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Turkey KVKK vs EU GDPR

Law No. 6698 on the Protection of Personal Data (as amended by Law No. 7499, 2024) (Türkiye) compared with Regulation (EU) 2016/679 (General Data Protection Regulation) (European Union (EEA)) on the same topics. Every value comes from the law pages, which link to the official sources.

Topic	Turkey KVKK Türkiye ✓ Confirmed by two sources	EU GDPR European Union (EEA) ✓ Confirmed by two sources
Status	In force since 7 April 2016 (OG 29677); Articles 8-9 and 11-18 applied from 7 October 2016 (Art 32). Amended by Law No. 7499 of 2 March 2024 (in force 1 June 2024), with the old consent-based transfer rule kept alongside the new one until 1 September 2024 (Provisional Art 3).✓	In force since 25 May 2018. Digital Omnibus amendments proposed Nov 2025, not adopted as of Oct 2026.✓
Who it applies to	Applies to natural persons whose data are processed and to every natural or legal person processing personal data by automated means, or by non-automated means as part of a filing system (Art 2). Controllers not established in Türkiye that process data of people in Türkiye are covered too: they must register in VERBIS through a Turkish representative (Registry By-Law Art 11).✓	Any organisation processing personal data in the context of an EU establishment, plus non-EU organisations that offer goods/services to people in the EU or monitor their behaviour there.✓
Size thresholds	The law itself has no size threshold. VERBIS registration exemption (Board Decision 2018/87 as amended by 2023/1154 and 2025/1572): fewer than 50 employees and an annual balance sheet under TRY 100m, provided the main activity is not processing special-category data; since 2025, controllers whose main activity is special-category data are also exempt if they have fewer than 10 employees and under TRY 10m. Controllers that do not keep balance-sheet books are judged on employee count alone (Decision 2025/2393 of 25 Dec 2025).✓	None — applies regardless of size. Limited record-keeping relief for organisations under 250 staff (Art 30(5)), lost if processing is risky, not occasional, or includes special-category or criminal data.✓
Regulator	Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu, KVKK), an independent public legal entity; its decision-making body is the Personal Data Protection Board (Kurul).✓	National data protection authorities (DPAs), coordinated by the European Data Protection Board (EDPB)✓
Breach or incident reporting	If personal data are obtained unlawfully by others, the controller must notify the Board and the affected people as soon as possible (Art 12(5)). Board Decision 2019/10 (24 Jan 2019) sets this as within 72 hours of learning of the breach, using the Board's breach notification form. Affected individuals are told within a reasonable time, directly where possible. There is no risk threshold, so all breaches are reportable.✓	Notify the competent supervisory authority without undue delay and within 72 hours of becoming aware, unless the breach is unlikely to result in a risk to individuals (Art 33). If you have an EU main establishment, that is your lead authority; if you have no EU establishment (even with an EU representative), notify the authority of every member state where affected people live (EDPB Guidelines 9/2022, para 73). Tell affected individuals without undue delay if the risk is high (Art 34).✓
Deadline to answer personal data requests	Requests must be resolved as soon as possible and within 30 days at the latest, free of charge. A fee from the Board's tariff may be charged only if the action has an extra cost (Art 13(2)). The reply must be given in writing or electronically; under an Authority announcement of 1 Oct 2026, phone or face-to-face replies do not count.✓	1 month from receipt; extendable by 2 further months for complex requests if the person is told within the first month. Free of charge unless manifestly unfounded or excessive.✓
Data protection officer	No statutory DPO requirement. Controllers registering in VERBIS must name a 'contact person' (irtibat kişisi) for communication with the Authority: a natural person named by a Turkish controller, or by the representative of a foreign controller. The contact person has no power to represent the controller.✓	DPO mandatory for public bodies, and where core activities involve large-scale regular and systematic monitoring, or large-scale processing of special-category or criminal-offence data.✓
Local representative	Controllers not established in Türkiye must register in VERBIS through a data controller representative before processing starts. The representative must be a legal entity established in Türkiye or a Turkish citizen, appointed by a certified designation decision. At minimum it must receive Authority notices and data subject requests.✓	Non-EU controllers/processors caught by Art 3(2) must appoint an EU representative in writing, unless processing is occasional, low-risk and excludes large-scale sensitive data, or they are a public body.✓
Sending data abroad	Since the 2024 amendments, a transfer abroad needs an Art 5 or Art 6 legal basis plus either a Board adequacy decision (reviewed at least every 4 years) or an appropriate safeguard: Board-approved binding corporate rules, the Board's standard contract, a written undertaking approved by the Board, or a non-treaty agreement between public bodies (Art 9(1)-(4)). A standard contract must be notified to the Authority within 5 business days of signature (Art 9(5)); failing to notify carries a fine (Art 18(1)(d)). Without adequacy or safeguards, only occasional (arızi) transfers on listed grounds are allowed, such as explicit consent after risk information or contract necessity (Art 9(6)).✓	Transfers outside the EEA need an adequacy decision (e.g. UK, Switzerland, EU-US Data Privacy Framework), or safeguards such as Standard Contractual Clauses or Binding Corporate Rules, or a narrow Art 49 derogation.✓
Cookies and consent	No cookie-specific statute; KVKK applies to cookies that process personal data. The Authority's Guide on Cookie Practices (final version 20 June 2022; the current PDF is Publication No. 69, July 2025) says that strictly necessary cookies, including first-party analytics limited to audience measurement, can rely on legal bases other than consent. Behavioural advertising, third-party tracking and similar cookies need prior opt-in explicit consent. Cookie walls that make consent a condition of access may undermine freely given consent.✓	Cookie/tracker consent is governed by the ePrivacy Directive Art 5(3); where consent is the GDPR legal basis it must be freely given, specific, informed, unambiguous and as easy to withdraw as to give.✓
Maximum penalty	2026 administrative fines (Art 18, revalued each 1 January by the tax revaluation rate, 25.49% for 2026): data security failures TRY 256,357-17,092,242; non-compliance with Board decisions TRY 427,263-17,092,242; VERBIS breaches TRY 341,809-17,092,242; privacy notice failures TRY 85,437-1,709,200; failing to notify a standard contract TRY 90,308-1,806,177. Criminal penalties under Turkish Criminal Code Arts 135-140 also apply (Art 17).✓	Up to EUR 20 million or 4% of total worldwide annual turnover, whichever is higher (lower tier: EUR 10 million or 2%).✓

= confirmed by two independent sources, at least one official.

Facts marked “Being verified” are still being confirmed and are not given as answers.

Who each law applies to

Turkey KVKK: Applies to natural persons whose data are processed and to every natural or legal person processing personal data by automated means, or by non-automated means as part of a filing system (Art 2). Controllers not established in Türkiye that process data of people in Türkiye are covered too: they must register in VERBIS through a Turkish representative (Registry By-Law Art 11).
EU GDPR: Any organisation processing personal data in the context of an EU establishment, plus non-EU organisations that offer goods/services to people in the EU or monitor their behaviour there.

What you must do under Turkey KVKK

Register in VERBIS before processing unless exempt (Art 16); foreign controllers register via a Turkish representative.
Give a privacy notice (aydınlatma) when collecting data (Art 10).
Rely on a listed legal basis, with explicit consent only where required (Arts 5-6).
Take technical and administrative security measures and report breaches to the Board within 72 hours (Art 12).
Answer data subject requests in writing or electronically within 30 days (Art 13).
Transfer abroad only via adequacy, safeguards or occasional derogations, and notify standard contracts within 5 business days (Art 9).

Full Turkey KVKK page, sources and checklist

What you must do under EU GDPR

Identify a lawful basis for every processing purpose and record it.
Publish a clear privacy notice covering purposes, recipients, retention and rights.
Keep a record of processing activities and sign Art 28 contracts with processors.
Run a DPIA before high-risk processing such as large-scale profiling or sensitive data.
Report qualifying breaches within 72 hours (lead authority, or every relevant DPA if you have no EU establishment) and log all breaches.
Answer access, erasure and other rights requests within one month.

Full EU GDPR page, sources and checklist

Information only, not legal advice. Laws change; confirm with the regulator or a qualified lawyer before relying on this page. Spotted an error? Email contact@glancedeskjurisdiction.com.