The gaming platform obligations added to Law No. 5651 take effect on 1 November 2026. Any platform that runs the infrastructure on which games are displayed, sold, downloaded or played, and provides users’ access to games or interaction between users, faces age rating, parental control and information request duties. Foreign-based platforms with more than 100,000 daily accesses from Türkiye must also appoint a representative in Türkiye. Vircon Legal handles compliance end to end, from the scope analysis to the representative notification and platform agreements.
Request a quote → Full guide to the new regime
Which obligations apply to you?
Tick the options that describe your service; the check shows which obligations reach you from 1 November 2026.
| Obligation | Who is bound | Substance |
|---|---|---|
| Age rating | Gaming platforms | Unrated games cannot be offered; the platform removes them or offers them classified at the highest age category |
| Parental controls | Gaming platforms | Parental controls over account settings, with parental approval available for purchases, rentals and paid memberships |
| Information requests | Gaming platforms | Cybersecurity Presidency requests on corporate structure, IT systems and data processing answered within the period it sets, capped at 15 days |
| Türkiye representative | Foreign-based platforms with more than 100,000 daily accesses from Türkiye | A representative is appointed, notified to the Presidency and published on the platform’s site |
The cost of non-compliance
The Cybersecurity Presidency first serves a notice. If compliance does not follow within 30 days, an administrative fine of TRY 1 to 10 million applies, and TRY 10 to 30 million if the breach continues. The Presidency can then ask a criminal judgeship of peace to throttle bandwidth by 30 percent, then by up to 50 percent. If the obligation is fulfilled later, only a quarter of the fines is collected and throttling orders lapse automatically. Finishing the work before 1 November is still the cheapest route, for fines and for visibility alike.
What Vircon Legal handles
- Scope analysis: whether your service falls within the gaming platform definition (Law No. 5651, Art. 2(1)(ü)); studios that run their own store, launcher or multiplayer infrastructure are assessed separately. For the representative duty, how daily access from Türkiye will be recorded.
- Türkiye representative: choice of representative structure, authority documents, notification to the Cybersecurity Presidency and the disclosure text to publish on the site.
- Age rating inventory: identifying unrated games in the catalogue and deciding whether to remove them or offer them at the highest age category.
- Parental controls: designing the account settings and paid transaction approval flow to the legal requirements, and updating the user terms and privacy notice (KVKK, Art. 10) accordingly.
- Information request procedure: an internal process and named owners able to answer Presidency requests within 15 days.
- Social network rules: where the service offers in-game chat, community or streaming features, an assessment against the social network obligations entering into force on the same date (Law No. 5651, Additional Art. 4).
- Agreements for studios and publishers: reviewing the rating, takedown and information sharing clauses of platform agreements against this regime.
- Enforcement: representation through the Presidency notice, administrative fine and throttling stages.
Information and documents we will ask for
- A description of the service: store, launcher, multiplayer infrastructure, chat and community features
- Daily access figures from Türkiye and how they are measured
- Age rating status of the games in the catalogue
- Corporate structure and any presence in Türkiye (company, branch, partner)
- Current user terms, privacy and data protection notices
- Platform or publishing agreements (for studios and publishers)
Process and timeline
- Week 1: scope analysis, assessment of the access threshold and an obligations map.
- Week 2: representative structure and notification preparation (where required); the rating inventory begins.
- Weeks 3-4: parental control flow, updates to user terms and privacy notice, information request procedure.
- After: adjustment to the rating method and measurement rules once the Presidency’s regulation is published.
Why Vircon Legal?
Vircon Legal regularly advises gaming and esports companies from incorporation through investment rounds: Tiplay, Hungri Games, No Surrender Games and Gameness are among those matters. We have followed the Law No. 5651 regime since its adoption; our guide has been updated for the transfer of powers under Law No. 7590. For the wider practice, see our gaming and esports law page.
Frequently asked questions
We publish our game on Steam. Are we caught?
A studio shipping its own game on Steam or a similar storefront is not the direct addressee of the representative or parental control duties. Because platforms must remove unrated games or place them in the highest age category, ratings become a visibility issue, and platform agreements will pass these obligations down the chain. If you run your own store, launcher or infrastructure for interaction between players, whether you fall within the platform definition should be assessed separately.
How will the 100,000 daily access threshold be measured?
The statute speaks of daily access and leaves the measurement method to the Cybersecurity Presidency’s regulation. Platforms near the threshold should keep records of their daily access figures from Türkiye in their own systems.
Is it too early to prepare before the regulation is out?
No. The framework of the obligations is in the statute and takes effect on 1 November 2026; the regulation will set the rating method and the detail of the obligations. As of October 2026, when this page was prepared, the regulation had not been published. The representative, parental controls and information request process can be put in place without waiting for it.
What happens if we comply late?
If compliance does not follow within 30 days of the notice, administrative fines and then bandwidth throttling follow. If the obligation is fulfilled later, a quarter of the fines is collected and throttling orders lapse automatically; the process is still costly for user experience and reputation.
Request a quote
Tell us about your platform or studio, your approximate daily access from Türkiye and your priority questions. The quote, with scope and timeline, will be sent by email.
Sources. Law No. 5651, Art. 2(1)(ü), Additional Arts. 4 and 5; Law No. 7578, Arts. 21-23 and 27 (Official Gazette 1 May 2026, No. 33240); Law No. 7590, Art. 27 (Official Gazette 31 July 2026, No. 33326); Law No. 6698, Art. 10.
This page is general information and not legal advice. A specific situation should be assessed with legal counsel.