issued under the Law may be challenged before the administrative courts.
⚖️ Export approval and transactions involving cybersecurity companies
Sales abroad of cybersecurity products and corporate transactions involving cybersecurity companies are subject to a control regime that operates independently of ordinary export legislation.
Under the Law, the sale abroad of cybersecurity products, systems, software, hardware and services is carried out in accordance with the procedures and principles to be determined by the Directorate, and for products subject to permission under those procedures, the approval of the Directorate is obtained. Transactions such as mergers, demergers, share transfers and sales involving cybersecurity companies are notified to the Directorate, and specified transactions are subject to its approval.
The commercial significance of this provision is easy to underestimate. A software company established in Turkey with a foreign parent may find that a routine intra-group reorganisation, or the sale of a product line to an overseas customer, requires an approval that has no analogue in the group’s other jurisdictions. Where that approval is not obtained, the applicable fine band is the highest one in the Law, between 10 million and 100 million Turkish lira.
This matters at two moments in particular. The first is during a transaction, where the approval requirement has to appear in the conditions precedent rather than being discovered in diligence. The second is during product launch planning, where an export-facing roadmap built without reference to the permission regime can require restructuring after commitments have been made to customers. Where a transaction is contemplated, the interaction with general company law is addressed alongside our corporate law practice in Turkey.
⚖️ Personal data: Law No. 6698 and the transfer regime after 2024
Turkey’s personal data regime changed substantially in 2024, and the change was structural rather than cosmetic: consent stopped being the ordinary route for sending data abroad.
Article 34 of Law No. 7499 amended Article 9 of Law No. 6698, headed transfer of personal data abroad. Law No. 7499 was published in the Official Gazette No. 32487 dated 12 March 2024, and the amendments to the data protection statute entered into force on 1 June 2024.
The amended architecture works in three tiers. The first is an adequacy decision for the destination country. Where no adequacy decision exists, personal data may be transferred abroad by data controllers and data processors where one of the appropriate safeguards is provided by the parties, on condition that the data subject also has the ability to exercise rights and pursue effective legal remedies in the country of transfer. Where neither an adequacy decision nor an appropriate safeguard is available, transfer remains possible only on an incidental basis, on one or a few occasions and without continuity, under the exceptional grounds.
Two of the appropriate safeguards are the ones foreign groups actually use. Standard contracts allow transfer without a separate authorisation once signed. Binding corporate rules, containing provisions on the protection of personal data which companies within a group of undertakings engaged in a joint economic activity are obliged to comply with, permit transfers between those companies without a separate authorisation from the Board once approved. By decision No. 2024/959 dated 4 June 2024, the Board adopted the standard contract texts, the binding corporate rules application forms and the guidance documents on the essential elements those rules must contain.
The standard contract route carries a deadline that is frequently missed. A new administrative offence was introduced for data controllers and data processors that fail to notify the Board of a standard contract within five business days of its signature, with an administrative fine of between 50,000 and 1 million Turkish lira. The obligation is not the signing. It is the notification afterwards.
One further change is procedural and works in the data controller’s favour. Administrative fines imposed by the Board are now challenged before the administrative courts, replacing the previous route through the criminal judgeships of peace. For a foreign company, that means the forum reviewing a data protection fine is one that ordinarily examines administrative acts, rather than one designed for a different purpose.
⚖️ Employee data and group HR systems
The transfer question reaches foreign companies through their own staff records long before it reaches them through customer data.
A Turkish subsidiary of an international group almost always processes employee data on a platform administered abroad. Payroll, performance management, leave, expense and identity systems are consolidated at group level precisely because consolidation is efficient, and the consolidation itself constitutes a continuous transfer of personal data out of Turkey.
That continuity closes off one of the three routes. Transfers on the exceptional grounds are available only where the transfer is incidental, made on one or a few occasions and without continuity. A group HR platform is the opposite of incidental, which means the company needs either an adequacy decision covering the destination or one of the appropriate safeguards, and in most group structures that means a standard contract or binding corporate rules.
Binding corporate rules are the better fit where the structure justifies the effort, because they cover transfers between companies within a group of undertakings engaged in a joint economic activity and, once approved by the Board, permit those transfers without a separate authorisation. The trade-off is preparation time, which is why groups facing an immediate deployment usually begin with standard contracts and move to binding corporate rules afterwards.
Employee monitoring raises a second question that is frequently conflated with the first. Logging, device management and security tooling deployed for cybersecurity purposes under Law No. 7545 process employee personal data, and the fact that the underlying measure is legally required does not by itself resolve the data protection analysis. The two obligations have to be reconciled rather than traded off, and the reconciliation belongs in the internal documentation before deployment rather than in a response to a complaint afterwards.
⚖️ Incident response: obligations that run in parallel
A single security incident can activate three separate notification duties, each owed to a different authority and each running on its own timetable.
The cybersecurity duty comes first in practice. Law No. 7545 requires those within its scope to take the prescribed cybersecurity measures and to report detected vulnerabilities and incidents. Failure to perform that duty falls in the band attracting an administrative fine of between 1 million and 10 million Turkish lira, which places incident reporting in the same exposure category as the underlying security obligations rather than in a lesser one.
The personal data duty is separate and is owed to a different regulator. Where an incident involves personal data, the assessment and notification obligations under Law No. 6698 apply independently of anything done under the cybersecurity framework, and satisfying one does not discharge the other. The timetable and the form of that notification are set by the Board rather than by the statute itself, which is why the applicable requirement has to be checked against the current decision rather than against a summary.
The content duty arises where the incident produces material online. Where a court decision establishing unlawfulness is notified to a social network provider, the twenty four hour compliance period applies, and a business seeking removal of leaked commercial information operates inside that framework rather than outside it.
What this means operationally is that the first day is a legal exercise as much as a technical one. Decisions taken in the initial hours, what is written in the internal incident log, what is communicated to customers, which systems are taken offline and what is preserved, determine the position that can later be presented to three regulators. Companies that treat the first day as purely an engineering problem routinely find that the record created during it is the record they have to defend.
⚖️ Content, hosting and platform liability under Law No. 5651
Law No. 5651 governs unlawful content online, and its timetables are measured in hours rather than in weeks.
The Law regulates the obligations and responsibilities of content providers, hosting providers, access providers and mass-use providers, together with the mechanisms for dealing with unlawful content. It defines a social network provider as a natural or legal person enabling users to create, view or share content such as text, image, sound and location online for the purpose of social interaction.
The core timetable is short. Where content whose unlawfulness has been established by a judge or court decision is notified to a social network provider, the provider must comply with the requirements of that decision within twenty four hours. A provider that fails to remove the content or block access within twenty four hours despite the notification is liable for the resulting damage. Applications made under the relevant provisions of the Law are separately subject to a forty eight hour reasoned response requirement.
Representation obligations attach above a usage threshold. Social network providers with daily access from Turkey above the statutory threshold must designate at least one authorised person in Turkey to handle notifications, requests and applications, and must publish that representative’s contact details, including a Turkish address for service and an email address, in a manner that is easily visible and directly accessible on their website. Changes to the representative’s details must be notified to the Authority within twenty four hours.
For most foreign companies the relevance of this statute is defensive rather than compliance-driven. Businesses facing defamatory content, counterfeit listings, impersonation accounts or leaked commercial information use the removal and access-blocking mechanisms as a remedy. Evidence preservation matters more than speed at the outset, because content is frequently altered once a process begins, and screenshots without URLs and timestamps rarely survive scrutiny. Where the underlying dispute is commercial rather than purely content-based, the removal route often runs in parallel with proceedings handled through commercial litigation.
⚖️ Electronic commerce: Law No. 6563, ETBİS and the licence
Turkey’s electronic commerce regime distinguishes between registration and licensing, and companies routinely assume that completing the first discharges the second.
Law No. 6563 was substantially rewritten by Law No. 7416 dated 7 July 2022, which introduced new categories, most importantly the electronic commerce intermediary service provider, defined as the provider enabling contracts to be concluded or orders to be placed for the goods or services of electronic commerce service providers in an electronic commerce marketplace. Different obligations attach depending on which category a business falls into and on the scale it has reached.
Scale is measured by net transaction volume and transaction count, and the thresholds move. The monetary thresholds specified in the Law are increased each year according to the annual rate of change in electronic commerce volume calculated using ETBİS data, and those thresholds, together with the annual rate of change, are announced on the Ministry’s website by the end of February at the latest. This is the mechanism that makes published figures unreliable: a threshold accurately reported in one year is simply the wrong number in the next. The thresholds are fixed in the statute and they change every February.
Registration and licensing are separate obligations. Registration in ETBİS does not remove the licensing obligation from a business that meets the scale conditions, and a licence application, where required, is renewed annually while the thresholds continue to be exceeded. The licence fee is calculated on a tiered basis, applying different rates to bands of net transaction volume.
The definitional trap is financial rather than legal. Gross sales, accounting turnover, commission income and net transaction volume are four different concepts, and a calculation performed on the wrong figure produces the wrong conclusion about which obligations apply. Companies that determine their category from management accounts rather than from the statutory definition tend to under-classify themselves.
One further point survives the 2022 rewrite. The repeal of the former data provision in Law No. 6563 did not create freedom to use customer data. Obligations under Law No. 6698 continue to apply to electronic commerce businesses independently, which returns the analysis to the transfer regime described above. Businesses setting up a Turkish sales entity for the first time should read this alongside our work on business formation and licensing in Turkey.
⚖️ Artificial intelligence: which of these regimes it lands in
There is no binding framework statute governing artificial intelligence in Turkey, which means an AI question does not arrive with its own regime attached. It resolves inside one of the statutes described on this page, and the first task is identifying which one.
Four mappings cover most deployments. Training data, model inputs and prompts raise questions under Law No. 6698, including the transfer analysis where processing runs on infrastructure abroad. Decisions taken about individuals through automated analysis engage the same statute. Synthetic media and manipulated content are addressed through the general criminal provisions and the removal mechanisms of Law No. 5651 rather than through any dedicated offence. Allocation of liability between a vendor and the business deploying its system is governed by general obligations law, which places the risk broadly where the contract puts it.
The practical consequence for a foreign group is that a governance programme built for the European framework has no Turkish counterpart to comply with, while the underlying data and content obligations are fully engaged. The gap is not in the obligations. It is in the assumption that a specialised statute exists to organise them.
This page covers the statutes themselves. It does not cover the AI-specific layer that sits on top of them: the Personal Data Protection Authority’s published AI guidance, vendor and procurement terms for AI systems, ownership questions in training data and generated output, the territorial scope of the EU AI Act, or the pending Turkish proposals and the supervisory structure being debated around them. Those are dealt with separately in our work on artificial intelligence law in Turkey.
Artificial Intelligence Lawyer in Turkey covers AI use cases sitting on top of these four statutes, including automated decisions under Article 11 of Law No. 6698 and the territorial scope of the EU AI Act for businesses selling into Europe.
⚖️ Common mistakes technology companies make in Turkey
These recur across sectors and across company sizes, and each one is cheap to prevent and expensive to correct.
The first is treating a European compliance programme as sufficient. A group that has completed GDPR alignment has addressed a substantial part of the personal data question and none of the cybersecurity question, because Law No. 7545 has no European equivalent that maps onto it.
The second is signing a standard contract and stopping there. The notification to the Board within five business days of signature is a separate obligation with its own administrative fine, and it is the step most often missed because it falls after the moment everyone treats as completion.
The third is assuming that a company without a Turkish entity is outside the perimeter. Obligations under these statutes attach to systems, data and activity rather than to incorporation, and a foreign company offering services into Turkey can carry obligations while having no local structure through which to discharge them.
The fourth is quoting stale monetary thresholds. In electronic commerce the figures are recalculated annually and announced by February, so a threshold taken from a secondary source published two years ago will produce an incorrect classification.
The fifth is leaving cybersecurity obligations with an IT function that has no legal reporting line. The obligations carry fines measured in millions, and in one band up to 5 per cent of audited gross sales revenue, but they are typically monitored by people whose escalation path does not reach the board.
The sixth is structural rather than procedural. Where systems are administered abroad, the Turkish entity carries obligations it cannot unilaterally perform. Intra-group service agreements that do not oblige the parent to provide access, documentation and cooperation leave the local company exposed during inspection. This is one of the points where technology compliance and corporate governance stop being separate subjects.
⚖️ Software, licensing and intellectual property
Software in Turkey is protected as a literary and artistic work rather than through a technology-specific right, which shapes both licensing and enforcement.
The practical consequences appear in three places. In licensing, the scope of the grant has to be drafted against a copyright framework rather than a patent framework, which affects how modifications, derivative works and source code escrow are handled. In development contracts, the allocation of rights between commissioning party and developer follows the rules applicable to works, and silence in the contract rarely favours the commissioning party. In enforcement, the available remedies and the evidentiary route differ from those applicable to trademarks or patents.
Branding and technical inventions follow separate tracks. Trademarks protect the platform name and interface branding, and registered designs may protect interface elements, while genuinely technical inventions may be patentable subject to the applicable exclusions. Most technology businesses hold a mixed portfolio and need the boundaries drawn deliberately, since a single product can involve copyright in the code, trademark in the brand and design protection in the interface. These questions are dealt with in our intellectual property practice.
This page addresses the regulatory framework governing technology operations. It does not cover the substantive law of trademark and patent prosecution, opposition proceedings before the national office, or copyright litigation strategy, each of which follows its own procedural track and is treated separately.
⚖️ Contracts: cloud, outsourcing and vendor arrangements
Most technology exposure in Turkey arrives through contracts signed with vendors rather than through the company’s own systems.
Cloud and hosting arrangements are the clearest example. Where processing takes place on infrastructure operated by a provider abroad, the transfer analysis under Law No. 6698 applies to that arrangement, and the appropriate safeguard has to be in place before the service starts rather than after. Standard terms offered by international providers frequently address European requirements and are silent on the Turkish notification obligation.
Outsourced development and managed services raise a second set of issues: who owns the resulting code, who is responsible for security measures, who bears the cost of an incident, and who is able to open systems to a Turkish inspection. Contracts that leave the last question unanswered create an obligation the Turkish company cannot perform.
Service level provisions deserve specific attention because they interact with regulatory timetables. Where a statutory response period is measured in hours, a contractual response commitment measured in business days is not merely commercially weak, it makes compliance impossible. Aligning the two is a drafting exercise that has to happen before signature. Disputes that arise from these arrangements are handled through the routes described in our work on commercial contract disputes in Turkey.
Financial services and payment arrangements add a further regulatory layer, and where customer onboarding involves identity verification and monitoring obligations, the analysis extends into financial crime compliance.
⚖️ When to bring in counsel
The useful moments are earlier than most companies assume, and they are identifiable in advance rather than only in hindsight.
Before a systems decision. Choosing where data will be hosted, which group platform will process Turkish customer records, or which vendor will administer infrastructure determines the compliance obligations that follow. Reversing those decisions later is an engineering project rather than a legal one.
Before a transaction. Where a target operates cybersecurity products or holds sensitive data, the approval and notification obligations belong in the transaction structure, not in the diligence report.
Before a product launch that faces export markets. The permission regime for cybersecurity products applies to the sale abroad, and it has to be assessed against the roadmap rather than against the finished product.
Within hours of an incident. Notification obligations, evidence preservation and the position with regulators are all determined in the first day, and steps taken by an internal team acting reasonably but without legal input frequently narrow the options available afterwards.
On receipt of any correspondence from a regulator. Inspection-related obligations carry their own fine band, between 100,000 and 1 million Turkish lira, for failing to keep systems open to inspection or to provide the necessary infrastructure within the periods given. The response window is where that exposure is created or avoided.
⚖️ How to choose technology counsel in Turkey
The distinguishing question is not whether a firm lists information technology among its practice areas, but whether it can tell you which statute does not apply to you.
Four criteria are worth applying. The first is whether the adviser separates the four regimes cleanly, since advice that treats cybersecurity and data protection as one subject will miss obligations under both. The second is whether the adviser works from the current text, given that this field has changed in 2022, 2024 and 2025 and that secondary commentary ages quickly. The third is whether the adviser can operate in the language of the proceeding, because regulatory correspondence, inspection responses and submissions are conducted in Turkish. The fourth is whether the adviser can coordinate with the group’s existing counsel abroad rather than duplicating their work.
A practical test is available at no cost. Ask a prospective adviser what changed on 1 June 2024 and what changed on 19 March 2025. The two dates cover the transfer regime and the cybersecurity framework, and an adviser who cannot place both is working from an outdated picture of the field. Broader regulatory coverage across sectors is addressed in our regulatory compliance practice.
⚖️ How we work
We act for foreign companies as Turkish counsel, and most engagements begin with a scope assessment rather than with a compliance programme.
The scope assessment establishes which of the four statutes attach to the company’s systems, data and activities, and which do not. That second half matters commercially, because a great deal of unnecessary compliance work in this field is performed by companies that were never in scope for the regime they were preparing for.
From there the work typically covers: mapping obligations to responsible functions inside the organisation; preparing or reviewing the transfer mechanism, including standard contracts and the five business day notification, or binding corporate rules where a group structure justifies them; reviewing vendor, cloud and intra-group agreements against the statutory response timetables; preparing inspection readiness documentation; representing the company in correspondence and proceedings with the relevant authority; and advising on approval and notification requirements where a transaction or an export is contemplated.
Engagements are conducted remotely where the client prefers. Documents are exchanged electronically, and where a power of attorney is required for representation before an authority, we provide the model text and the legalisation route applicable in the client’s jurisdiction. Companies in a group structure frequently ask us to work directly with in-house counsel abroad, which we do as a matter of course.
The consolidated text of the legislation in this field is published by the state through the Official Gazette, which is available at the Resmî Gazete website.
⚖️ Who we work with
Our technology work is concentrated among foreign companies operating in Turkey rather than among domestic startups, which shapes the questions we see most often.
Software and platform businesses with a Turkish development centre form one group, and their recurring questions concern intra-group data flows, code ownership in outsourced development, and the export permission regime where the product has a security component.
Manufacturers and logistics operators form a second and larger group. They are in scope for cybersecurity obligations because of connected systems rather than because of any technology offering, and their questions are usually about the perimeter itself.
E-commerce and marketplace businesses form a third, and their questions concentrate on category classification, threshold calculation and the interaction between registration and licensing.
Financial and payment-adjacent businesses form a fourth, where technology obligations sit on top of a separate regulatory layer and the sequencing between the two determines what can launch and when. Companies in this group generally need the technology analysis to run alongside corporate compliance work rather than after it.
⚖️ Related Legal Resources
🔹 Corporate structure and governance
Corporate Lawyer in Turkey covers company structures, share transfers and the board approvals that a cybersecurity transaction notification has to be built around.
Corporate Governance Lawyer in Turkey addresses intra-group reporting lines, which determine whether a Turkish entity can actually perform obligations administered from abroad.
Business Formation and Licensing in Turkey sets out the incorporation and permit sequence for a company preparing to register in ETBİS or apply for an electronic commerce licence.
🔹 Compliance and regulatory
Regulatory Compliance Lawyer covers sector-facing obligations that sit alongside the four technology statutes, including inspection and reporting duties.
Corporate Compliance Lawyer addresses internal policy architecture, which is where the five business day standard contract notification either happens or is missed.
MASAK Compliance in Turkey covers identity verification and monitoring obligations for businesses whose platforms handle payments or onboarding.
Artificial Intelligence Lawyer in Turkey covers AI use cases sitting on top of these four statutes, including automated decisions under Article 11 of Law No. 6698 and the territorial scope of the EU AI Act for businesses selling into Europe.
🔹 Contracts, disputes and rights
Commercial Contract Disputes in Turkey deals with vendor, cloud and outsourcing agreements where service level commitments conflict with statutory response periods measured in hours.
Commercial Litigation Lawyer covers proceedings that run in parallel with content removal under Law No. 5651, including damage claims following a failure to act within twenty four hours.
Intellectual Property Law addresses software as a protected work, trademark protection for platform branding, and the boundaries between the two.
Schedule a Legal Consultation
Whether you are assessing scope for the first time, preparing a transfer mechanism, responding to a regulator, or planning a transaction involving a cybersecurity business, our technology lawyers in Istanbul can work directly with your existing counsel.
The legal question in technology work almost never arrives first. It arrives after the hosting decision, after the vendor contract, after the platform has gone live, and by then the range of available answers has already narrowed. The companies that handle this field well are rarely the ones with the largest compliance programmes. They are the ones that asked, before the systems decision rather than after it, which of these four statutes was ever going to apply to them.