Turkish Trade Monitor – June 2026
Legal Developments in Türkiye and Their Impact on Foreign Investors
The June 2026 updates introduce pivotal shifts across multiple sectors in Türkiye. From strict KVKK enforcement on biometric data and workplace surveillance, to the expansive tax exemptions and investment incentives under Law No. 7582, the regulatory landscape is rapidly evolving. Key actions by the Competition Authority regarding AI and the launch of the National AI Action Plan further signal a dynamic environment for tech and global business operations.
KVKK Principle Decision on Biometric Data for Attendance Tracking
The Personal Data Protection Board (KVKK) issued a key principle decision regarding the processing of biometric data for workplace attendance tracking. The Board emphasized that data such as fingerprints, facial recognition, iris or retina scans, and voiceprints constitute special categories of personal data that require high protection due to their irreversible nature if compromised. The Board noted that while labor regulations govern working hours, there is no explicit statutory law allowing biometric data processing for attendance tracking. Furthermore, due to the inherent power imbalance between employers and employees, explicit consent alone does not provide a valid legal basis. Since less intrusive alternatives exist, such as RFID or NFC cards, PIN-based systems, or traditional paper sign-in sheets, using biometric data violates the principle of proportionality. Data controllers must implement non-biometric alternative methods immediately, or face administrative sanctions under Law No. 6698.
Law No. 7582: Omnibus Amendments to Tax and Investment Legislation
Law No. 7582 introduces significant structural updates to tax collection, income tax, corporate tax, foreign direct investment (FDI), R&D incentives, and the Istanbul Financial Center (IFM) framework. Key tax collection modifications include increasing the tax debt postponement period from 36 to 72 months under Law No. 6183, and raising the monetary threshold for deferral authorization to 1 million TL. For foreign individuals, the law introduces a major 20 year income tax exemption on overseas income and a reduced 1% inheritance tax rate, provided they had no Turkish residence or tax liability in the last three years prior to relocating to Turkey.
The law explicitly defines "qualified service centers" under FDI legislation. This covers capital companies providing finance, management, tech, HR, or R&D coordination to related foreign entities across at least three countries, provided 80% of revenues are derived from abroad. Staff at these centers enjoy income tax exemptions on their salaries, with higher incentives applied within designated industrial zones and the IFM. Additionally, a new voluntary asset declaration regime is established until July 31, 2027, allowing individuals to register overseas or unregistered domestic assets at a base tax rate of 5%, which can be progressively reduced if the assets are committed to long-term deposits, government bonds, or venture capital funds.
Competition Authority Launches Investigation Against Meta
The Turkish Competition Authority has initiated a formal investigation into Meta Platforms, Meta Platforms Ireland, WhatsApp LLC, and Meta Platforms Istanbul. The probe examines allegations that Meta restricted rival artificial intelligence providers from offering services over WhatsApp while integrating its own Meta AI feature. The Board determined that the initial findings indicate a serious potential violation of Article 6 of Law No. 4054. Consequently, the Board has imposed interim measures requiring Meta to establish conditions that allow third-party general-purpose generative AI chatbots to operate on WhatsApp. Meta must avoid any practices that economically or logistically obstruct these rival services and must comply with these obligations within one month from the notification of the reasoned decision.
Court of Cassation: Calculation of Annual Paid Leave and Holiday Overlaps
The 9th Civil Chamber of the Court of Cassation issued a significant judgment on the calculation of annual paid leave in an employee compensation lawsuit. Following an appeal by the Ministry of Justice in the interest of the law, the Court of Cassation reversed the lower court's decision, which had previously rejected the employee's remaining annual leave claim. The Court reiterated that under Labor Law No. 4857, the burden of proving that annual leave was fully used rests entirely on the employer. Crucially, the Court ruled that weekly rest days, public holidays, and national holidays that coincide with the annual leave period cannot be counted as part of the annual leave days. In this case, since four weekly rest days fell within the employee's designated leave periods, the court ruled that the employee is entitled to four additional days of annual leave compensation.
Visa Exemption for Diplomatic and Special Passports: Turkey and Saudi Arabia
Presidential Decision No: 11413The Turkish government has ratified the agreement signed in Ankara on May 6, 2026, granting mutual visa exemptions for holders of diplomatic, special, and official passports from Turkey and Saudi Arabia. The agreement permits citizens holding these specific passports to enter, exit, transit, and stay temporarily without a visa for up to 90 days within any 180 day period. Passports must be valid for at least six months from the entry date. Long-term residencies, employment, study, and research remain subject to national visa regulations. Notably, Turkish citizens traveling for Hajj and Umrah are excluded from this specific exemption. The agreement will enter into force 30 days after the final internal ratification notice and will remain valid for five years.
KVKK Guidelines on Workplace Security Camera Usage
The Personal Data Protection Authority (KVKK) published a public announcement warning employers that security cameras cannot be utilized for continuous employee surveillance, performance monitoring, or general disciplinary control. Camera use is limited to legitimate security purposes, crime prevention, and occupational health and safety monitoring. The guidelines strictly prohibit installing cameras in private staff areas such as restrooms, changing rooms, prayer rooms, and break lounges. Employers must avoid wide-angle or face-focused recordings, turn off audio recording functions unless absolutely necessary, notify employees transparently, restrict access to authorized personnel, and keep records for the shortest period possible. Non-compliant employers face administrative fines under Law No. 6698.
Istanbul Commercial Court Formally Discloses Use of AI in Judicial Process
In a landmark decision, the Istanbul Asliye Commercial Court explicitly documented how it utilized artificial intelligence during a trial. The court clarified that AI was employed strictly as a technical tool to verify Dutch court judgments cited by the plaintiff, access foreign legal sources, and translate Dutch legal texts into Turkish. The judgment notes that the AI tool did not play a decision-making role; legal interpretation, evidence evaluation, and the final judgment remain exclusively with the judge. To ensure transparency and comply with the Public Officials Ethics Committee guidelines, all prompts, sources, and links used were fully logged. Furthermore, no personal data was shared with the AI system to protect privacy.
President Erdoğan Announces National AI Action Plan (2026-2030)
President Recep Tayyip Erdoğan unveiled the Turkey Artificial Intelligence Action Plan for the 2026–2030 period during the Turkey AI Summit. The plan is structured around four pillars: awareness, utilization, production, and governance. The initiative will launch the National AI Literacy Program, establishing workshops across 81 provinces to train 5 million citizens within two years. It aims to train 10,000 advanced AI experts and 100,000 AI application professionals. Furthermore, at least 2,000 public datasets spanning health, agriculture, defense, and e-commerce will be opened via the National Data Library. The plan mandates that at least 2% of public investments be allocated to AI projects, targets expanding data center capacity to 1 gigawatt by 2030, and seeks to mobilize 10 billion dollars in private sector-led resources for AI infrastructure.
New Tax Restructuring Framework: Collection General Communique
Series: B, Serial No: 20The Ministry of Treasury and Finance issued a new Communique establishing the procedures for restructuring outstanding tax debts via the postponement and installment mechanism under Article 48 of Law No. 6183. The scope covers public claims monitored by tax offices that fell due by June 5, 2026, but remain unpaid. Special Consumption Tax (OVT) and certain temporary corporate or income taxes are excluded. Debtors must apply electronically or in writing by August 31, 2026. Installments will start in September 2026. The plan allows 36, 48, or up to 72 months for general taxpayers based on financial status, while VAT and BSMV debts are restricted to 12 installments. Restructured debts will attract an annual postponement interest rate of 29%. No collateral is required for debts up to 10 million TL; for higher amounts, collateral is required for half of the exceeding balance.
Law No. 7583: Ratification of the OTS Digital Economy Partnership Agreement
The Grand National Assembly of Turkey has enacted Law No. 7583, approving the ratification of the "Digital Economy Partnership Agreement among the Governments of the Member States of the Organization of Turkic States". The agreement, originally signed in Bishkek on November 6, 2024, seeks to boost cross-border digital trade, simplify digital transactions, and foster economic cooperation among member nations. The law entered into force upon publication.
New Rules for Animal Embryo Production: Communique No. 2026/8
The Ministry of Agriculture and Forestry published Communique No. 2026/8, governing the production, transfer, storage, market supply, and traceability of embryos from cattle, buffalo, sheep, goats, cats, and dogs. Bovine embryo operations are restricted to authorized production centers and specialized sales businesses, while small ruminant, cat, and dog embryo production can only occur at certified embryo production centers. Production from unregistered or unidentified donor animals is strictly prohibited.
Law No. 7585: Renewable Energy Cooperation with Saudi Arabia
Law No. 7585 has been enacted, ratifying the Intergovernmental Agreement between Turkey and Saudi Arabia on Renewable Energy Power Plant Projects, signed in Riyadh on February 3, 2026. The legislation concludes the domestic legislative approval phase for bilateral renewable energy investments and joint infrastructure projects. The law took effect upon publication.
New Regulation on the Sale of Refurbished Products
The Ministry of Trade has completely overhauled the framework for processing and reselling used electronics as refurbished products. Under the new rules, all refurbishment processes must comply with national standards and be logged via the Refurbished Product Information System (YUBIS). To establish a refurbishment center, companies must obtain a five year non-transferable authorization certificate from the Ministry, which requires a minimum paid-in capital of 100 million TL and specific corporate qualifications.
For devices with electronic identifiers (such as mobile phones), the device must be listed on the e-Government White List, have at least one year of historical network traffic, and be activated via a successful call on a YUBIS-registered line. Valuation must be completed within three business days of receiving the item. Refurbished products must include a minimum one year warranty, with repairs completed within a maximum of 20 business days. The regulation becomes effective on August 1, 2026, replacing the 2020 framework.