If a foreign game platform is accessed from Türkiye more than one hundred thousand times a day, it must appoint a representative in Türkiye, notify the Authority, and publish that representative’s identity and contact details on its own website. The duty starts on 1 November 2026. A second violation carries an administrative fine of up to thirty million Turkish lira.
The rule is new. It was created by Law No. 7578, published in the Resmî Gazete of 1 May 2026, issue 33240, which inserts a new supplementary article into Law No. 5651 on the regulation of internet publications. Because the obligation only commences on 1 November 2026, it does not yet appear in the consolidated text of Law 5651 on the government’s legislation portal; the Gazette is the source until that date, and anyone who checks the consolidated text before then will find the article missing and conclude wrongly that it does not exist.
This page is written for the person inside a foreign platform who has to decide what to do about it: a general counsel, a head of compliance, a regional director, or the founder of a studio that has grown a Turkish audience without planning for one.
Who exactly does the representative requirement bind?
The article binds a yurt dışı kaynaklı oyun platformu — a foreign-sourced game platform — whose daily access from Türkiye exceeds one hundred thousand. Two elements decide it, and both are worth reading slowly.
Foreign-sourced. The platform is operated from outside Türkiye. A Turkish company running a Turkish platform is already inside the ordinary regime and is not the target of this article.
More than one hundred thousand daily accesses from Türkiye. The test is access, not registered users, not downloads, not paying customers, and not monthly figures. It is a daily count of access from Türkiye. No public register tells an operator whether it is over the line; the figure sits in the platform’s own analytics, and applying the test is the operator’s own job. We do not assert any company’s access figure and no adviser honestly can.
What does the representative actually have to do?
Three duties sit in the article, and they are cumulative rather than alternative.
- Designation. The platform designates a representative in Türkiye. The representative may be a real person or a legal person, so a Turkish company or an individual professional both qualify.
- Notification. The designation is notified to the Authority.
- Publication. The representative’s identity and contact details are published on the platform’s own website, in an easily visible and directly accessible form. This is the part operators tend to miss: it is not enough to have appointed someone privately and told the regulator. The appointment has to be visible to the public on the platform’s own site.
Rating and parental-control duties attach in the same article, so a platform working through this obligation should treat the representative appointment and its content-rating position as one project rather than two.
What happens on 1 November 2026, and what happens after it?
Article 27 of Law 7578 sets the commencement expressly: the articles carrying these obligations enter into force six months after publication, and every other article entered into force on the day of publication. Publication was 1 May 2026, so the operative date is 1 November 2026.
The practical consequence of that date is worth stating plainly, because it is the whole reason to act now rather than in November. Before the date, a platform that appoints a representative is in preparation. After it, the same platform is in enforcement: the duty is live, the absence of a representative is a violation on its face, and the conversation with the Authority starts from a different place. Nothing about the work is easier in December than in September, and the file is materially worse.
How large is the fine?
The article carries an administrative fine on a ladder rather than a single figure. The first violation runs from one million to ten million Turkish lira. A second violation runs from ten million to thirty million Turkish lira. Thirty million is therefore the ceiling of the second step, not the opening figure, and a platform that corrects quickly after a first notice never reaches it.
| Point | Position |
|---|---|
| Who it binds | a foreign-sourced game platform with more than 100,000 daily accesses from Türkiye |
| What is required | a representative in Türkiye, notified to the Authority, published on the platform’s own website |
| Who may be the representative | a real or legal person in Türkiye |
| Live from | 1 November 2026 |
| First violation | administrative fine, one million to ten million lira |
| Second violation | administrative fine, ten million to thirty million lira |
| Instrument | Law No. 7578, Resmî Gazete 1 May 2026, issue 33240, inserting a supplementary article into Law No. 5651 |
Is there a parallel duty for social networks?
Yes, and it commences on the same day. The same Law rewrites the social-network provider regime in Law 5651 and adds a heavier tier above ten million daily accesses from Türkiye. A company that operates both a game platform and a social surface should read the two together rather than assume one answer covers both, because the thresholds differ by two orders of magnitude and the duties are not identical.
Which authority receives the notification?
The article as published says the Authority without naming it in the text. We say the same, deliberately. The naming is settled either by the implementing secondary legislation or by the Authority’s own announcement, and an adviser who guesses at this stage is guessing on the one point a platform cannot afford to get wrong, since a notification filed with the wrong body is not a notification. When the position is fixed we act on the fixed position; until then the honest answer is that the article does not name it.
Who can act as the representative?
Because the article permits a real or a legal person, a platform has a genuine choice. A local employee is possible but ties a statutory function to one person’s employment. A subsidiary is possible where one already exists and is unattractive where one does not, since incorporating a Turkish company to hold a notification duty is a disproportionate answer. A Turkish law firm acting as representative keeps the function professional, insured, permanent, and independent of any single individual’s tenure, and it puts the person who receives a regulatory communication in a position to answer it.
This office acts as representative for foreign platforms and handles the whole appointment: the threshold assessment against the article’s own wording, the designation instrument, the notification to the Authority, the published contact block for the platform’s own site in Turkish and English, and the standing role afterwards.
What should a platform do before November?
- Take the daily access figure from Türkiye out of your own analytics and apply the article’s test to it. If you are close to the line rather than clearly under it, plan as though you are over.
- Decide who the representative will be, and decide it early enough that the designation instrument can be executed without a rush.
- Prepare the published contact block for your own site now. It is the visible part of compliance and the part a regulator can check without asking you anything.
- Read the rating and parental-control duties alongside the appointment, because they sit in the same article and arrive on the same day.
Why this firm
The file is answered by Av. Serkan Kara, Istanbul Bar roll no. 53770, Union of Turkish Bar Associations no. 121348, in practice since 2015, holder of the CCBE Lawyer’s Professional Identity Card. He reads both great legal families: Turkish and Continental civil law, and Anglo-American common law read at the University of Cologne on the US Law program. He is also a developer, hands-on since MS-DOS, and a member of the Google Developer Program at Premium tier, with machine learning among the firm’s stated specialisms.
That combination is the point on a file like this one. A platform’s compliance question is never only a legal question: it turns on how access is actually counted, what the analytics can and cannot show, and what a published contact block does to the platform’s own front end. Counsel who has to be briefed on the architecture before reading the statute costs a platform a round trip on every question.
The source
The instrument is Law No. 7578, published in the Resmî Gazete of 1 May 2026, issue 33240: the Gazette’s own page. Cite it to the Gazette rather than to the consolidated text of Law 5651, which does not carry the article until the day it commences.