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“Public Announcement on the Implementation Principles of the Personal Data Protection Board’s Decision Dated 04.09.2025 and Numbered 2025/1572” Has Been Published by the Turkish Personal Data Protection Authority

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The Turkish Personal Data Protection Authority has published the “Public Announcement on the Implementation Principles of the Decision of the Personal Data Protection Board dated 04.09.2025 and numbered 2025/1572” on its official website.

Pursuant to the second paragraph of Article 16 of the Personal Data Protection Law No. 6698 (“Law”) natural and legal persons who process personal data are required to register with the Data Controllers’ Registry Information System (“VERBIS”) prior to commencing data processing activities. However, taking into account objective criteria such as the nature and volume of the processed personal data, whether the data processing is based on a legal obligation, or whether the data are transferred to third parties, the Personal Data Protection Board (“Board”) may grant exemptions from this obligation.

Within this framework, the Board has adopted various decisions determining the data controllers and processing activities that are exempt from the obligation to register with VERBIS, and the scope of such exemptions has been updated. With the Board Decision dated 04.09.2025 and numbered 2025/1572, the following data controllers have been exempted from the VERBIS registration obligation:

  • Natural or legal person data controllers whose annual number of employees is fewer than 50 and whose annual financial balance sheet total is below TRY 100 million, provided that their principal activity does not involve the processing of special categories of personal data; and

  • Natural or legal person data controllers whose principal activity involves the processing of special categories of personal data, provided that their annual number of employees is fewer than 10 and their annual financial balance sheet total is below TRY 10 million.

However, in the opinion requests submitted to the Authority, it has been stated that the information regarding the “annual financial balance sheet total” is available only for taxpayers who keep books on a balance sheet basis, and that uncertainties have arisen as to how this criterion should be applied to data controllers who do not keep books on a balance sheet basis.

As a result of the assessment carried out in this context, with the Board Decision dated 25.12.2025 and numbered 2025/2393, it has been resolved that:

  • For data controllers who keep books on a balance sheet basis, both the “annual number of employees” and the “annual financial balance sheet total” criteria shall be taken into account cumulatively in determining the VERBIS exemption; and

  • For data controllers who do not keep books on a balance sheet basis, as there is no available information regarding the annual financial balance sheet total, only the “annual number of employees” criterion shall be taken into account.

You can access the full text of the public announcement here. 

 

Kind regards,

Zumbul Attorneys-at-Law

info@zumbul.av.tr

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