New Regulatory Framework For Social Media And Digital Games In Turkey

The Act on Amendments to the Social Services Act and Certain Other Acts (Law No. 7578) (the "Act") was published in the Official Gazette on 1 May 2026, establishing a framework addressing both social media platforms and digital games in Turkey. On the social media front, the Act prohibits social network providers from offering services to children under the age of fifteen and mandates the implementation of age verification measures to enforce this prohibition. Social network providers are further required to provide parental control tools and to take measures to prevent deceptive advertising. Those with more than ten million daily users from Turkey are additionally required to take all necessary measures to proactively prevent the re-publication of content that has previously been subject to a removal or access-blocking order. On the digital games front, the Act introduces the concepts of Game Platform, Game Developer and Game Distributor, imposing key obligations on Game Platforms including mandatory age ratings, parental control tools requiring parental approval for in-app purchases, and the appointment of a local representative for foreign-based platforms exceeding 100,000 daily users from Turkey to handle legal and administrative communications with the Information and Communication Technologies Authority ("ICTA").

I. Background

Earlier this year, the Turkish Ministry of Family and Social Services published the Action Plan for Empowering Children in the Digital Environment (2026–2030), signalling forthcoming legislative reforms aimed at strengthening child protection in Turkey's digital ecosystem.

On 4 March 2026, the first concrete legislative step in this direction materialised with the submission to the Turkish Parliament of the Act on Amendments to the Social Services Act and Certain Other Acts. The Act was adopted by the General Assembly of the Turkish Grand National Assembly on 22 April 2026 and published in the Official Gazette on 1 May 2026 as Law No. 7578. Among its wide-ranging provisions, the Act envisages significant amendments to Internet Act No. 5651 (the "Internet Act"), introducing substantial new compliance obligations for social network providers and establishing a dedicated framework for Game Platforms.

II. Obligations Applicable to Social Network Providers

The Act introduces significant new obligations for social network providers operating in Turkey, with a particular focus on the protection of minors and the regulation of online content. These obligations encompass a prohibition on providing services to children under fifteen, mandatory age verification, parental control tools, a prohibition on deceptive advertising, automated content filtering requirements, and expedited compliance with administrative decisions. Each of these key obligations is outlined below.

A. Prohibition on Services to Minors and Age Verification

The Act prohibits social network providers from offering their services to children under the age of fifteen. To enforce this prohibition, providers are required to implement age verification measures and take all necessary steps to ensure that children below this age threshold cannot access their services. Furthermore, social network providers are obligated to take measures to provide differentiated services specifically tailored for children aged fifteen and above. The measures adopted by social network providers under this framework must be published on their respective websites.

B. Automated Content Filtering

Social network providers with more than ten million daily users accessing their platforms from Turkey are required to take all necessary measures to proactively prevent the re-publication of content that has previously been subject to a removal or access-blocking order issued under the Internet Act. Furthermore, where administrative decisions are issued in circumstances of urgency, such providers are obligated to comply immediately and in any event within one hour of notification.

C. Parental Control Tools for Social Network Providers

Social network providers are required to provide clear, understandable, and easy-to-use parental control tools. These tools must include mechanisms for: (a) controlling account settings; (b) making purchases, rentals and paid memberships subject to parental permission or approval; and (c) monitoring and limiting usage time.

D. Prohibition on Deceptive Advertising

Social network providers are obligated to take measures to prevent deceptive advertising on their platforms.

E. Sanctions for Social Network Providers

Where an administrative fine is imposed and the relevant obligation remains unfulfilled within thirty days of the service of such fine, the President of ICTA shall prohibit natural and legal persons who are tax-resident in Turkey from placing new advertisements with the relevant social network provider; no new contracts may be concluded and no monetary transfers may be made in this regard. If the obligation is not fulfilled within three months of the date of the advertising ban decision, the President of ICTA may apply to a criminal court of peace for an order to throttle the social network provider's internet traffic bandwidth by fifty per cent. If the obligation is still not fulfilled within thirty days of the implementation of such court order, the President of ICTA may apply to the criminal court of peace for a further order to throttle the social network provider's internet traffic bandwidth by up to ninety per cent. In its decision on the second application, the court may, taking into account the nature of the service provided, determine a lower rate, provided that it is not less than fifty per cent. Appeals against such court orders may be filed by the President of ICTA in accordance with the provisions of the Criminal Procedure Code (Law No. 5271). Court orders shall be transmitted to access providers through ICTA, and access providers shall comply with such orders immediately and in any event within four hours of notification. Where the relevant obligation is subsequently fulfilled, the advertising ban shall be lifted and the court orders shall become automatically void. ICTA shall notify access providers to terminate the bandwidth throttling measures.

III. Obligations Applicable to Game Platforms

In addition to the social media provisions outlined above, the Act also establishes a dedicated framework for digital games, primarily imposing obligations on Game Platforms.

A. Key Definitions

The Act introduces the concepts of Game, Game Developer, Game Distributor and Game Platform into the legal framework, in order to determine the correct legal subjects for each obligation and to prevent any ambiguity regarding the targets of administrative sanctions. Specifically:

Game is defined as digital games that are distributed or updated via the internet and can be played online or offline in an electronic environment. Game Developer refers to real or legal persons who design digital games or in-game content, develop their software, or manage the development process. Game Distributor refers to real or legal persons who manage sales channel relationships, coordinate the generation and management of licence keys, utilise digital rights management systems, and provide financial or technical intermediary services for the purpose of delivering games produced or published by content providers to end users. Game Platform refers to real or legal persons who provide software or technical infrastructure for the display, sale, distribution, download or playing of digital games and related additional content via the internet, and who facilitate or coordinate user access to games or content, licence management, or user-to-user interaction.

B. Key Obligations for Game Platforms

The Act introduces a set of obligations applicable to Game Platforms operating in Turkey. These obligations encompass mandatory age rating classifications, the provision of parental control tools, the appointment of a local representative for foreign-based platforms exceeding certain user thresholds, and data disclosure requirements to ICTA. Each of these key obligations is outlined in further detail below.

C. Mandatory Age Rating

Game Platforms may not offer games that have not been properly classified in accordance with age criteria. However, they may offer unclassified games by assigning them the highest age category. Without prejudice to their responsibilities and obligations arising from their status as content or hosting providers, Game Platforms are further obliged to remove content that has not been properly classified. The detailed rules regarding age rating classifications and the obligations of Game Platforms in this regard shall be determined by a regulation to be issued by ICTA.

D. Mandatory Parental Control Tools

Game Platforms are required to provide clear, understandable, and easy-to-use parental control tools. These tools must include mechanisms for: (a) controlling account settings; and (b) making purchases, rentals and paid memberships subject to parental permission or approval.

E. Local Representative Requirement

Foreign-based Game Platforms with daily access from Turkey exceeding 100,000 are obliged to appoint a representative, either a natural person or legal entity, in Turkey to receive official notifications, communications or requests from ICTA, the Union, and judicial or administrative bodies, and to comply with other obligations under the Act. The Game Platform must publish the representative's contact information on its website in an easily visible and directly accessible manner.

F.Data Disclosure Obligations to ICTA

ICTA may request disclosures from Game Platforms regarding their compliance with the Act, including their corporate structure, IT systems, and data processing mechanisms, provided that such requests are directly related to the application of the Act. Game Platforms are obliged to submit the requested information and documents immediately and within a timeframe to be determined by ICTA, not exceeding fifteen days.

G. Enforcement Mechanisms and Sanctions

Where a Game Platform fails to comply with the obligations set forth in the Act or in the regulation to be issued by ICTA, ICTA shall issue a notification to the relevant Game Platform. If the notified obligation is not fulfilled within thirty days of such notification, the President of ICTA may impose an administrative fine ranging from one million Turkish liras to ten million Turkish liras. If the notified obligation remains unfulfilled within thirty days of the service of the initial administrative fine, a second administrative fine ranging from ten million Turkish liras to thirty million Turkish liras may be imposed. The amount of the administrative fine shall be determined taking into account the nature and severity of the violation, its impact on users, or the damage caused. Where the notified obligation remains unfulfilled within thirty days of the service of the second administrative fine, the President of ICTA may apply to a criminal court of peace for an order to throttle the Game Platform's internet traffic bandwidth by thirty per cent. If the notified obligation is still not fulfilled within thirty days of the implementation of such court order, the President of ICTA may apply to the criminal court of peace for a further order to throttle the Game Platform's internet traffic bandwidth by up to fifty per cent. In its decision on the second application, the court may, taking into account the nature of the service provided, determine a lower rate, provided that it is not less than thirty per cent. Appeals against such court orders may be filed by the President of ICTA in accordance with the provisions of the Criminal Procedure Code (Law No. 5271). Court orders shall be transmitted to access providers through ICTA, and access providers shall comply with such orders immediately and in any event within four hours of notification. Where the notified obligation is subsequently fulfilled, only one quarter of the administrative fines imposed shall be collected, and the court orders shall become automatically void. ICTA shall notify access providers to terminate the bandwidth throttling measures.

IV. Conclusion

The Act represents a significant development in Turkey's digital landscape, establishing a framework that addresses both social media platforms and the digital gaming industry. By introducing stringent age verification requirements, parental control obligations, mandatory content filtering measures, and a dedicated regime for Game Platforms, the Act signals a clear shift towards enhanced digital sovereignty and child protection. The provisions relating to social network providers and Game Platforms will enter into force on 1 November 2026, providing a six-month transition period from the date of publication. Entities operating in or offering services to users in Turkey are advised to assess the applicability of the Act to their operations and to take the necessary steps to align their technical systems, governance frameworks, and local representation arrangements within this transition period.

We will continue to monitor developments in this area and provide updates as the legislative process progresses.

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.