A phone sold with “accidental damage cover”, a travel policy ticked at the end of a flight booking, a loan app that bundles life cover: embedded insurance is the most familiar form of embedded finance, and in Türkiye one of the most tightly drawn. Insurance Law No. 5684 reserves risk-taking to licensed insurers and intermediation to registered agencies and licensed brokers, and a 2021 regulation of the Insurance and Private Pension Regulation and Supervision Agency (SEDDK) closes most third-party e-commerce checkouts to insurance sales. Below: who may sell at a checkout or in an app, which models work and what an insurtech needs, as of November 2026.
Insurers carry risk, agencies and brokers intermediate
An insurance agency is a person who, under a contract and on a permanent basis, intermediates or concludes insurance contracts in the name and on behalf of insurers (Law No. 5684 Art. 2(1)(m)). A broker instead represents the customer and must choose the insurer “completely impartially and independently” (Art. 2(1)(d)); brokerage needs a licence (Art. 21(2)).
An agency needs a certificate of suitability from the supervisor and entry in the register (Levha) kept by the Union of Chambers and Commodity Exchanges of Türkiye (TOBB) (Art. 23(1)-(2)). No one else may carry on agency activity or use words suggesting it (Art. 23(13)). Banks and institutions given agency powers by special law are exempt from the certificate and register (Art. 23(3)) but notify TOBB of the insurers they work for (Agencies Regulation Art. 13(1)).
Sanctions are criminal: three to five years’ imprisonment for assuming insurance risk without a licence (Art. 35(1)); one to three years for agency activity without a certificate or brokerage without a licence (Art. 35(23)); judicial fines for unregistered agency activity or creating the impression of it (Art. 35(20), (24)).
SEDDK was created by Presidential Decree No. 47 (Official Gazette (RG) 18.10.2019/30922). References in Law No. 5684 to the “Undersecretariat” now mean SEDDK, which exercises the Law’s insurance powers (Decree Arts. 4(1)(a), 19).
Checkout sales: the 2021 SEDDK Regulation
The Regulation on Activities Considered Insurance and Insurance Contracts Concluded at a Distance (RG 16.6.2021/31513) is the core text:
- No insurance on third-party marketplaces. On e-commerce environments selling goods and services, other than an authorised entity’s own, insurers’ products may not be offered for sale, except those in Article 10; authorised entities may advertise there (Art. 9(4)). “Authorised entities” include insurers, agencies, brokers and banks acting as agencies (Art. 4(1)(k)). SEDDK Circular 2021/14 repeats this (Art. 2(2)).
- Device cover. With the sale of computers, tablets, phones, white goods and similar devices, electronic device, machinery breakdown and theft insurance may be offered if it complements the device, the annual premium does not exceed TRY 3,000 uprated each year by consumer prices, and cover lasts at most two years, extended warranty cover excepted (Art. 10(1)).
- Travel cover. Passenger carriers may offer travel-risk insurance with a ticket on their own website or app (Art. 10(2)).
- Conditions. The seller may not suggest it gives the cover and must show the insurer, the scope, that the insurer pays claims, and where to find more (Art. 10(3)-(4)). The premium may be collected with the price but is shown separately and counts as paid to the insurer (Art. 10(6)). The seller’s service fee “cannot be linked to the premium” (Art. 10(7)). The authorised entity informs SEDDK one month before launch (Art. 10(9)).
- No assisted sales by non-specialists. At workplaces of non-authorised persons, staff who are not technical personnel may not help conclude insurance remotely; this is unauthorised intermediation under Article 35 (Art. 9(5)).
- “Protection plans” can be insurance. A paid voluntary guarantee is not insurance, but repair, replacement or refund for insurable risks outside the guarantee certificate is (Art. 6(2)), and by a non-insurer it is unlicensed insurance (Art. 7(2)-(3)).
- Cover bought for customers. A business insuring consumers in connection with its contract with them may not take a fee or commission from the insurer, and “gifted” cover may not be charged to the consumer under any name (Art. 8(3)-(4)).
Four models compared
| Model | What the platform does | Legal position | Main constraint |
|---|---|---|---|
| Registered agency | Sells policies in its app through technical personnel | Agency (Law No. 5684 Art. 23) | Agencies may not carry on other commercial activity (Art. 23(10)), so in practice a marketplace needs a separate agency company |
| Point-of-sale cover | Offers Article 10 device or travel cover with its own goods or tickets | Seller under the 2021 Regulation, backed by an authorised entity | Product list, premium cap, disclosure, no premium-linked fee, notice to SEDDK |
| Referral or advertising | Shows an ad; the customer buys on the insurer’s or agency’s own site or app | Advertising expressly allowed (Art. 9(4)) | No proposing, informing or selling; no agency-like wording |
| Technology or white-label provider | Builds the insurer’s or agency’s app, API or call centre | Possible support service provider | May not also act as an intermediary (Support Services Regulation Art. 6(3), as amended in July 2026) |
Referral fees. We found no specific referral fee regime. Our reading: a premium-linked fee paid to a business without agency status looks like remuneration for intermediation (Article 10(7) bans it even for point-of-sale sellers); a flat advertising fee carries less risk.
MGA-like structures. Turkish law has no managing general agent category. An insurer may delegate authority to conclude contracts and collect premiums to an agency (Agencies Regulation Art. 17(1)), but that authority cannot be passed on (Art. 14(1)), and an insurer may not transfer its obligation to carry risk and pay claims (2021 Regulation Art. 5(3)). Product and tariff design can be outsourced as a support service, but core insurance activities cannot (Support Services Regulation Arts. 4(1)(j), 4(3)). Since 23 July 2026, end-to-end claims handling and 24/7 assistance providers to insurers need SEDDK permission and TRY 250 million equity (Art. 8/A), phased in by 2030 for existing providers (Provisional Art. 2).
What an insurtech agency needs
Under the Regulation on Insurance Agencies (RG 22.4.2014/28980, last amended RG 22.1.2025/32790):
- a joint-stock or limited company headquartered in Türkiye, with adequate premises, infrastructure and staff (Art. 5(1));
- paid-in capital of at least TRY 3,250,000, or TRY 4,000,000 for distance-only sales without branches, and for agencies with branches or distance sales equity of at least 4% of premiums intermediated, never below TRY 4,000,000; amounts (set January 2025) are uprated each January by producer prices unless SEDDK decides otherwise; check current figures (Art. 9, Additional Art. 1);
- a SEDDK certificate of suitability via TOBB-designated chambers, then registration within six months (Art. 10);
- marketing, informing and selling only by technical personnel who passed the Insurance Education Centre (SEGEM) exam (Art. 6(1)-(2));
- “insurance agency” or “insurance intermediation” in the trade name, and “insurance” online only with one of those words (Arts. 12, 19);
- a registered special power of attorney from each insurer (Art. 14(1)).
Loans and insurance: the tying rules
No credit-linked insurance may be taken out without the consumer’s explicit request in writing or on a durable medium; a lender offering credit with insurance must also offer it without; and the lender must accept cover from the insurer the consumer chooses (Law No. 6502 Art. 29(1)-(2); Art. 38 for mortgages). The Regulation on Insurance Linked to Personal Loans (RG 13.3.2015/29294, amended RG 29.12.2021/31704) voids any clause requiring a specific insurer (Art. 13(1)) and, if the borrower presents a suitable alternative policy within one month, cancels the original from its start with a full refund within five business days (Art. 11(1)). The right to choose the insurer cannot be restricted (Law No. 5684 Art. 32(5)). In Sector Notice 2025/2 (5 March 2025) SEDDK reported complaints that lenders required specific insurers or intermediaries and warned of sanctions under Articles 32, 34 and 35.
Disclosure, consumer and data rules
The Regulation on Information in Insurance Contracts (RG 14.2.2020/31039) binds agencies as well as insurers (Art. 6) and applies to distance contracts (2021 Regulation Art. 9(2)): a pre-contract information text names the insurer and agency and sets out cover, exclusions and claims rules (Art. 8(1)); where parties do not meet, it may be given on a durable medium (Art. 5(2)).
A seller may not make a sale conditional on buying another good or service, absent custom or just cause (Law No. 6502 Art. 6(3)). For distance financial services the consumer has 14 days to withdraw, with more favourable insurance rules prevailing, but travel, baggage and similar policies valid for under one month carry no withdrawal right (Regulation on Distance Contracts for Financial Services, RG 31.1.2015/29253, Arts. 8(1), 13(1)(b)).
Health data is special category data under KVKK (Law No. 6698 Art. 6(1)) and, since the 2024 amendment, may be processed only on a listed condition such as explicit consent or express provision in law, with the Board’s adequate measures (Art. 6(3)-(4)). Agencies and their staff must also keep what they learn confidential (Law No. 5684 Art. 23(17)).
The EU contrast
The Insurance Distribution Directive (Directive (EU) 2016/97) lets a non-insurance business distribute complementary cover as an “ancillary insurance intermediary” (Art. 2(1)(4)), and exempts it from the Directive where the cover protects its goods or services against breakdown, loss or damage, or covers travel-linked risks, and the premium does not exceed EUR 600 a year, or EUR 200 per person for services of up to three months (Art. 1(3)). Türkiye has no comparable general carve-out: outside Article 10, a platform must be, or sell through, an authorised entity’s own channel.
Where to start
- Classify each product: insurance, or a voluntary guarantee or service?
- Check Article 10; if it does not apply, the sale must happen on an authorised entity’s own website or app.
- Pick one capacity per entity: agency (in a separate company), point-of-sale seller, advertiser or technology provider.
- Remove premium-linked fees for anyone who is not an agency.
- Draft disclosures, the withdrawal flow and the SEDDK notice.
Payments and credit: see our BaaS and embedded finance article and fintech law hub.
Can a Turkish marketplace sell third-party insurance at checkout?
Generally no. Outside the device and travel cover in Article 10 of the 2021 SEDDK Regulation, it may only carry insurers’ or agencies’ advertisements (Art. 9(4)).
Can an e-commerce company register itself as an insurance agency?
In practice it needs a separate company, because agencies other than banks and special-law institutions may not carry on other commercial activity (Law No. 5684 Art. 23(10)).
Is a paid extended warranty insurance?
A voluntary guarantee is not, even if paid for, but repair, replacement or refund for insurable risks outside the guarantee certificate is insurance reserved to insurers (2021 Regulation Arts. 6(2), 7).
Sources. Insurance Law No. 5684 (RG 14.6.2007/26552), Arts. 2, 21, 23, 32, 34, 35; Presidential Decree No. 47 (RG 18.10.2019/30922), Arts. 4, 19; Regulation on Activities Considered Insurance and Insurance Contracts Concluded at a Distance (RG 16.6.2021/31513), Arts. 4-10; SEDDK Circular 2021/14 and Sector Notice 2025/2; Regulation on Insurance Agencies (RG 22.4.2014/28980, consolidated), Arts. 5, 6, 9, 10, 12-14, 17, 19; Regulation on Insurance Support Services (RG 28.8.2015/29459, amended RG 23.7.2026/33318), Arts. 4, 6, 8/A, Provisional Art. 2; Regulation on Insurance Linked to Personal Loans (RG 13.3.2015/29294) and its 2021 amendment, Arts. 11, 13; Regulation on Information in Insurance Contracts (RG 14.2.2020/31039), Arts. 5, 6, 8; Law No. 6502 (RG 28.11.2013/28835), Arts. 6, 29, 38; Regulation on Distance Contracts for Financial Services (RG 31.1.2015/29253, amended RG 31.12.2024/32769), Arts. 8, 13; Law No. 6698 (KVKK) (RG 7.4.2016/29677), Art. 6; Directive (EU) 2016/97 (IDD), Arts. 1(3), 2(1)(4).
This article is general information and not legal advice; a specific situation should be assessed with counsel.
