Game marketing in Türkiye runs on three channels that the Advertising Board (Reklam Kurulu) watches closely: paid creatives on social platforms and ad networks, creator and streamer sponsorships, and the store page itself. Each is a “commercial advertisement” under Article 61 of the Consumer Protection Law No. 6502, and the Regulation on Commercial Advertising and Unfair Commercial Practices (Official Gazette 10 January 2015, No. 29232, as amended) applies to it whether the advertiser is in İstanbul or Helsinki, as long as the ad reaches consumers in Türkiye. For games, the Board’s attention concentrates on four things: creatives that show gameplay the game does not contain, sponsored content not labelled as advertising, ads that exploit children, and the word “free” attached to a product that costs money. This article sets out the general rules, the influencer guide and its labels, the children’s rules in Article 24, the free-claim and dark-pattern items in the unfair-practice annex, the position of the studio when the ad is placed by a network or an agency, and the sanctions. It pairs with our AI in advertising note and the loot box article.
The general rules: truthful, identifiable, not exploitative
Article 61 of Law 6502 requires commercial advertising to comply with the law and the principles the Board sets, to be truthful and honest, and not to mislead or exploit the consumer’s lack of experience or knowledge, and prohibits covert advertising. The Regulation turns this into operative rules. Article 5 lists the general principles: ads must not violate public morality, must not exploit the sick, children, the elderly or the disabled, and must respect human dignity, among others. Article 6 requires an ad to be identifiable as an ad whatever its format or medium. Article 7 requires ads to be truthful and honest and prohibits statements or images that mislead by implication, omission or ambiguity. Article 29 treats as deceptive a commercial practice whose information, even if factually correct, deceives the average consumer by the way it is presented, and Article 9 puts on the advertiser the burden of proving every claim in its ads. Article 13 governs price presentation, Article 14 discount claims, Article 15 promotions and prize draws, and Article 22 bans covert advertising in any medium. For a game studio the most frequently engaged rule is Article 7 read with Article 29: the “fake gameplay” creative, which shows a puzzle, a mechanic or graphics the downloaded game does not deliver, is misleading advertising, and under Article 29 a “not actual gameplay” disclaimer does not cure a creative whose overall impression is false. The safe creative shows the game as it is, or labels clearly and prominently what is cinematic.
The influencer guide
Additional Article 1 of the Regulation authorises the Board to publish guides that apply together with the Regulation, and for five years the Guide on Commercial Advertising and Unfair Commercial Practices by Social Media Influencers, adopted by the Board’s decision of 4 May 2021 (Principle Decision No. 2021/2, meeting No. 309), was the operative text for creator marketing. Since 1 August 2026 the core rules are in the Regulation itself. Article 23/A, added by the amending regulation published in the Official Gazette of 1 July 2026 (No. 33297), requires advertising through social media influencers to be clear, understandable and distinguishable, and requires the post to state plainly that it is an advertisement where the creator directs followers to the advertiser or its goods or services, receives money or free or discounted goods or services or other benefits from the advertiser, shares content about the advertiser’s draws, contests or campaigns, or posts in return for a benefit for attending the advertiser’s event. Every such post must contain the word “Reklam” or “Tanıtım” together with the advertiser’s name or trade name or a statement such as “provided by @[advertiser]” or “thanks to @[advertiser]”; tags such as #Sponsor, #İşbirliği or #Ortaklık on their own are no longer enough. Under Article 23/A(4) the label must stand out from the post’s colours and background in an easily readable size, be visible when the consumer first sees the post without scrolling or being sent elsewhere, come before and be clearly separate from any other tags, not be covered by text or symbols, and be repeated in every post where the content is spread over several posts or formats; under Article 23/A(5) audio-only content must say “contains advertising/promotion about [advertiser]” at the start of the broadcast and before the advertisement. The Guide continues to apply together with the Regulation where consistent with Article 23/A, including its rules that creators may not present a product as personally experienced if they have not used it or create the impression that they bought a product they were given, and its duties on the advertiser: to inform creators of the rules, to ensure that agencies and networks acting for it comply, and to act when they do not. For a studio this means a creator brief prescribing the “Reklam” or “Tanıtım” label and the studio’s name, a contract clause requiring compliance with Article 23/A and the Guide and giving the studio a takedown right, and a monitoring routine, because the Board sanctions the advertiser as well as the creator.
Children: Article 24
Article 24 of the Regulation applies to ads directed at children, ads likely to influence children and ads in which children appear. Such ads may not contain anything harmful to children’s physical, mental, moral, psychological or social development; may not create unrealistic expectations or blur fiction and reality in a way unsuited to the age group; may not suggest that owning the product gives a child an advantage over peers or that not owning it has the opposite effect; may not show imitable violence or dangerous situations; may not exploit children’s trust in parents or teachers or undermine parental authority; may not directly encourage children to persuade parents or others to buy; may not imply that children may conclude contracts; may not state that the product suits every family budget or use “only” or “just” next to a price; must disclose where additional products or skills are needed to achieve the shown result; and, under Article 24(2), ads for distance contracts may not contain a direct invitation to purchase aimed at children. For a game whose audience is young, this rules out the “ask your parents for gems” creative, the “only 29 lira” banner, the influencer telling children to buy the skin, and gameplay shown as achievable without purchases when it is not. The store age rating does not settle who the ad is “likely to influence”; the Board looks at the content, the medium and the placement. Since 1 August 2026, Article 25/A(3) of the Regulation also prohibits targeted advertising based on profiling with personal data where the consumer is known, or can reasonably be expected to be known, to be a child, so user-acquisition campaigns aimed at young audiences should use contextual rather than behavioural targeting.
“Free”, prizes and dark patterns
The Regulation’s annex lists commercial practices that are unfair in all circumstances. Item A-16 makes it unfair to describe a good as free, gratis or similar where the consumer must pay anything beyond the necessary delivery cost; a game advertised as “free” that cannot be played meaningfully without payment, or a “free” reward that requires a purchase, is caught where the “free” claim is the central message and the paywall is material to the decision to download. Item A-15 makes it unfair to claim a contest or prize without a defined prize or equivalent, and item B-5 targets creating the false impression that the consumer has won or will win a prize where obtaining it requires payment. Item A-22, in force since 1 March 2022, makes it unfair to use interface designs, options or wording online that impair the consumer’s decision-making or steer it in the seller’s favour, which reaches countdown timers that reset, “limited” offers that recur, confusing currency bundles, pre-selected upsells and cancellation flows designed to fail. Article 15 requires promotions, contests and draws to state their conditions and duration. The practical checklist for a store page and an in-game store is therefore short: say “free to download” or “free to play with optional purchases” rather than “free”; price every bundle in lira; make timers true; and design cancellation to be as easy as purchase.
Who is liable when the network placed the ad
Article 61(7) of Law 6502 makes the advertiser, the advertising agency and the media owner each responsible for compliance, Article 77(12) sanctions all three, and the Board’s practice is to sanction the advertiser for the content and the agency or medium where they contributed to it. A studio that hands creatives to an ad network or a user-acquisition agency remains the advertiser: it approved the message and benefits from it. Where the network generates variations, including with AI tools, the studio’s approval process should cover them, and the agency contract should allocate the fine and the takedown cost. Cross-border placement does not remove jurisdiction; the Board applies the Regulation to ads reaching Turkish consumers whoever placed them, and Article 77 of the Law, as amended in 2022 and 2024, lets the Board order the removal of infringing online content and, where it is not removed within twenty-four hours of notice or the advertiser cannot be reached, order access to be blocked, limited to the content where technically possible and otherwise to the whole site.
Sanctions and process
Article 77 of Law 6502 gives the Board the power to order cessation or correction of the advertisement or practice, to suspend it for up to three months as a precaution, to order content removal and access blocking for online infringements, and to impose administrative fines that are revalued annually, graded by medium (internet placements fall in the same band as satellite television) and calibrated to the gravity of the breach, the benefit obtained or damage caused, and the advertiser’s fault and economic situation; the Board publishes its decisions monthly. Proceedings start with a complaint or the Board’s own monitoring, the advertiser is asked for its evidence and defence, and the decision can be challenged before the administrative courts. Because the Board publishes the advertiser’s name with the decision, the reputational cost in a market where store reviews matter often exceeds the fine. A studio’s defensive file should contain the approved creatives with dates and placements, the substantiation for every claim (including that the gameplay shown exists), the creator briefs and contracts, and the store-page history.
Our creatives say “not actual gameplay”. Is that enough?
Not where the overall impression is that the shown mechanic is the game. Article 29 of the Regulation, read with Article 7(5), treats an ad as misleading by its presentation even if a disclaimer is literally true. Show the real game, or make the cinematic nature unmistakable in size, duration and wording.
We send free codes to streamers with no payment. Do they need to label?
Yes. Article 23/A(2)(b) of the Regulation, in force since 1 August 2026, expressly covers free or discounted goods and services received from the advertiser; the post must carry the word “Reklam” or “Tanıtım” together with your name or one of the prescribed statements, and the streamer may not present the game as bought or as experienced beyond what she actually played. Put the label requirement in your code-distribution terms.
Can we advertise a game rated 12+ on channels children use?
You can, but Article 24 then applies because the ad is likely to influence children, whatever the rating. Remove direct purchase invitations, price framing and persuasion cues, and check the creator’s audience data before booking.
Related: B2C · freemium model · age assurance · explicit consent for marketing · gaming law in Türkiye.
Sources. Consumer Protection Law No. 6502 (Articles 61–63, 77); Regulation on Commercial Advertising and Unfair Commercial Practices (Official Gazette 10 January 2015, No. 29232, as last amended by the regulation in Official Gazette 1 July 2026, No. 33297, in force 1 August 2026; Articles 5–7, 9, 13–15, 22, 23/A, 24, 25/A, 28–29, Additional Article 1, Annex); Advertising Board, Guide on Commercial Advertising and Unfair Commercial Practices by Social Media Influencers (Principle Decision No. 2021/2 of 4 May 2021). Statute links open the official Turkish texts on mevzuat.gov.tr.
This article is provided for general information only and does not constitute legal advice. Please seek legal support for an assessment of any specific matter.
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