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Türkiye Writes Gaming into Law No. 5651: A Guide to the New Platform Regime

Türkiye Writes Gaming into Law No. 5651: A Guide to the New Platform Regime

Türkiye has written digital gaming into statute for the first time. Law No. 7578, published in the Official Gazette on 1 May 2026, adds a games-specific layer to Law No. 5651, the internet law: definitions, platform obligations and a tiered sanctions regime. The gaming provisions entered into force six months after publication, on 1 November 2026 (Law No. 7578, Art. 27(1)(a)); the six-month transition period gave studios, publishers and platforms time to prepare.

Update (1 October 2026): Law No. 7590, published in the Official Gazette on 31 July 2026 (Art. 27(5)), replaced “Authority” with “Presidency” in the gaming and social network provisions of Law No. 7578. The gaming platform regime, which applies from 1 November 2026, is therefore supervised not by the BTK but by the Cybersecurity Presidency. This guide has been updated accordingly.

Who does the law now recognise?

The amendment starts by settling the vocabulary. Four definitions enter the law: game for digital games distributed or updated over the internet; game developer for those who design and build the game or its content; game distributor for those coordinating sales channels, licence keys and digital rights management; and game platform for those providing the infrastructure on which games are displayed, sold, distributed, downloaded or played, and providing or coordinating users’ access to games, licence management or interaction between users (Art. 2(1)(ü)). The distinction matters because the weight of the new obligations falls on platforms; developers and distributors remain at the definition level for now, though the Cybersecurity Presidency’s regulation to come is expected to sharpen the roles.

The platform checklist

Obligation Substance
Age rating Unrated games cannot be offered; the platform removes them or classifies them at the highest age category
Türkiye representative Foreign platforms with daily access from Türkiye above 100,000 must appoint a representative, notify the Cybersecurity Presidency and publish the details on their site
Parental controls Clear parental controls over account settings, with parental approval available for purchases, rentals and paid memberships
Information requests Cybersecurity Presidency requests on corporate structure, IT systems and data processing answered within the period it sets, capped at 15 days

The sanctions ladder

The regime is deliberately stepped. The Cybersecurity Presidency first serves a notice; if compliance does not follow within 30 days, a fine of TRY 1 to 10 million applies, and a second fine of TRY 10 to 30 million if the breach continues. After that, the authority can ask a criminal judgeship of peace to throttle bandwidth by 30 percent, then by up to 50 percent. The clever part is the incentive to comply late: once the obligation is fulfilled, only a quarter of the fines is collected and throttling orders lapse automatically. The arithmetic is plain enough; resisting is expensive, turning back is cheap.

What comes next

What will shape the calendar is the regulation setting the rating methodology and the detail of platform obligations. After Law No. 7590, the power to issue it sits with the Cybersecurity Presidency, which now also handles supervision, fines and throttling applications under Law No. 5651. The transfer, described in the first version of this guide as a pending bill, was adopted on 24 July 2026 and took effect on 31 July, so the counterpart for gaming platforms is the Presidency from the outset rather than the BTK. For the sector’s wider legal map, see our gaming law guide.

Are Turkish studios caught by these rules?

The weight rests on platforms; a studio shipping its game on Steam or a similar storefront is not the direct addressee of the representative or parental control duties. A studio that runs its own store, launcher or infrastructure for interaction between players should, however, assess whether it falls within the game platform definition; the representative duty applies only to foreign-based platforms with more than 100,000 daily accesses from Türkiye. Two indirect effects still land: since platforms must remove or top-rate unrated games, ratings become a visibility issue, and platform agreements will inevitably grow new clauses passing these obligations down the chain.

How will the 100,000 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 in their own systems.

Social network rules on the same date

The social network obligations added to Additional Article 4 of Law No. 5651 by Article 22 of Law No. 7578 were drafted to enter into force on the same date. A social network provider may not serve children under fifteen and must take the necessary measures, including age verification; it must offer a separate service for children aged fifteen and over. It must also provide parental control tools covering account settings, parental approval for paid transactions and monitoring and limiting usage time, and take measures to block deceptive advertising. Social network providers with more than ten million daily accesses from Türkiye must implement decisions issued in urgent cases within one hour at the latest. Services offering in-game chat, community or streaming features should also be assessed against these rules.

Where to start

For platforms, four workstreams stand out: an inventory of unrated games in the catalogue, a shortlist for the representative role, the design of the parental control flow, and an internal process able to answer the Presidency’s requests within 15 days. If you are a studio or publisher, your work is in the contracts: read the rating, takedown and information-sharing clauses of your platform agreements against this regime.

The game platform regime took effect on 1 November 2026. Are you compliant?Vircon Legal handles the scope analysis, Türkiye representative, age rating inventory, parental controls and the 15-day information request process. Check which obligations apply to you and request a quote.

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Sources. Law No. 7578, Arts. 21-23 and 27 (Official Gazette 1 May 2026, No. 33240; Law 5651 Additional Art. 5, in force 1 November 2026); Law No. 7590, Art. 27 (Official Gazette 31 July 2026, No. 33326); Law No. 5651 (official Turkish text).

Author

  • Erdem Mümtaz Hacıpaşaoğlu

    Mümtaz is the Managing Partner of Vircon Legal, which he founded in 2016. He advises founders, investors and operators on financing rounds, M&A, cross-border incorporations and regulated verticals such as crypto-asset infrastructure, fintech and games, bringing a former startup founder's perspective to every engagement. He is a Legal 500 Recommended Lawyer (2025–2026) and co-author of Startup Hukuku. Canonical profile: https://mumtazhacipasaoglu.com · Open-access legal guides: https://github.com/mumtazhpo

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Published: 4 August 2026 · last updated: 2 November 2026
This article is for general informational purposes only and does not constitute legal advice. Laws and practices may have changed since the publication date. For specific situations, please consult Vircon Legal.
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