Turkey Personal Data Protection Law (KVKK No. 6698) + AI Strategy 2021-2025: AI Compliance Requirements
Turkey's KVKK (Kişisel Verileri Koruma Kanunu, Law No. 6698) is Turkey's GDPR-equivalent, administered by the Personal Data Protection Authority (KVKK Board). While Turkey is not in the EU, KVKK aligns closely with GDPR principles and is a prerequisite for Turkish market access. Turkey's National AI Strategy 2021-2025 adds sector-specific AI obligations across finance (BRSA/BDDK), healthcare, and transportation. Turkey processed for EU adequacy decision as of 2026.
Key Facts
April 7, 2016
October 1, 2018
TRY 1,000,000 (~$30,000 USD) administrative fine + criminal sanctions under Turkish Penal Code (TPC Art. 135-140). KVKK Board can suspend processing.
What Your Business Must Do
4 compliance requirements identified. Critical requirements carry the highest risk of enforcement action.
Explicit Consent and Processing Conditions
CriticalKVKK Article 5 permits personal data processing only under explicit consent or specific lawful grounds (statutory obligation, contract, vital interests, legitimate interest). AI systems processing Turkish residents' data must obtain affirmative, specific consent for each processing purpose and maintain timestamped consent records.
Data Controller Registry (VERBİS) Registration
CriticalKVKK Article 16 requires data controllers processing personal data to register in VERBİS (Veri Sorumluları Sicili Bilgi Sistemi) before commencing processing. Foreign companies processing Turkish resident data must also register. AI system data processing activities must be accurately declared in VERBİS.
Data Subject Rights and Response Obligations
High PriorityKVKK Article 11 grants Turkish residents rights to access, correct, delete, and object to processing. Controllers must respond within 30 days (or 60 days in complex cases). AI decisions must be explainable and subject to human review on request. Healthcare and financial AI must provide enhanced explainability under KVKK Board guidance.
Turkey National AI Strategy 2021-2025 Compliance
Medium PriorityTurkey's National AI Strategy sets requirements for public-sector AI transparency, algorithmic accountability, and human oversight. BDDK/BRSA-regulated entities using AI in credit, fraud, or customer segmentation must conduct model risk assessments. KVKK Board has issued sector-specific guidance on AI profiling and automated decisions.
Frequently Asked Questions
Does Turkey Personal Data Protection Law (KVKK No. 6698) + AI Strategy 2021-2025 apply to my business?
Turkey's KVKK (Kişisel Verileri Koruma Kanunu, Law No. 6698) is Turkey's GDPR-equivalent, administered by the Personal Data Protection Authority (KVKK Board). While Turkey is not in the EU, KVKK aligns closely with GDPR principles and is a prerequisi. Use ComplianceIQ's free scanner to get a personalized assessment in under 5 minutes.
What is the penalty for non-compliance?
The maximum penalty under Turkey Personal Data Protection Law (KVKK No. 6698) + AI Strategy 2021-2025 is: TRY 1,000,000 (~$30,000 USD) administrative fine + criminal sanctions under Turkish Penal Code (TPC Art. 135-140). KVKK Board can suspend processing.. Fines are typically scaled by company size, severity of violation, and whether violations were willful or accidental.
How do I comply with Turkey Personal Data Protection Law (KVKK No. 6698) + AI Strategy 2021-2025?
The 4 requirements above cover the core obligations. The fastest path to compliance is: (1) conduct an AI risk assessment, (2) document your AI systems, (3) implement transparency disclosures where required. ComplianceIQ generates all required documents automatically.
Official Source
https://kvkk.gov.tr/en/Last updated: 2026-04-14 — verify at source before relying on this information.
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