Legal Bulletin On The Amendment To The Regulation On Workplace Opening And Operating Permits

With the Regulation on the Amendment to the Regulation on Workplace Opening and Operating Permits (the "Amending Regulation"), published in the Official Gazette dated 11 December 2025 and numbered 33104, certain amendments have been introduced to the Regulation on Workplace Opening and Operating Permits, which was published in the Official Gazette dated 10 August 2005 and numbered 25902 (the "Regulation").

The principal amendments introduced by the Amending Regulation are summarized below:

• The legal basis provision of the Regulation has been amended, and the underlying legislation has been updated to refer to Law No. 5393 on Municipalities and subparagraphs (c) and (f) of the first paragraph of Additional Article 11 of Law No. 3194 on Zoning.
• The definition of "public places of rest and entertainment" has been revised to expressly include accommodation, entertainment, food and beverage venues, electronic gaming venues, internet cafés, amusement parks, circuses and similar establishments within its scope.
• The definition of "accommodation facilities" has been expanded to cover hotels, holiday villages, motels, pensions, apart-hotels, rural tourism facilities, mobile homes, picnic areas designated for accommodation purposes, accommodation-equipped forest parks, camping sites and luxury tents.
• Within the scope of the amendments regarding general conditions required for workplaces, subparagraph (k) of Article 5 of the Regulation has been amended. Accordingly, instead of being limited to measures facilitating access solely for persons with disabilities, workplaces are now required to be designed in compliance with accessibility legislation for persons with disabilities, the elderly, and other persons with restricted mobility.
• Regarding identity notification obligations, Article 43 of the Regulation has been amended. The obligation, which was previously limited to "hotels, motels, camps and similar accommodation facilities," has been expanded to cover all accommodation facility operators. Consequently, accommodation operators are now required to maintain daily records of identity information and check-in/check-out details of Turkish citizens and foreign nationals staying at such facilities, and to keep such records available for inspection by law enforcement authorities.
• Pursuant to Article 45/A, which has been added to the Regulation, where an application is duly submitted in accordance with the Regulation in relation to investments or activities to be carried out by the public or private sector on immovable properties that are under the control and disposition of the State or owned by the Treasury, public institutions or organizations, or real persons or private legal entities, and the competent authority fails to issue a workplace opening and operating permit within two months from the application date, the Ministry of Environment, Urbanization and Climate Change is authorized to issue a workplace opening and operating permit ex officio, against payment of the fee set out in the Annual Unit Price List of the Revolving Fund Directorate of the Ministry.
• The key amendments introduced under Annex-1 titled "Qualifications Required According to the Classes and Characteristics of Sanitary Establishments" are summarized below:
  • Under the section "A – Minimum Common Conditions Required for Workplaces", a new requirement has been introduced stipulating that accommodation facilities must have obtained an occupancy permit and a fire safety report.
  • The heading "I – Hotels and Pensions" has been replaced with "Accommodation Facilities", and the scope of the provisions under this section has been expanded to cover different types of accommodation facilities.
  • A new section titled "S – Residential Units Leased for Tourism Purposes" has been introduced. Accordingly, excluding high-quality residences, a workplace opening and operating permit has become mandatory for residential units falling within the scope of Law No. 7464 dated 25 October 2023, where the number of independent units within the same building leased by the same lessor and subject to a permit exceeds five. Additional conditions applicable to the permits to be issued for such residential units are also regulated under this section.
• With respect to Annex-2 titled "List of Non-Sanitary Establishments", amendments—primarily in the form of additions—have been made concerning various activity areas, particularly in the chemical, petrochemical, food products, beverages, animal feed and agricultural products, machinery, mining, energy and textile sectors.
• By the introduction of Annex-3, the types of workplaces classified as public places of rest and entertainment have been listed separately and explicitly for the first time.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.