Türkiye’s amends Internet Law with new framework for digital game platforms and enhanced obligations for social network providers

Türkiye’s passage of the Law on Amendments to the Social Services Law and Certain Other Laws (published in the Official Gazette on 1 May 2026 and numbered 33240) has introduced significant changes to the Law No. 5651 on the Regulation of Broadcasts via the Internet and the Prevention of Crimes Committed through Such Broadcasts (i.e. the Internet Law). 

The rationale behind the Amendments is the increasing risks that children are exposed to in the digital environment, which includes harmful content, cyberbullying, digital addiction and imprudent or uninformed spending. Against this background, the existing regulatory framework is not considered to be sufficiently preventive and proactive.

The Amendments are intended to strengthen child protection online, reduce risks and equip families with better tools to supervise and manage the internet use of children. The Amendments introduce enhanced obligations for digital service providers operating in the gaming and social media sectors, while strengthening the overall enforcement framework to ensure a safer, more transparent and more accountable digital ecosystem for children.

The Amendments establish two distinct sets of obligations targeting different categories of digital service providers:

• First, for the first time under the Internet Law, game platforms are expressly defined and brought within the scope of the regulatory framework, making such platforms subject to specific compliance obligations, including the appointment of a local representative in Türkiye. 
• Second, the Amendments expand the existing obligations applicable to social network providers by introducing additional duties and restrictions to strengthen the protection of children and young users in digital environments. 

The Amendments both create a new compliance regime for online game platforms and reinforce the existing regulatory framework for social network providers.

I. A new regulatory phase for the gaming ecosystem

With the Amendments, the legal framework for the gaming sector has defined the relevant actors and introduced new obligations and provisions applicable to them.

1. Key definitions introduced for the digital gaming ecosystem

The Amendments clarify key concepts relating to the digital gaming ecosystem and define the terms "game”, “game developer”, “game distributor” and “game platform”. Specifically, the Amendments introduce the following definitions:

• “Game” refers to digital games that are distributed, played or updated via the internet and played online or offline in an electronic environment.
• “Game distributor” refers to natural or legal persons that coordinate relationships with sales channels for the purpose of delivering digital games produced or published by a content provider to the end user; coordinates the generation and management of licence keys; utilises digital rights management systems; and provides financial or technical intermediary services in this process.
• “Game developer” refers to natural or legal persons that design digital games or game content, develop this software or manage the development process.
• “Game platform” refers to natural or legal persons that provide the software or technical infrastructure for the display, sale, distribution, downloading or playing of digital games and related additional content via the internet. It also refers to natural or legal persons that facilitate or coordinate user access to games or content, licence management or interaction between users. 

2. Obligations of game platforms

The Amendments do not impose specific obligations on game developers or distributors. Instead, the regulatory framework primarily targets “game platforms” as defined under the law. A series of obligations are introduced for game platforms, notably including age rating requirements, the deployment of parental control mechanisms, and local representative obligations, with the overall goal of creating a safer and more accountable digital ecosystem for children.

2.1. Age restrictions

Game platforms will be required to ensure that games are properly age-rated before being made available to users. Unrated games may only be offered under the highest age classification, and platforms must remove content that does not comply with applicable age-rating requirements. Further details on the age rating framework will be set out in secondary legislation to be issued by the Information and Communication Technologies Authority (ICTA).

2.2. Parental control tools 

The Amendments enable parents to exercise effective control over their children’s digital activities. Game platforms are required to offer clear, understandable and user-friendly parental control tools. Parental control tools must include mechanisms to control account settings, and, make payment-based transactions on parents’ permission or approval.

2.3. Local representative appointment

Under the Amendments, foreign-based game platforms with more than 100,000 daily accesses from Türkiye must appoint a local representative in Türkiye. The representative will be responsible for handling communications and compliance matters before the ICTA, judicial and administrative authorities and the Access Providers Association under the Internet Law. Platforms must also notify the ICTA of the representative’s details and ensure that this information is clearly accessible on their website.

2.4. Response to regulatory requests 

With the Amendments, the ICTA is authorised to request from game platforms any information and documentation necessary to assess compliance with the Internet Law, including information regarding their corporate structure, information systems and data processing mechanisms. Game platforms are required to provide the requested information and documents immediately and within a period to be determined by the ICTA, which may not exceed 15 days.

3. Regulatory oversight and sanctions

The Amendments introduce a new compliance and enforcement framework for online game platforms, together with administrative sanctions for non-compliance. Administrative fines may range from TRY 1 million to TRY 10 million (approximately EUR 18,825 to EUR 188,260) with additional fines of up to TRY 30 million (EUR 564,800) for continued breaches. Persistent non-compliance may also lead to bandwidth restrictions of up to 50%, and, if it continues, up to 90% following additional regulatory intervention.

The framework further provides for a graduated enforcement mechanism. If obligations are not met following the imposition of fines, resident taxpayers in Türkiye may be prohibited from placing new advertisements on the relevant platform. Continued non-compliance may ultimately result in broader bandwidth restrictions imposed by court order. Compliance with the relevant obligations removes the applicable restrictions and reduces the administrative fine.

Alongside the new regime applicable to game platforms, the Amendments further expand the obligations imposed on social network providers under the Internet Law.

II. New obligations for social network providers under the Internet Law

The Amendments introduce a distinct set of enhanced obligations for social network providers under the Internet Law with a particular focus on child protection, content governance and platform accountability in digital environments.

1. Age restrictions and segregated services

With the Amendments, social network providers are expressly prohibited from offering services to children under the age of 15. Providers are required to implement age verification systems and adopt all necessary technical and administrative measures to ensure effective enforcement of this restriction.

For users aged between 15 and 18 years, social network providers must provide a segregated, child-specific service that is clearly distinguished from services offered to adult users. Providers also must publish the measures implemented to ensure the provision of segregated services to minors.

2. Parental control and advertising requirements

Social network providers are required to implement effective parental control tools designed to enable parents to monitor and manage children’s online activities. These tools must allow control over account settings, approval of payment-based transactions (including purchases, rentals, and subscriptions), and monitoring and limitations on screen time.

In addition, social network providers are required to adopt measures to prevent misleading advertising on their platforms.

3. Response obligations to user applications and content removal

Under the Internet Law’s existing framework, social network providers with more than one million daily access counts from Türkiye are required to respond within 48 hours to user applications relating to content falling within the scope of Articles 9 and 9/A.

With the Amendments, this obligation covers all applications submitted under the Internet Law by users of such platforms.

In relation to content removal, social network providers with more than ten million daily access counts from Türkiye must comply with content removal or access blocking decisions issued under Article 8/A immediately and within one hour of notification. In addition, providers must take all necessary measures to prevent the re-publication of content subject to such decisions.

4. Response to regulatory requests

The Amendments reduce the timeframe for responding to information and document requests issued by the ICTA. Social network providers must provide the requested information within a period determined by the ICTA, which may not exceed 15 days.

5. Enforcement and sanctions

Non-compliance with key obligations under the Internet Law, including those relating to child protection, advertising practices and content re-publication can result in administrative fines of up to 3% of the global turnover of the relevant social network provider for the preceding calendar year.

In addition, a graduated enforcement mechanism applies for non-payment of administrative fines. As an initial step, resident taxpayers in Türkiye are prohibited from placing new advertisements with the relevant social network provider. Continued non-compliance may lead to progressive restrictions on the provider’s internet traffic bandwidth as determined by the competent authority. When the relevant obligations have been fulfilled, the advertising ban will be lifted and any bandwidth restrictions will cease to apply.

Transition period

The Amendments provide for a six-month transition period for the newly introduced obligations applicable to game platforms and social network providers discussed above under the Internet Law. The relevant requirements will go into effect on 1 November 2026. The technical and operational aspects of the compliance process will likely be set out in legislation to be issued by the ICTA.

Conclusion

The Amendments significantly expand Türkiye’s regulatory framework for digital platforms by introducing a dual compliance regime for online game platforms and social network providers. Game platforms are now brought within the scope of the Internet Law for the first time and are subject to new obligations, including local representative appointment, age-rating and parental control requirements. At the same time, the existing regime applicable to social network providers is further strengthened through enhanced child protection measures, stricter content removal timelines, and additional service obligations for minors.

Affected providers, particularly foreign-based platforms meeting the applicable access thresholds, should review their operations and prepare for compliance in advance of the implementation timeline. Given the stringent enforcement regime, including administrative fines and potential bandwidth restrictions, early compliance planning will be critical. Further guidance is expected through secondary legislation from the ICTA, which will clarify the practical implementation of the new obligations.

For more information on the Amendments and their implications in Türkiye, contact the experts who contributed to this article: alican.babalioglu@ybk-av.com, melis.celik@ybk-av.com, and ezgi.bahar@ybk-av.com.