Turkish Trade Monitor – May 2026
Legal Developments in Türkiye and Their Impact on Foreign Investors
The May 2026 edition highlights landmark enforcement data from the Data Protection Authority (KVKK), critical updates on corporate compliance deadlines, and a major breakthrough in international data transfer mechanisms alongside new agricultural and food safety standards. Furthermore, Law No. 7582 introduces significant wealth repatriation options and sweeping tax exemptions for foreign earnings.
1. Data Protection & Corporate Compliance
A. KVKK Releases 2025 Annual Activity Report: Enforcement Risks Surge
The Personal Data Protection Authority (KVKK) published its 2025 Annual Activity Report, revealing a dramatic 51% year-on-year increase in complaints and notices, reaching a record total of 12,512 applications.
- Key Violation Trends: Unlawful data processing ranked as the top complaint, followed closely by unauthorized data sharing and unsolicited marketing SMS/calls.
- Administrative Fines: In 2025, the KVKK imposed a staggering TRY 352.5 million in total administrative fines across 876 data controllers. Notably, TRY 216.8 million of this total directly stemmed from non-compliance with VERBİS (Data Controllers Registry) registration obligations.
- Breach Notifications & Contracts: The Authority received 328 data breach notifications (51 of which were publicly announced) and processed 2,497 Standard Contract notifications for cross-border data transfers.
B. Crucial VERBİS Registration Deadline Extended to June 5, 2026
Following the submission of 2025 corporate tax returns, companies crossing the financial thresholds have a strict mandatory window to register with VERBİS. While the standard 30-day window following the April 30 tax deadline was set to expire on June 1, the KVKK officially extended the deadline to Friday, June 5, 2026, accounting for the upcoming Eid al-Adha calendar.
- Applicable Thresholds: Registration is mandatory for companies whose 2025 financial balance sheet total reaches TRY 100 million or more (provided their core business is not processing special categories of personal data), or TRY 10 million or more for companies whose core business is processing special categories of personal data.
C. Landmark Approval: Türkiye's First Binding Corporate Rules (BCR) Certified
On May 20, 2026, the Personal Data Protection Board approved Türkiye's first-ever Binding Corporate Rules (BCR / Bağlayıcı Şirket Kuralları) application, submitted by Sosyo-Plus Bilgi Bilişim Teknolojileri (Insider One). This marks a historic milestone for cross-border data transfer mechanisms under Article 9 of the KVKK.
2. Agriculture, Food Safety & Customs Import Regulations
A. Brand New Framework for "Novel Foods" in the Turkish Food Code
The Ministry of Agriculture and Forestry published the Regulation on Novel Foods, establishing strict market authorization and safety assessment rules for foods that were not significantly consumed in Türkiye prior to December 31, 2025.
- Scope: Covers foods with new molecular structures, ingredients derived from microorganisms, fungi, or algae, mineral-based materials, cellular/tissue cultures, and products derived via novel production processes or engineered nanomaterials.
- Exclusions: GMOs, food enzymes, additives, flavorings, and extraction solvents remain governed under separate vertical legislation.
B. Plant Quarantine Regulation Overhauled
A comprehensive update to the Plant Quarantine Regulation redefines the biosecurity and phytosanitary rules governing the entry and exit of plants, plant products, and related materials across Turkish borders. The framework tightens official control mechanisms at border inspection points, customs clearance in Free Zones, and transit shipping logistics.
3. Tax Incentives & Wealth Repatriation (Law No. 7582)
A. Wealth Amnesty and Repatriation of Assets
Law No. 7582 introduces a significant asset peace and repatriation mechanism (Provisional Article 19 to Law No. 5520). Real and legal persons can report money, gold, foreign currency, and securities held abroad to Turkish banks until July 31, 2027.
- No Tax Investigation: Assets reported and physically or virtually brought into Türkiye within two months will not be subject to tax examinations or assessments.
- Variable Tax Rates: Banks will apply an advance tax, which can be reduced to 0% if the funds are held in TRY deposit accounts or specific government bonds/funds for at least five years (rising to 4% for a one-year hold, and 5% standard).
B. Tax Exemptions for Foreign Earnings & Qualified Service Centers
The amendments introduce strategic tax advantages aimed at attracting foreign talent and service exports:
- Foreign Earnings Exemption: Natural persons who settle in Türkiye (with no tax liability or domicile in the prior three years) are completely exempt from income tax on foreign earnings for twenty years.
- Qualified Service Centers: Capital companies generating at least 80% of revenue from related entities abroad can be designated as "Qualified Service Centers".
- Wage Tax Deductions: A significant portion of the wages of qualified personnel working in these centers will be exempt from income tax, heavily incentivizing high-value service exports.
- Corporate Tax Reductions: A 95% deduction applies to earnings from the sale abroad of goods purchased abroad without bringing them to Turkey, or through intermediation. Additionally, the corporate tax rate is reduced to 12.5% for production activities by institutions holding an industrial registry certificate.