Data Protection Requirements for Companies in Türkiye in 2026

Data protection has become a central compliance priority for companies operating in Türkiye. As digitalization accelerates and cross-border data flows increase, Turkish regulators have strengthened oversight under the Personal Data Protection Law No. 6698 (“KVKK”), aligning many principles with global standards such as the GDPR while preserving country-specific requirements.

For foreign investors and local enterprises alike, understanding and implementing data protection obligations is no longer optional—it is a core component of risk management, corporate governance, and sustainable business operations. Akkas CPA & Turkish Accounting Firm, based in Istanbul and advising international clients since 2017, regularly supports companies at every stage, from company formation to long-term regulatory compliance.

This article outlines the data protection requirements companies must address in Türkiye in 2026, with a practical and business-oriented perspective.

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As businesses increasingly operate in the digital realm, understanding data protection requirements has become fundamental for any company conducting operations in Türkiye. Whether you’re planning company formation in Türkiye or managing an established enterprise, compliance with Turkish data protection legislation is not optional—it’s mandatory.

Understanding the Turkish Data Protection Framework

Türkiye’s data protection regime is governed by the Law on Protection of Personal Data (KVKK – Kişisel Verilerin Korunması Kanunu), which entered into force in 2016. This comprehensive legislation aligns closely with the European Union’s General Data Protection Regulation (GDPR), making it one of the most robust data protection frameworks in the region.

The Personal Data Protection Authority (KVKK Kurumu) serves as the independent regulatory body responsible for overseeing compliance, investigating violations, and imposing penalties. For foreign investors working with Turkish company formation lawyers, understanding these requirements from the outset can prevent costly compliance issues down the road.

Who Must Comply with Data Protection Requirements?

Every legal entity and individual processing personal data in Türkiye falls under KVKK’s scope, including:

• Companies established through joint stock company formation or limited liability company formation
• Foreign companies with operations or customers in Türkiye
• Data processors acting on behalf of data controllers
• Public institutions and organizations
• Non-profit associations and foundations

The law applies regardless of whether data processing occurs within or outside Turkish territory, provided the data subjects are located in Türkiye or the processing activities relate to offering goods or services to individuals in the country.

Core Principles of Data Protection in Türkiye

Turkish data protection law establishes several fundamental principles that govern all personal data processing activities:

Lawfulness and Fairness: Personal data must be processed lawfully, fairly, and in accordance with one of the legal grounds specified in the KVKK. Processing without proper legal basis constitutes a violation.

Data Accuracy: Data controllers must ensure that personal data remains accurate and up-to-date. Inaccurate data must be corrected or deleted promptly.

Purpose Limitation: Organizations can only collect and process personal data for specified, explicit, and legitimate purposes. Any subsequent processing incompatible with these purposes is prohibited.

Data Minimization: Companies should limit data collection to what is strictly necessary for the stated purposes. Excessive data collection violates this principle.

Storage Limitation: Personal data must not be retained longer than necessary for the purposes for which it was collected, unless a legal obligation requires longer retention periods.

Registration Requirements with the Data Controllers Registry

One of the most critical compliance obligations involves registering with the Data Controllers Registry (VERBİS). Companies processing personal data must register through this electronic system maintained by the Personal Data Protection Authority.

Registration typically includes detailed information about data processing activities, categories of data subjects, types of personal data processed, data retention periods, and technical and organizational security measures implemented. This requirement integrates seamlessly with other compliance obligations such as annual report filing and corporate governance responsibilities.

Obtaining Valid Consent for Data Processing

Explicit consent represents one of the primary legal bases for processing personal data under Turkish law. Valid consent must be:

• Freely given without coercion or undue influence
• Specific to particular processing activities
• Informed, with clear information provided about data usage
• Expressed through affirmative action rather than silence or inactivity

Companies should implement robust consent management systems, particularly when processing special categories of personal data such as health information, biometric data, or data revealing ethnic origin, political opinions, or religious beliefs. Proper contract drafting & review ensures that data processing agreements and consent forms meet legal standards.

Data Subject Rights and Company Obligations

Turkish data protection law grants individuals extensive rights regarding their personal data. Data subjects can:

• Request information about whether their data is being processed
• Demand access to their personal data
• Request correction of inaccurate or incomplete data
• Request deletion or destruction of data under certain circumstances
• Object to processing activities
• Request data portability
• Request restriction of processing

Companies must establish efficient mechanisms to respond to these requests within thirty days. Failure to respond or unjustified rejection of legitimate requests can result in administrative fines and enforcement actions.

Cross-Border Data Transfers

Transferring personal data outside Türkiye requires careful consideration of legal requirements. The KVKK permits international data transfers only under specific conditions:

The destination country must have adequate data protection safeguards, as determined by the Personal Data Protection Authority, or the data controller and foreign recipient must provide written undertakings ensuring adequate protection. Explicit consent from data subjects may also serve as a legal basis for cross-border transfers.

For companies engaged in international business operations, including those requiring bank account opening in multiple jurisdictions, understanding cross-border data transfer requirements is essential.

Data Security Measures and Breach Notification

Organizations must implement appropriate technical and organizational measures to protect personal data against unauthorized access, disclosure, alteration, or destruction. These measures should be proportionate to the risks associated with the data processing activities.

In case of a data breach, companies must notify the Personal Data Protection Authority within seventy-two hours of becoming aware of the incident. If the breach poses a high risk to data subjects’ rights and freedoms, affected individuals must also be notified without undue delay.

Penalties for Non-Compliance

The Personal Data Protection Authority has the power to impose substantial administrative fines for KVKK violations. Penalty amounts range from approximately 2,000 to 2 million Turkish Lira, depending on the nature and severity of the violation.

Common violations attracting penalties include processing data without legal grounds, failing to register with VERBİS, inadequate security measures, improper cross-border transfers, and failure to respond to data subject requests. Criminal penalties may also apply in cases involving unlawful data processing or disclosure.

Beyond monetary penalties, non-compliance can damage corporate reputation, disrupt business operations, and create liability risks. Companies should integrate data protection compliance into their broader accounting & bookkeeping and risk management frameworks.

Best Practices for Ensuring Compliance

Successful data protection compliance requires a proactive, comprehensive approach:

Conduct Regular Data Protection Impact Assessments: Evaluate processing activities that may pose high risks to data subjects and implement appropriate safeguards.

Appoint a Data Protection Officer: While not mandatory for all companies, designating a qualified professional to oversee data protection activities significantly enhances compliance.

Implement Privacy by Design: Integrate data protection considerations into all business processes, products, and services from their inception.

Provide Employee Training: Ensure all personnel handling personal data understand their obligations and the importance of compliance.

Maintain Comprehensive Documentation: Keep detailed records of processing activities, consent forms, data transfer agreements, and security incident logs.

Review and Update Policies Regularly: Data protection requirements evolve, and companies must adapt their policies and practices accordingly.

Looking Ahead: Data Protection in 2026 and Beyond

As digital transformation accelerates and cross-border data flows increase, data protection compliance will become even more critical for companies operating in Türkiye. The Personal Data Protection Authority continues to strengthen enforcement activities and issue guidance on emerging technologies such as artificial intelligence, cloud computing, and biometric systems.

Companies that prioritize data protection compliance not only avoid legal risks but also build trust with customers, partners, and stakeholders—creating a sustainable competitive advantage in increasingly privacy-conscious markets.

Contact Akkas CPA & Turkish Accounting Firm for Expert Data Protection Guidance

Navigating Türkiye’s complex data protection requirements requires specialized legal expertise and practical business understanding. At Akkas CPA & Turkish Accounting Firm, we have been providing comprehensive corporate legal services in Istanbul since 2017, helping businesses of all sizes achieve and maintain full compliance with Turkish data protection legislation.

Our multilingual legal team offers end-to-end support, from initial compliance assessments and VERBİS registration to drafting privacy policies, implementing data security measures, and representing clients before the Personal Data Protection Authority. Whether you’re establishing a new company or ensuring an existing business meets current requirements, we deliver practical, effective legal solutions tailored to your specific needs.

Contact Akkas CPA & Turkish Accounting Firm today to discuss your data protection compliance requirements and learn how we can help protect your business while enabling growth in the Turkish market.