Türkiye's data protection landscape in 2025: What international companies need to know

International organisations have faced a shifting landscape for complying with data Türkiye's protection law (KVKK) in the years since it was first adopted in 2016. While the core tenets of the KVKK have remained relatively stable, regulatory activity and market maturity has increased significantly in the last three years.

Guidance, penalties and enforcement have all increased in 2025, while KVKK scrutiny of foreign data controllers and processors has expanded into other areas including international transfers and security practices. 

This article provides an overview of: 

• Recent changes to Turkish data protection law
• How enforcement activity has evolved 
• What international organisations should know about processing the personal data of Turkish individuals.

Changes to KVKK requirements

A local KVKK representative appointment and VERBİS registration have been requirements for foreign data controllers for several years, but the regulation continues to develop. The 2025 Cross-Border Data Transfer Guide issued by the Turkish Data Protection Authority (KVKK Authority) is an important step in this evolution.

The Guide provides more detail on the mechanics of how the adequacy of protection is to be assessed by setting out a hierarchical evaluation method for selection of the legal ground of cross-border data transfers. It makes a clear distinction between data transfers and direct collection/disclosure of personal data to foreign third parties. 

In this respect, it also includes specific guidelines on the use of the standard contractual clauses (SCCs) as one of the primary safeguards to be applied by data controllers in absence of adequacy decision. The Guide imposes an obligation on data controllers to notify KVKK regarding the execution of the SCCs within 5 business days together with the submission of all the documentation in the form of apostilled and translated versions of the contract and its annexes.

These are examples of how the regulatory framework is not static and how foreign data controllers should evidence not just compliance with new procedures but engagement with them.

Monitoring and enforcement trends

The Turkish Data Protection Authority has moved away from a guidance-orientated approach to active enforcement. In August 2024, 16,350 organisations were investigated for non-compliance with KVKK VERBİS registration obligations and penalties totalling ₺503,935,000 (~€14 million) were issued. 

The sanctions were applied to both domestic and foreign data controllers and even public institutions were not spared from disciplinary action. This was a turning point in the KVKK Authority’s enforcement posture, which now extends beyond registration to data security practices, consent management and cross-border transfer mechanisms.

Coordination with other regulators also appears to be on the rise. In 2025, the KVKK Authority and the Capital Markets Board signed a protocol of cooperation, which may be an early sign of greater regulatory convergence and associated implications for financial institutions and listed companies that process personal data.

Companies are increasingly being reviewed on whether they:

1. Have an appropriate legal basis for each processing activity;
2. Provide data subjects with clear and transparent information;
3. Have implemented reasonable technical and organisational safeguards;
4. Respect data subject rights in practice; and
5. Take steps to manage international data transfers in line with applicable requirements.

Potential risks and consequences of non-compliance

The increase in enforcement activity has been accompanied by increases in penalties. The administrative fines for non-compliance with the KVKK were increased in 2025 with the applicable range now being between ₺68,083 and ₺13.6 million (increased by 43.93%). Fines can be imposed for a range of violations including failing to appoint a representative and data breaches.

Demonstrated compliance with the KVKK has also become operationally important in practice. Reputational damage from enforcement should not be underestimated either. For foreign companies operating in Türkiye, there is a move towards greater operational accountability, with possible requests for inspections or audits in certain circumstances such as complaints or incidents.

Enforcement trends and examples

Below are some examples of cases that are related to the Authority’s increased intervention:

1. In 2023, Meta and WhatsApp were fined ~₺2.6 million each for failure to complete VERBİS registration. The companies had been given a final compliance deadline before further escalation measures.
2. In 2024, the mass investigations resulted in more than ₺500 million in fines across over 16,000 entities that were found not compliant with KVKK registry obligations.
3. Twitch was fined ₺2 million in 2024 for a data breach that affected over 35,000 Turkish users. This reflects the growing scrutiny of data security practices. These cases are just some examples of how the Authority’s focus has broadened beyond administrative to more substantive data protection.

The role of the KVKK representative

The breadth of requirements in the KVKK has increased, but appointment of a local representative remains a core obligation. Foreign data controllers without a legal entity in Türkiye are not permitted to register with VERBİS themselves. The representative serves as the main point of contact for the KVKK Authority and Turkish data subjects.

The appointment should be formalised through a notarised and apostilled power of attorney or equivalent document issued by the controller’s authorised body, clearly outlining the scope of the representative’s authority and responsibilities. The representative mechanism also helps to facilitate the Authority’s oversight of foreign companies and enforcement of the law.

Conclusion

Meeting KVKK compliance requirements in 2025 involves more than checking a list of procedures. With expectations and global rules around data transfer mechanisms becoming more stringent, international companies will need to be more strategic and integrated in their approach. 

Monitoring by Turkish authorities will increase and so will sector-specific interventions and the financial impact of non-compliance. Businesses must ensure that they meet core obligations such as local representation, lawful international transfers and transparency requirements to avoid disruption and maintain trust with Turkish stakeholders.

If you would like support in navigating your obligations under Turkish Data Protection law, book a free consultation with one of our experts and find out how Prighter can support you.