Türkiye’s insurance supervisor, the Insurance and Private Pension Regulation and Supervision Agency (SEDDK), has issued the Regulation on Embedded Insurance (Bütünleşik Sigortalar Hakkında Yönetmelik, literally “integrated insurance”). It was published in Official Gazette No. 33428 of 12 November 2026 and entered into force the same day. The Regulation governs insurance offered to a buyer in the same physical or electronic environment where goods are sold or rented or services are sold: the model the market calls embedded insurance. A companion amendment in the same issue repealed Article 10 of the 2021 Regulation on Insurance Contracts Concluded at a Distance, the provision that until now allowed device and travel cover at the point of sale. Insurance offered at checkout by e-commerce sites, marketplaces, shops, ticketing, subscription and car rental apps is now governed mainly by one regulation, and the list of covers that may be offered is considerably wider than before. Below we explain what the Regulation says, how it differs from the old regime and what a company that wants to add insurance to its checkout should check.
Last updated: 12 November 2026.
What is embedded insurance and who is covered?
The Regulation defines embedded insurance as insurance containing covers offered to the buyer in the physical or electronic environment where goods are sold or rented or services are sold, limited to risks directly connected with those goods, services or their financing (Art. 4(1)(b)). Three elements matter:
- Environment: physical shops as well as e-commerce sites, mobile apps and other means of distance communication.
- Connection: the cover must be limited to risks directly connected with the goods or service sold or their financing. Screen breakage cover with a phone qualifies; home insurance with a phone does not.
- Buyer: the insurance is offered to the person buying or renting the goods or service.
The Regulation applies to insurers, reinsurers, pension companies providing insurance cover, insurance agencies and brokers, banks and institutions authorised by special law to act as agencies, and persons and organisations providing the commercial environment for embedded insurance (Art. 2). The last group matters: a marketplace, online shop, retail chain, travel or events platform or subscription app is addressed by the Regulation even though it is not an insurer. The Regulation also uses the term “authorised entities”: insurers, pension companies providing insurance cover, intermediaries and banks and institutions with agency powers (Art. 4(1)(n)). Most notification, collection and security duties fall on the authorised entity.
What changed? The old Article 10 compared
Until now, insurance linked to a sale was governed by Article 10 of the Regulation on Activities Considered Insurance and Insurance Contracts Concluded at a Distance of 16 June 2021. Article 9(4) of the same Regulation prohibits offering insurance products for sale on e-commerce environments other than an authorised entity’s own, with an exception only for the Article 10 covers. After the amendment, that exception now refers to insurance offered “within the scope of the Regulation on Embedded Insurance”. Insurance sales on third-party e-commerce environments therefore remain prohibited as a rule, but the exception is wider.
| Topic | Old regime (2021 Regulation, Art. 10) | New regime (Regulation on Embedded Insurance) |
|---|---|---|
| Covers allowed | Electronic device, machinery breakdown and theft cover for devices such as computers, tablets, phones and white goods; travel cover on a passenger carrier’s own website or app | Breakage, loss, theft, fire or malfunction of any goods; pets; non-use, cancellation or interruption of travel, accommodation, events, subscriptions, bill payment, cyber security and shared or short-term motor vehicle rental; residence permit and visa insurance; life, debt-payment and personal accident cover linked to banks’ individual (retail) loans on third-party e-commerce environments (Art. 5) |
| Premium cap | Annual premium of TRY 3,000, uprated by consumer prices | Annual gross premium may not exceed the monthly gross minimum wage in force in the first half of the relevant year; the Board may lower it by up to half or raise it up to double for particular goods or services (Art. 7(1)) |
| Term of cover | Maximum two years, extended warranty cover excepted | Maximum two years; may be extended in line with the warranty for products with extended warranty cover (Art. 7(2)) |
| When it may be offered | With the sale or afterwards, linked to the same device or ticket | During the sale or rental, or within 14 days after the contract is concluded (Art. 8(1)) |
| No tying | No express rule in that article | Insurance may not be made a condition of the sale; buyers who decline may not get a worse price or terms (Art. 8(4)-(5)) |
| Cancellation | No specific rule | A request through any means of distance communication suffices; no harder method than the one used to buy; cover ends automatically if the underlying contract is withdrawn from or rescinded (Art. 10) |
| Fee paid to the seller / platform | “May not be linked to the premium” (Art. 10(7)) | “May not be treated as an insurance intermediation commission” (Art. 11(2)) |
| Notice to SEDDK | One month before launch | One month before launch (Art. 13) |
Which covers may be offered?
Article 5 lists five groups:
- Goods: breakage, loss, theft, fire, malfunction or any other damage to the goods. The old limitation to devices (“such as computers, tablets, mobile phones and white goods”) is gone; bicycles, furniture, glasses or e-scooters can fall within this group.
- Pets: risks connected with illness, theft and loss of a pet, as defined in Animal Protection Law No. 5199.
- Services: risks such as non-use, cancellation, interruption or unauthorised use of travel, transport, accommodation, events, subscriptions, bill payment, cyber security, shared or short-term motor vehicle rental and similar services for reasons not attributable to the service provider, and other travel-related risks. There is an important limit here: the cover addresses risks arising from causes not originating from the service provider, not cancellation or interruption originating from the provider (whether or not it is at fault). In our view, a provider cannot sell its own performance obligation to the customer as insurance.
- Residence permit and visa insurance: insurance that must be submitted with residence permit and visa applications under the Law on Foreigners and International Protection No. 6458.
- Loan-linked cover: life, debt-payment and personal accident insurance linked to individual (retail) loans that banks provide through e-commerce environments they do not own. The text expressly requires compliance with banking legislation, Consumer Protection Law No. 6502 and related rules; in our view, the consumer credit rules on loan-linked insurance (such as the consumer’s explicit request and free choice of insurer) therefore continue to apply. The group covers bank loans only; products offered by non-bank lenders do not benefit from this carve-out.
Which insurance may not be offered?
Article 6 lists insurance that may not be offered as embedded insurance, with carve-outs for the Article 5 groups:
- compulsory insurance under Article 13 of Insurance Law No. 5684 or other laws, and compulsory earthquake insurance;
- home and workplace insurance;
- insurance of land, air, rail and water vehicles (except cover linked to shared or short-term car rental);
- private health and sickness insurance (except residence permit and visa insurance);
- personal accident insurance (except service-linked and loan-linked cover) and life insurance (except loan-linked cover);
- liability insurance (except pet and service-linked cover);
- construction and erection, savings and investment-linked, agricultural, financial loss, marine and transport, and legal protection insurance;
- credit and surety insurance (except loan-linked cover).
In practice, checkout insurance is designed to be low-premium, simple and tied to a single purchase. The boundary can be thin: cover against damage to goods in transit, for example, needs careful product-by-product assessment against the exclusion of marine and transport insurance (Art. 6(1)(j)). Likewise, the insurance branch in which cancellation and non-use covers are written should be checked against the exclusion of financial loss insurance (Art. 6(1)(ı)). Which group a product falls into depends on the insurer’s product design and policy wording, so the product terms should be read together with the Regulation.
Premium cap and term
The annual gross premium may not exceed the monthly gross minimum wage in force during the first six months of the calendar year in which cover starts (Art. 7(1)). The 2026 monthly gross minimum wage is TRY 33,030 (Minimum Wage Determination Commission decision, Official Gazette 26.12.2025, No. 33119). Cover starting in 2026 may therefore carry an annual gross premium of up to TRY 33,030. For cover starting in 2027, the cap will follow the minimum wage in force in the first half of 2027. The Board may lower the cap by up to half or raise it up to double for particular goods or services, so SEDDK announcements need to be followed.
In our view, the new cap, higher than the old TRY 3,000 cap uprated each year by consumer prices, leaves room for broader cover on expensive items such as phones and laptops. Cover may last at most two years; for products with extended warranty cover the term may be extended in line with the warranty (Art. 7(2)).
Rules at the point of sale
Timing. The insurance may be offered during the sale or rental, or within 14 days after the contract is concluded (Art. 8(1)). In our view, this may allow post-purchase offers, provided they remain connected with the environment where the sale took place; offers after the 14 days fall outside embedded insurance.
The insurer must be clear. No conduct may suggest that the cover is provided by anyone other than the insurer, and the underlying contract may contain no such wording (Art. 8(2)). Branding such as “our store’s protection plan” is risky unless the insurer is clearly shown.
Mandatory information. In a physical shop, by visuals placed where they are easily seen; online, through a link (Art. 8(3)): the insurer’s and any intermediary’s name and contact details and the premium; the subject and scope of the cover and the fact that the insurer pays claims under insurance law; and where more information can be found. The Regulation on Information in Insurance Contracts also applies, and the duty to issue a policy continues; the policy may be delivered on a durable medium such as email, SMS or e-Government (Art. 9(1)-(2)).
Identity check and consent. Before the contract is concluded, the insurer informs the policyholder about the commercial environment in which the transaction takes place and obtains consent by a secure method that verifies identity and records or captures the declaration (Art. 9(3)). In our view, pre-ticked boxes or insurance added to the basket automatically do not fit this structure.
No tying, no price difference. Buying the insurance may not be made a condition of buying or renting the goods or service (Art. 8(4)). A buyer who declines may not be charged a higher price or offered worse terms (Art. 8(5)). In our view this also makes “discount if you add insurance” offers problematic: the discount effectively means a higher price for buyers who decline.
Ending the contract
The policyholder may send a termination request to the commercial environment provider or the authorised entity through any means of distance communication (Art. 10(1)). The commercial environment provider must put systems in place so that the request can also be sent by the method used to conclude the contract (Art. 10(2)). The policyholder may not be required to use a method with heavier conditions than the one used to conclude the contract (Art. 10(3)). Requiring a call-centre call or a wet-ink letter to cancel cover added with one click would not fit this rule.
If a right of withdrawal, termination, cancellation or rescission is exercised under the contract for the goods or service, the insurance ends automatically, without any compensation or contractual penalty (Art. 10(4)). In our view, passing returns and withdrawals automatically to the insurer is therefore necessary in practice.
Premium collection, the platform’s fee and security
The premium may be collected together with the price, in which case it is shown separately on the payment document; if paid separately, a premium receipt is issued. Payment of the premium is in all cases deemed made to the insurer (Art. 11(1)). Authorised entities must design premium collection in line with the Bank Cards and Credit Cards Law No. 5464 and Law No. 6493 on payment services, and are responsible for the security of the information systems and integrations used, for transaction records and for regulatory compliance (Art. 12). How a platform passes collected premiums on to the insurer should be checked separately under payment services law; we discussed this in our article on marketplace collections and the commercial agent exclusion.
The service fee that authorised entities pay to the commercial environment provider “may not be treated as an insurance intermediation commission” (Art. 11(2)). The old text said expressly that the fee “may not be linked to the premium”; the new text uses different words. It is not clear from the text whether the rule means the platform’s fee may not be structured as an intermediation commission, or whether it characterises such a fee as not being one. In our view, until SEDDK issues guidance under Article 14, a flat or service-based fee is safer than a fee calculated as a percentage of premium per policy sold. The rule that a business without agency status may not intermediate insurance (Law No. 5684 Arts. 23 and 35) is unchanged.
Notification and existing programmes
Authorised entities inform SEDDK one month before launch; SEDDK may request changes where it considers necessary, without prejudice to administrative sanctions (Art. 13). SEDDK may also set implementing rules and issue secondary regulation (Art. 14).
The Regulation contains no transitional provision, and the old Article 10 was repealed on the same day. Device and travel insurance programmes run under the old regime are subject to the new Regulation from 12 November 2026. Whether existing programmes need a fresh notification is not addressed. In our view, existing programmes should be reviewed now against the new rules (especially the termination method, the tying ban, identity verification and automatic termination), and the one-month notice period should be built into any new programme or any change of scope, product or channel.
The rest of the 2021 Regulation remains in force; the amendment also rewrote its purpose and scope articles, removing commercial environment providers from its scope, and retitled its third section “Insurance Contracts Concluded at a Distance”. In particular, under Article 9(5), at the workplaces of persons who are not authorised entities, people who are not technical personnel may not intermediate the conclusion of insurance contracts through a means of distance communication. A shop assistant completing an insurance purchase for a customer on a tablet should be assessed against that rule.
What it means for different businesses
- Marketplaces and online shops: breakage, theft and malfunction cover linked to the product sold may be offered to buyers in their environment by an authorised entity, in the basket or after the order; the product range is no longer limited to electronic devices. With several sellers on one marketplace, the cover must still be directly connected with the goods sold.
- Travel, ticketing and events platforms: under the old regime, travel insurance linked to a ticket sale could be offered only on the passenger carrier’s own website or app. The new text has no such limit; cancellation and interruption cover may be offered by an authorised entity in the environment of travel agencies, accommodation and events platforms as well.
- Subscription apps and SaaS: subscriptions, bill payment and cyber security are listed expressly. Cover for non-use of a subscription service or unauthorised use of an account is possible.
- Car sharing and short-term rental: motor vehicle insurance is excluded in general, but cover linked to shared and short-term rental is carved out. Both terms are defined by reference to the Regulation on the Rental of Motor Land Vehicles of 15 August 2026.
- Pet platforms: illness, loss and theft of pets are listed expressly. The definition of embedded insurance still requires a direct connection with the goods or service sold, so which sales can carry this cover should be assessed product by product.
- Shopping loans: only life, debt-payment and personal accident cover linked to banks’ individual loans on e-commerce environments they do not own may be offered; non-bank BNPL products fall outside the carve-out. The relevant consumer credit and banking rules continue to apply. For the legal nature of BNPL products see our BNPL article.
- Insurtech agencies: platform integrations can now carry a wider product range, while notification, security and record-keeping duties sit with the authorised entity. For licensing models, see our articles on embedded insurance and insurtech and BaaS and embedded finance.
Checklist
- Place the cover you want to offer in one of the Article 5 groups and compare it with the Article 6 exclusions.
- Confirm the cover is directly connected with the goods, service or financing sold and, for service covers, does not cover causes originating from the provider.
- Check that the annual gross premium stays under the minimum wage cap and the term does not exceed two years.
- Review the sales flow: no pre-ticked boxes, no price difference for buyers who decline, the 14-day offer window tracked.
- Make sure the product page and checkout give the Article 8(3) information through a link and do not suggest that the platform provides the cover.
- Agree with the insurer how identity verification and consent records will be handled.
- Make cancellation as easy as the purchase channel; pass returns and withdrawals to the insurer automatically.
- Show the premium separately on the payment document; check the premium flow against payment services law.
- In the contract between the platform and the authorised entity, cover the fee structure, data sharing (KVKK), information security and audit access.
- Obtain written confirmation that the authorised entity notified SEDDK one month in advance.
Frequently asked questions
Can marketplaces now sell insurance in Türkiye?
A marketplace cannot itself sell insurance; the ban on intermediation without insurer or agency status continues. But covers within the Regulation on Embedded Insurance may be offered to buyers through a marketplace together with an authorised entity. Offering other insurance products for sale on third-party e-commerce environments remains prohibited; authorised entities may only advertise there.
Can I make the insurance mandatory with the product?
No. Buying the insurance may not be made a condition of buying or renting the goods or service, and buyers who decline may not be charged a different price or offered worse terms.
What is the premium cap?
The annual gross premium may not exceed the monthly gross minimum wage in force in the first half of the relevant year. For cover starting in 2026 this is TRY 33,030. The Board may lower the cap by up to half or raise it up to double for particular goods or services.
What happens to my device insurance programme under the old Regulation?
The old Article 10 was repealed on 12 November 2026 with no transitional provision. The programme must comply with the new Regulation from that date. The text does not say whether a fresh notification is needed; in our view a new notification should be made for any change of scope, product or channel, and the existing flow should be reviewed at once against the termination, tying and consent rules.
Sources. Regulation on Embedded Insurance (Official Gazette 12.11.2026, No. 33428); Regulation amending the Regulation on Activities Considered Insurance and Insurance Contracts Concluded at a Distance (Official Gazette 12.11.2026, No. 33428); Regulation on Activities Considered Insurance and Insurance Contracts Concluded at a Distance (Official Gazette 16.6.2021, No. 31513); Insurance Law No. 5684, Arts. 23 and 35; Minimum Wage Determination Commission decision (Official Gazette 26.12.2025, No. 33119). All texts in Turkish.
This article is general information and not legal advice; please seek advice on your specific situation.
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