Türkiye: New Regulatory Requirements for Game Platforms Taking Effect on 1 November 2026

What game platforms, publishers and game businesses need to know about Law No. 7578, Law No. 7590 and the 2026 advertising amendments.

New Game-Platform Obligations Taking Effect on 1st November 2026 and Advertising Rules Already in Force

Two sets of legal changes adopted in 2026 are relevant to video game businesses in Türkiye.

First, Law No. 7578 on Amendments to the Social Services Law and Certain Other Laws (“Law No. 7578”), published in the Official Gazette dated 1 May 2026 and numbered 33240, amended Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed by Means of Such Publications (“Law No. 5651”).

Law No. 7578 introduced statutory definitions of “game”, “game distributor”, “game developer” and “game platform”. These definitions entered into force on 1 May 2026. The provisions introducing specific obligations for game platforms will enter into force on 1 November 2026.

Law No. 7590 subsequently transferred relevant functions and powers under Law No. 5651 from the Information and Communication Technologies Authority ("ICTA"/"BTK") to the Cybersecurity Presidency. Accordingly, the Cybersecurity Presidency is now the relevant administrative authority for the game-platform regime discussed below.

Separately, the Regulation Amending the Regulation on Commercial Advertisement and Unfair Commercial Practices was published in the Official Gazette dated 1 July 2026 and numbered 33297. The amendments entered into force on 1 August 2026 and introduced or revised rules concerning targeted advertising, social media influencer advertising, artificial intelligence in advertising, discounted sales advertisements and consumer reviews. These provisions are not specific to the video game sector and apply only where the relevant advertising or commercial practice falls within their respective scope.

The principal issues can be considered under five questions.

1. Does the Relevant Service Qualify as a “Game Platform”?

Law No. 5651 defines a “game platform” as a natural or legal person that:

• provides software or technical infrastructure over the internet for the display, sale, distribution, downloading or playing of digital games and additional content associated with them; and
• enables or coordinates users’ access to games or content, licence management or interaction between users.

The specific obligations under Additional Article 5 of Law No. 5651 are imposed on game platforms. Whether those obligations apply therefore depends on the functions performed by the relevant service and whether those functions meet the elements of the statutory definition.

The assessment should be made separately for each relevant service. A group may, for example, operate different services for game development, publishing, distribution, account management or access to content. The statutory definition must be applied to the particular service under review.

“The key question is not whether a business operates in the gaming sector, but whether the particular service it provides falls within the statutory definition of a ‘game platform’.”

2. Does a Game Platform Originating From Outside Türkiye Exceed the Daily-Access Threshold?

A game platform originating outside Türkiye and receiving more than 100,000 daily accesses from Türkiye must appoint a natural or legal person as its representative in Türkiye.

The representative must be appointed to ensure that:

• formal service, notifications or requests sent by the Cybersecurity Presidency, the Access Providers Association and judicial or administrative authorities are acted upon; and
• the platform’s other obligations under Law No. 5651 are fulfilled.

Information concerning the representative must be notified to the Cybersecurity Presidency. The platform must also publish the representative’s contact information on its website in an easily visible and directly accessible manner.

The 100,000 daily-access threshold is stated in the provision governing the representative requirement for game platforms originating outside Türkiye. The other obligations under Additional Article 5 are not expressed by reference to this threshold.

The legislation refers to “daily accesses from Türkiye”. It does not use the expressions “daily users”, “active users” or “unique visitors”.

3. What are the Age-Rating and Parental-Control Requirements?

The legislation also provides for the treatment of games that have not been duly rated, including the possibility of classification according to the highest age criterion. The precise rating methodology and implementation requirements remain subject to the secondary regulation to be issued under Additional Article 5.

Without prejudice to its responsibilities and obligations as a content provider or hosting provider, a game platform must remove content that has not been duly rated.

Game platforms must also provide parental-control tools that are clear, understandable and usable. These tools must include mechanisms that:

• allow account settings to be controlled; and
• allow purchases, rentals, paid memberships and similar fee-based transactions to be made subject to parental permission or approval.

The parental-control obligations imposed on game platforms do not include the separate usage-time monitoring and limitation requirement introduced for social network providers.

Additional Article 5 requires the procedures and principles concerning the implementation of the game-platform provisions, the obligations applicable to game platforms and classification according to age criteria to be determined by a regulation of the Cybersecurity Presidency.

The primary law does not itself set out the detailed age categories, rating procedure or technical specifications for parental-control tools.

4. What Information Powers and Sanctions Apply?

The Cybersecurity Presidency may request explanations from a game platform concerning its compliance with Law No. 5651. The request may cover the platform’s corporate structure, information systems and data-processing mechanisms, provided that the matters requested are directly related to the implementation of Law No. 5651.

The platform must provide the requested information and documents promptly and within the period determined by the Cybersecurity Presidency, which may not exceed 15 days.

Failure to comply with Additional Article 5 or the regulation issued under it is subject to the following statutory sequence:

The amount of the second administrative fine is determined by taking into account the nature and seriousness of the infringement, its effect on users or the damage caused.

On the second bandwidth application, the judge may determine a lower reduction rate by taking into account the nature of the service, provided that the rate is not below 30%.

Judicial bandwidth-reduction decisions are sent to the Cybersecurity Presidency for notification to access providers. Access providers must implement them immediately and no later than four hours after notification.

If the obligation concerned is subsequently fulfilled:

• one quarter of the administrative fines imposed is collected;
• the judicial decisions automatically cease to have effect; and
• the Cybersecurity Presidency notifies access providers to terminate the bandwidth restriction.

The enforcement mechanism can therefore escalate from notification to significant administrative fines and, ultimately, court-ordered bandwidth reductions.

5. Which Advertising Rules Require Review?

The Regulation on Commercial Advertisement and Unfair Commercial Practices applies generally to consumer-facing commercial advertisements and unfair commercial practices. The 2026 amendments are therefore relevant to video game businesses only where the relevant activity falls within the respective statutory provision.

Targeted Advertising

The Advertising Regulation defines targeted advertising as advertising content presented specifically to certain individuals or groups:

• by sellers or service providers, or by intermediary service providers facilitating the conclusion of distance contracts on their behalf; and
• through analysis of consumers’ online behaviour, records of past preferences, location information, demographic data or similar personal data.

Targeted advertising may be carried out only if consumers are provided with direct and easily accessible information explaining:

• the criteria used to determine why the advertisement is shown to them; and
• how those criteria can be changed.

Where a consumer is known, or can reasonably be expected to be known, to be a child, targeted advertising using profiling methods based on personal data is prohibited.

The provision applies only where the activity meets the definition of targeted advertising. It does not classify every personalised feature or recommendation as advertising.

Social Media Influencers, Steamers and Creators

The Advertising Regulation now contains specific provisions governing advertisements made through social media influencers.

A social media influencer may be a natural or legal person who shares content through social media, directly or indirectly promotes a good or service on their own behalf or on behalf of an advertiser, engages in marketing communication and converts that communication into any form of benefit. These can include, Twitch streamers, YouTube gaming creators, TikTok gaming creators, sponsored game reviews; paid promotion and affiliate arrangements etc.

The Regulation identifies circumstances in which content must be expressly identified as advertising. These include:

• directing users to an advertiser or to its goods or services;
• receiving financial gain or benefits such as free or discounted goods or services;
• sharing content relating to prize draws, competitions or campaigns organised to promote an advertiser’s goods or services; and
• receiving a benefit in return for participating in an event organised by an advertiser.

Advertisements made through social media influencers must include either “Reklam” (“Advertisement”) or “Tanıtım” (“Promotion”). This must be accompanied by the advertiser’s name or trade name, or by one of the alternative statements prescribed in the Regulation.

The disclosure must:

• be distinguishable from the background and easily readable;
• be visible when the consumer first encounters the content, without requiring scrolling or redirection;
• appear before other labels or explanations;
• not be covered by text, symbols or interface elements; and
• appear in each post where the content extends across multiple posts or formats.

For audio-only content, the prescribed advertising disclosure must be made at the beginning of the broadcast and before the advertising content.

These requirements apply to streamers, creators and similar persons where they fall within the statutory definition of a social media influencer and the content concerned constitutes advertising under the Regulation.

“AI disclosures may be required where technology materially affects consumers.”

Artificial Intelligence in Advertising

The Advertising Regulation addresses two uses of artificial intelligence and other software in advertising.

A clear, understandable and distinguishable disclosure is required where:

• artificial intelligence or other software is used in advertising in a manner that significantly affects consumers’ economic behaviour in relation to a good or service; or
• artificial intelligence technologies are used to feature digital characters that cannot be distinguished from humans.

The Regulation also prohibits advertisements in which an AI-generated digital copy of a real person falsely creates the impression that the person has personally experienced, used or recommended a good or service.

These provisions concern the use of artificial intelligence in advertising. Their application depends on the use made of the technology in the relevant advertisement.

Discounted Sales Advertisements

Where an advertisement includes a written, audio or visual statement that a good or service is discounted, the following information must be stated clearly and understandably:

• the pre-discount price;
• the start and end dates of the discounted sale; and
• where the quantity available at the discounted price is limited, that quantity.

The advertiser bears the burden of proving that the relevant good or service is offered at a price lower than the pre-discount price.

The 2026 amendments introduced or revised the following reference-price rules:

• For advertisements concerning the sale of goods, the pre-discount price is the lowest price applied during the ten days preceding the start of the discount.
• For advertisements concerning perishable goods and services, the price applied immediately before the discounted price is used.
• Where the same good or service is offered through different sales channels, the pre-discount price must be determined solely by reference to the channel in which the discount is offered. A price applied through one channel cannot be used as the pre-discount price for another channel.
• The discounted-sales provisions apply to advertisements for loyalty programmes where the relevant programme is easily accessible or usable by consumers.
• Except for the requirement to state the available quantity, the discounted-sales provisions also apply to conditional sales advertisements where a discount or other benefit depends on a specified quantity, number, value or type of purchase, the completion of a particular transaction or a similar condition.

The Advertising Regulation defines “goods” to include software, sound, images and similar intangible goods prepared for use in electronic form. It separately defines services as consumer transactions, provided for consideration or benefit, other than the supply of goods.

The Regulation does not itself classify every digital game, virtual item, bundle, subscription or other in-game offering as either a good or a service. This distinction can affect which reference-price rule applies to a particular promotional claim. Businesses should therefore avoid applying a single discount-pricing methodology indiscriminately across games, virtual goods, subscriptions and other digital offerings.

Article 14 refers to prices previously applied. It does not contain a separate reference-price formula for a newly introduced offering that has no prior applied price.

“Businesses should prepare now for the 1 November 2026 deadline.”

Consumer Reviews

Where sellers, service providers or intermediary service providers enable consumers to publish online reviews of a good, service, seller or service provider:

• reviews may be submitted only by consumers who purchased the relevant good or service;
• reviews obtained from channels where the purchasing process cannot be verified may not be published;
• the rules governing publication must be made available in the review area or through an easily accessible link or warning;
• positive and negative reviews must be published without discrimination after the required checks and retained for at least one year using an objective ordering criterion; and
• arrangements may not be made, or services purchased, to obtain false reviews or endorsements.

For complaint platforms whose principal activity is publishing consumer complaints, the period given to the seller or service provider to respond before publication has been reduced from 72 hours to 48 hours.

What Should Businesses Review?

Before the game-platform provisions take effect on 1 November 2026, businesses should:

• map each Turkish-facing service against the statutory definition of a “game platform” and document the basis for the classification;
• establish a methodology for measuring daily accesses from Türkiye and, for any foreign-origin game platform, assess whether the 100,000 daily-access threshold is met or may be exceeded;
• review and, where necessary, update age-classification processes, parental-control tools, account settings and mechanisms requiring parental approval for paid transactions;
• establish internal procedures and responsibilities for responding to information and document requests from the Cybersecurity Presidency within the applicable deadline; and
• monitor the implementing regulation and related administrative guidance and update compliance measures as the secondary regulatory framework develops.

The advertising amendments are already in force. Turkish-facing advertising and commercial practices should therefore be reviewed separately for targeted advertising, child profiling, influencer and creator campaigns, AI-generated advertising, discount claims and online consumer reviews.

The game-platform and advertising provisions apply different scope tests. Applicability should be assessed separately for each service, advertising activity and transaction structure.

Images

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