Turkey AI Regulation Overview

Overview

Turkey's AI governance strategy operates at the intersection of executive policy planning, multi-agency supervisory guidance, and pending legislative initiatives. Central coordination is led by the Presidency Digital Transformation Office and the Ministry of Industry and Technology under the National Artificial Intelligence Strategy 2024-2025 Action Plan. This strategy builds upon Presidential Circular 2021/18 and sets 71 concrete actions to accelerate technological adoption, build compute infrastructure, and foster talent through national programs.

In parallel, legislative activity within the Grand National Assembly of Turkey (TBMM) reflects an active movement toward binding regulatory frameworks. Parliament established a dedicated AI Research Commission via Decision No. 1426 in October 2024 to evaluate risks, map cross-sectoral deployments, and draft recommendations for national legal infrastructure. Meanwhile, two primary draft bills are under parliamentary review: the Yapay Zeka Kanun Teklifi (Esas No. 2/2234) and the Bill on Amendments to Certain Laws Regarding Artificial Intelligence (Esas No. 2/3358).

Regulatory Approach

Turkey currently employs a hybrid regulatory approach that relies on non-binding soft law, sector-specific directives, and existing statutory frameworks while preparing formal horizontal legislation. Guidance documents issued by key authorities—such as the Personal Data Protection Authority (KVKK), the Council of Higher Education (YÖK), and the Ministry of National Education (MEB)—provide immediate operational compliance standards based on accountability, transparency, and data minimization principles.

The emerging legislative architecture exhibits both horizontal and risk-based characteristics. Bill Esas No. 2/2234 proposes a consolidated horizontal framework that classifies AI applications by risk levels, imposing strict pre-market conformity assessments and registration requirements for high-risk systems. Conversely, Bill Esas No. 2/3358 adopts a targeted omnibus approach, integrating AI definitions, expedited content-takedown obligations, deepfake labeling requirements, and penal modifications directly into existing statutes such as Law No. 5651, Law No. 5237, Law No. 6698, and Law No. 7545.

Key AI Legislation

Main regulations and bills in Turkey's legal framework include:

• National Artificial Intelligence Strategy 2024-2025 Action Plan: Adopted in July 2024 under the coordination of the Presidency Digital Transformation Office and the Ministry of Industry and Technology, establishing 71 priority actions across public administration, R&D, infrastructure, and standards.
• Yapay Zeka Kanun Teklifi (TBMM Esas No. 2/2234): A comprehensive draft law submitted in June 2024 that establishes baseline principles, risk management duties, mandatory registration and conformity assessments for high-risk AI systems, and turnover-based administrative fines.
• Bill on Amendments to Certain Laws Regarding Artificial Intelligence (Esas No. 2/3358): Introduced in November 2025 to amend existing statutes, defining AI systems under Law No. 5651, mandating a 6-hour takedown window for infringing AI content, requiring persistent deepfake labeling, and amending the Turkish Penal Code.
• TBMM Decision No. 1426: Adopted in October 2024 establishing a 22-member parliamentary Meclis Research Commission to examine legal infrastructure, cross-sectoral impacts, and risk mitigation strategies for AI.
• Policy Document and Action Plan on AI in Education (2025-2029): A sectoral policy adopted by MEB in June 2025 outlining 15 policy directions and 40 action steps for governance, curriculum review, and learning analytics.
• KVKK AI Personal Data Protection Recommendations Guide: Non-binding guidance issued in September 2021 covering the entire AI lifecycle, privacy-by-design, and controller/processor responsibilities under Law No. 6698.
• KVKK Explanatory Note on Chatbots: Guidance published in November 2024 clarifying compliance requirements under Law No. 6698 for conversational models, user prompts, and cross-border transfers.
• YÖK Generative AI Ethics Guide: Issued in May 2024 by the Council of Higher Education to govern GAI use in university research, manuscript preparation, and academic publishing.

Governance & Enforcement Bodies

AI oversight in Turkey is currently distributed across multiple existing executive offices and independent regulatory authorities. Executive steering is led by the National AI Strategy Guidance Board, chaired by the Vice-President, alongside operational coordination by the Presidency Digital Transformation Office and the Ministry of Industry and Technology. These bodies manage strategic infrastructure investments, domestic large language model initiatives, and cross-sectoral policy delivery.

Enforcement of data-related AI risks is spearheaded by the Personal Data Protection Authority (KVKK), which enforces Law No. 6698 across AI development and deployment. The Information and Communication Technologies Authority (BTK) manages online content, internet publications under Law No. 5651, and telecommunications integrity. Additional institutional oversight is exercised by sector-specific bodies, including the Ministry of National Education (MEB) and its General Directorate of Innovation and Educational Technologies (YEĞİTEK) for primary and secondary education, and the Council of Higher Education (YÖK) for university research.

Penalties & Enforcement

Penalties for non-compliance are established under existing statutory regimes and expanded in proposed legislation. Under the draft Yapay Zeka Kanun Teklifi (Esas No. 2/2234), enforcement authorities are empowered to issue severe administrative fines and turnover-based caps: prohibited AI applications carry fines up to 35 million TL or up to 7% of annual global turnover; general obligation breaches carry fines up to 15 million TL or up to 3% of turnover; and disseminating false or misleading information incurs penalties up to 7.5 million TL or up to 1.5% of turnover.

Under proposed omnibus amendments in Bill Esas No. 2/3358, the BTK gains emergency authority to block content or order removals, with administrative fines up to 10 million TL for specific violations, cybersecurity fines up to 5 million TL under Law No. 7545, and temporary activity suspensions. In addition, proposed amendments to the Turkish Penal Code (Law No. 5237) treat individuals who direct AI systems to commit offenses as direct perpetrators and increase penalties for developers and designers whose system designs or training enable criminal acts.

Data Protection Framework

Data protection in Turkey is anchored by Law No. 6698 on the Protection of Personal Data (KVKK Law). KVKK has issued extensive guidance adapting Law No. 6698 to AI contexts, including the 2021 AI Recommendations Guide, the 2024 Deepfake Information Note, and the 2024 Explanatory Note on Chatbots. These instruments affirm that core privacy principles—lawfulness, purpose limitation, data minimization, accuracy, storage limitation, and security—apply strictly to AI training datasets, user inputs, interaction logs, and derived inferences.

KVKK guidance requires data controllers and processors to establish clear lawful bases before processing personal or special category data in AI systems. The framework highlights privacy-by-design and privacy-by-default, mandatory Data Protection Impact Assessments (DPIAs) for high-risk profiling or sensitive data uses, dataset anonymization, and contractual safeguards for vendor models and cross-border data transfers. The Deepfake Information Note specifically addresses risks stemming from synthetic media that combine authentic personal data with generative manipulations.

Sector-Specific Rules

Sector-specific AI governance is most fully articulated in the education and higher education sectors. The Ministry of National Education (MEB) implemented the Policy Document and Action Plan on AI in Education (2025-2029) alongside a practical Teacher Guide on Generative AI in July 2025. These frameworks mandate ethical review procedures for school-level AI projects, vendor evaluation criteria, privacy safeguards for student data under KVKK, and guidelines for adaptive learning tools and prompt engineering in classrooms.

For academic research, the Council of Higher Education (YÖK) issued its Ethics Guide in May 2024, regulating generative AI in higher education institutions. The guide prohibits listing AI tools as authors, mandates transparent disclosure of AI contributions in research methodologies and acknowledgements, and requires institutional ethics committees to review high-risk research applications involving sensitive data or automated decision-making. In broader commercial sectors, draft bill Esas No. 2/2234 identifies high-risk applications in medical diagnostic tools, autonomous vehicles, and criminal justice systems.

International Alignment

Turkey's AI strategy and regulatory guidance explicitly seek interoperability with international standards and frameworks. The National Artificial Intelligence Strategy 2024-2025 Action Plan emphasizes active participation in international standardization activities, aligning national policy with OECD AI Principles and Council of Europe workstreams. KVKK's AI recommendations also reference OECD principles and European data protection practice to ensure cross-border regulatory alignment.

Educational and academic governance frameworks similarly incorporate international benchmarks. MEB's Policy Document and Action Plan on AI in Education (2025-2029) was published with an official English translation to facilitate knowledge sharing and align national policies with European regulatory developments. Furthermore, draft legislative proposals reflect risk classification concepts and conformity assessment mechanisms drawing inspiration from international legislative models like the EU AI Act.

Future Developments

Future developments in Turkish AI regulation center on legislative deliberation within the Grand National Assembly of Turkey (TBMM). The parliamentary Meclis Research Commission on AI, established under Decision No. 1426, is tasked with mapping existing deployments, identifying legal gaps, and issuing a comprehensive report to guide future legislation and regulatory structures across public and private sectors.

Key pending legislative proposals under commission review include the Yapay Zeka Kanun Teklifi (Esas No. 2/2234) and the omnibus Bill Esas No. 2/3358. If enacted, these bills will formalize national AI registries, establish mandatory conformity procedures for high-risk models, enforce 6-hour takedown response windows for infringing AI content, introduce persistent deepfake labeling, and establish turnover-based penalty regimes administered by BTK, KVKK, and relevant ministries.

Enforcement Bodies