Introduction
Internet content removal and access blocking under Law No. 5651 is one of the most important areas of Turkish internet law. In Turkey, online publications may create legal problems in many different ways: defamatory content, fake news pages, privacy violations, unlawful publication of personal data, revenge porn, phishing websites, illegal betting pages, child sexual abuse material, obscene content, threats to public order, social media impersonation, fake investment advertisements and cybercrime-related publications.
Law No. 5651, officially titled the Law on Regulation of Publications on the Internet and Combating Crimes Committed by Means of Such Publications, regulates the obligations and responsibilities of content providers, hosting providers, access providers and mass use providers, as well as procedures for combating certain crimes committed through internet publications. The purpose and scope of the law are expressly defined as regulating these internet actors and the procedures for combating specific crimes committed online.
However, Turkish internet content removal law has changed significantly in recent years. The Constitutional Court annulled Article 9 of Law No. 5651, which had been the main fast-track mechanism for personality-right violations, and the annulment entered into force on 10 November 2024. As a result, the legal landscape now requires a more careful distinction between catalogue crimes under Article 8, urgent public-order situations under Article 8/A, privacy violations under Article 9/A, social network provider obligations, ordinary civil-law remedies, and criminal complaints.
This article explains internet content removal and access blocking under Turkish Law No. 5651 from a practical legal perspective. It covers the current legal mechanisms, the effect of the annulment of Article 9, evidence preservation, urgent remedies, social media obligations, victim rights, defence arguments and strategic considerations for individuals, companies and digital platforms.
1. What Is Internet Content Removal?
Internet content removal means eliminating unlawful content from the platform, website, social media page, hosting environment or digital publication where it appears. Removal is stronger than access blocking because the content itself is no longer available through the original source.
For example, if a social media post unlawfully publishes a person’s private photograph, removal means the platform deletes the post. If a fake e-commerce page uses a company’s logo to commit fraud, removal means the hosting provider or website operator takes down the page. If a phishing website imitates a bank, removal means the fraudulent page is disabled.
Content removal is usually the preferred remedy where the content provider, hosting provider or social network provider can technically remove the content. It avoids the broader consequences of access blocking and is more consistent with proportionality. In practice, however, removal may be difficult if the content is hosted abroad, the publisher is anonymous, the platform does not respond quickly, or the content has been copied to multiple addresses.
2. What Is Access Blocking?
Access blocking means preventing internet users in Turkey from reaching a specific URL, page, section, image, video, domain or website. Unlike removal, the content may still exist on the original server, but access from Turkey is restricted.
Turkish law generally prefers targeted blocking. Law No. 5651 provides that certain access-blocking decisions should be applied to the specific publication, section or part where the violation occurs, such as a URL. However, if the violation cannot technically be prevented by blocking only the relevant content, blocking the entire website may become possible in certain circumstances. This URL-first approach appears in the consolidated text of Article 8 and similar mechanisms.
This distinction matters for freedom of expression and proportionality. Blocking an entire website because of one unlawful page may be excessive unless targeted blocking cannot prevent the violation. Therefore, petitions should always identify the exact URL, post link, image link, video link or page address when possible.
3. Article 8: Catalogue Crimes and Criminal Content
Article 8 of Law No. 5651 regulates content removal and/or access blocking for certain catalogue crimes. It applies where there is sufficient suspicion that the content of an internet publication constitutes one of the listed offences. The catalogue includes offences such as encouraging suicide, child sexual abuse, facilitating drug use, supplying substances dangerous to health, obscenity, prostitution, providing place or opportunity for gambling, offences under the Law on Crimes Against Atatürk, and offences under the law on football and other sports betting and games of chance.
Article 8 is especially relevant in serious criminal-content cases. Examples include:
Child sexual abuse material.
Illegal betting websites.
Obscene content within the statutory meaning.
Online content encouraging suicide.
Online content facilitating drug use.
Illegal gambling promotion.
Publications violating the Law on Crimes Against Atatürk.
In these cases, access blocking and/or content removal is not merely a private-rights remedy. It is connected to criminal law enforcement and public protection. A criminal complaint may also be filed, and the prosecutor may investigate the persons who created, hosted or disseminated the content.
A person or company applying under Article 8 should clearly explain which catalogue offence is involved, why the content creates sufficient suspicion, which URL contains the unlawful content, whether the content is still online, and whether urgent action is necessary to prevent further harm.
4. Article 8/A: Urgent Removal and Blocking Where Delay Is Detrimental
Article 8/A regulates urgent situations where delay may be detrimental. It may apply on grounds such as protection of the right to life, protection of persons’ life and property safety, protection of national security and public order, prevention of crime, or protection of public health. Under the consolidated text, a judge may decide removal and/or access blocking, and in urgent cases the President of the Information and Communication Technologies Authority may act upon requests from the Presidency or relevant ministries.
Article 8/A is not designed for every ordinary reputational dispute. It is an exceptional and urgent mechanism. It may become relevant where content creates an immediate and serious public risk, such as content that may endanger life, provoke violence, threaten public order, spread instructions for crime, or cause serious public-health risks.
The Constitutional Court has also scrutinized access-blocking mechanisms and emphasized procedural guarantees, equality of arms, adversarial review and proportionality concerns. In a 2025 decision, the Court referred to previous findings that access-blocking procedures may be problematic where affected parties cannot effectively participate, where objections do not provide sufficient adversarial review, and where indefinite blocking may occur.
For this reason, Article 8/A applications should be carefully reasoned. The applicant should not merely claim urgency. The petition should explain why delay would create concrete harm, why less restrictive measures would not be sufficient, and why the requested blocking or removal is proportionate.
5. Article 9 and the Current Gap for Personality Rights
For many years, Article 9 of Law No. 5651 was the main mechanism used for online personality-right violations, such as reputational attacks, defamatory publications, false allegations, insults, misleading news articles, company reputation damage and search-result association problems. However, the Constitutional Court annulled Article 9, and the annulment entered into force on 10 November 2024.
This has created a major practical shift. Before the annulment, persons claiming that online content violated their personality rights could request removal from the content provider or hosting provider and could also apply directly to the criminal judgeship of peace for content removal and/or access blocking. The former system also allowed decisions to be implemented quickly through the Access Providers Association. Although some consolidated legal texts may still show the historical wording, Article 9 is marked as annulled by the Constitutional Court.
After the annulment, ordinary personality-right disputes require more careful strategy. Legal commentary notes that Article 9’s annulment created a gap for online personality-right protection and that, during the period after the annulment, Article 8/A was sometimes used as a main access-blocking route, while individuals also relied on civil-law remedies such as Turkish Civil Code Article 25.
Therefore, in ordinary personality-right cases, the legal route should be selected carefully. If the content violates privacy, Article 9/A may apply. If it constitutes a catalogue crime, Article 8 may apply. If it creates urgent public-order risks, Article 8/A may apply. If it is mainly a reputational or personality-right dispute, civil-law remedies, compensation claims, injunctions and platform applications may need to be considered.
6. Article 9/A: Privacy-Based Access Blocking
Article 9/A remains one of the most important mechanisms for urgent online privacy violations. It applies where a person claims that the privacy of private life has been violated due to internet content. The person may directly apply to the Information and Communication Technologies Authority and request access blocking of the content. The request must include the full URL of the publication causing the violation, an explanation of how the right is violated, and information proving identity; otherwise, the request is not processed.
Article 9/A is especially relevant in cases involving:
Private photographs.
Intimate images or videos.
Hidden camera footage.
Private messages.
Private family information.
Personal data exposing private life.
Revenge porn.
Doxxing involving home address or private contact details.
Unlawful publication of private medical, sexual or family information.
Under Article 9/A, the President notifies the Access Providers Association, and access providers must implement the measure immediately and within four hours at the latest. The measure is applied by blocking access to the specific URL, image, video, section or part violating privacy. The applicant must submit the access-blocking request to the criminal judgeship of peace within 24 hours, and the judge must decide within 48 hours; otherwise, the measure is automatically lifted.
This mechanism is designed for speed. However, speed does not eliminate the need for evidence and legal reasoning. The applicant should preserve screenshots, URLs, account names, publication dates, platform details and evidence of privacy violation before seeking removal or blocking.
7. Privacy Violation vs. Personality Rights Violation
A major practical issue is distinguishing between a privacy violation and a general personality-right violation. This distinction became even more important after Article 9 was annulled.
A privacy violation concerns the private sphere of the person. It may involve intimate images, private family life, personal communications, medical information, sexual life, private residence information or hidden recordings. Article 9/A may be appropriate where the content directly intrudes into private life.
A personality-right violation is broader. It may involve reputation, honour, dignity, name, image, professional identity, commercial reputation or false allegations. After the annulment of Article 9, ordinary personality-right disputes may not fit automatically into Article 9/A unless the content also violates private life.
For example, a false news article accusing a company of misconduct may be a personality-right or commercial reputation issue, but not necessarily a privacy issue. An online post publishing a person’s private photographs is clearly closer to Article 9/A. A defamatory social media post may require civil action, criminal complaint for insult or defamation-related offences where applicable, platform complaint, or other remedies rather than Article 9/A.
8. Law No. 5651 and Criminal Complaints
Content removal and access blocking are preventive or remedial measures. They do not replace criminal complaints. If online content constitutes a crime, a criminal complaint should be considered separately.
Examples include:
Insult under Turkish Penal Code Article 125.
Threat under Article 106.
Blackmail under Article 107.
Violation of privacy under Article 134.
Unlawful acquisition or publication of personal data under Article 136.
Unauthorized access to social media or e-mail accounts under Article 243.
System interference under Article 244.
Fraud or qualified fraud through fake websites or social media accounts.
Obscenity, illegal betting or child sexual abuse material within Article 8.
A strong legal strategy often combines content removal, access blocking, criminal complaint, evidence preservation and civil compensation claims. For example, if private images are published online, Article 9/A may help restrict access quickly, while a criminal complaint may target the person who obtained or published the images.
9. Social Network Provider Obligations
Law No. 5651 also imposes obligations on social network providers. Large social platforms may have duties to respond to user applications, implement court or authority decisions, cooperate with authorities, appoint representatives, keep reports, and comply with Turkish internet-law obligations.
Recent amendments have further expanded obligations for social network providers. Under provisions entering into force on 1 November 2026, social network providers with more than ten million daily accesses from Turkey must implement Article 8/A urgent removal or access-blocking decisions immediately and within one hour at the latest. They must also take necessary measures to prevent republication on their own platforms of content subject to removal or access-blocking decisions.
This is important for companies, influencers, public figures and victims of fast-spreading harmful content. If unlawful content is reposted repeatedly on the same platform, the applicant should not limit the strategy to one URL. It may be necessary to document copies, request extension of the decision where legally available, notify the platform, and preserve evidence of non-compliance.
10. Access Providers Association
The Access Providers Association plays a central implementation role in access-blocking and content-removal decisions outside certain Article 8 and 8/A contexts. Under Law No. 5651, the Association was established to ensure implementation of content removal and/or access-blocking decisions outside the scope of Articles 8 and 8/A.
In practice, the Association is important because many court or authority decisions are transmitted through this mechanism to access providers. Applicants should ensure that decisions identify the correct URLs and that implementation is monitored. If the same content is republished under new addresses, the procedural route for applying the existing decision to new URLs must be examined carefully according to the applicable legal basis.
11. Evidence Preservation Before Removal or Blocking
Evidence preservation is one of the most important steps in any online content case. If the content is removed before evidence is preserved, the applicant may later struggle to prove the violation, identify the perpetrator or support a compensation claim.
Key evidence includes:
The full URL of the content.
Screenshots showing date, time, username and platform.
The account profile page.
Comments, captions, images, videos and replies.
E-mail headers if the content was sent by e-mail.
IP or login information if available.
Messages showing threats or blackmail.
Bank account or payment information in fraud cases.
Witness statements from persons who viewed the content.
Notarial determination where appropriate.
Platform complaint records.
Evidence should be preserved in a way that shows authenticity and context. Cropped screenshots may be weaker. The full page, URL bar, publication date, user profile and surrounding content may be necessary.
12. Content Removal for Companies and Commercial Reputation
Companies may suffer serious harm from unlawful online content. Fake news articles, impersonation websites, fake investment advertisements, counterfeit product pages, fraudulent social media accounts, defamatory reviews, employee leaks and phishing websites can damage commercial reputation and customer trust.
For companies, the correct legal route depends on the nature of the content. If the content is a phishing website or fraud page, criminal complaint and urgent provider action may be necessary. If the content uses personal data or trade secrets, criminal and civil remedies may apply. If the content is mainly reputational, civil-law remedies may be required after the annulment of Article 9.
Companies should preserve evidence showing commercial harm, such as customer complaints, lost contracts, fake invoices, misleading advertisements, confusion among customers, fraudulent bank details and brand misuse. Where the content involves trademark infringement or unfair competition, intellectual property and commercial law remedies may also be added.
13. Fake Social Media Accounts and Impersonation
Fake accounts are common in Turkish internet law practice. A person may create a fake account using another person’s name, photograph, professional title or company identity. The account may publish private data, defame the victim, deceive followers, request money or impersonate a professional.
The legal remedy depends on the content. If private life is violated, Article 9/A may apply. If the fake account commits fraud, a criminal complaint should be filed. If personal data is published, Turkish Penal Code Article 136 and KVKK remedies may be relevant. If the fake account harms reputation, civil action and platform complaints may be necessary.
The victim should preserve the fake account URL, profile information, account handle, screenshots, messages, posts, follower interactions and any payment requests. Platform takedown should be pursued, but evidence should be preserved first.
14. Phishing Websites and Fraudulent Content
Phishing websites are a major area where content removal and access blocking may be urgent. A fake bank page, fake cargo payment page, fake public authority page or fake investment website may deceive many victims quickly.
In these cases, legal strategy should include:
Criminal complaint for fraud or qualified fraud.
Request for preservation of hosting and domain records.
Notification to the bank or institution impersonated.
Platform or hosting provider takedown request.
Access blocking if legal conditions are met.
Evidence collection of URLs, screenshots, payment pages and bank details.
If personal data or card information is collected, KVKK and banking issues may also arise. The urgency is clear because each hour the fake site remains online may create new victims.
15. Private Images and Revenge Porn
Private image publication is one of the clearest areas for Article 9/A. If intimate photographs, private videos, hidden recordings or private conversations are published online, the victim should act immediately.
The first step is evidence preservation. The second step is urgent access blocking under Article 9/A. The third step is criminal complaint for violation of privacy, unlawful publication of personal data, blackmail or related offences. If the content appears on multiple platforms, each URL should be documented separately.
Victims should avoid engaging with the perpetrator in a way that may escalate the situation. If blackmail is involved, messages, payment demands, account names, IBANs, cryptocurrency wallet addresses and phone numbers must be preserved.
16. Objection and Defence Against Access Blocking
Access-blocking and removal decisions affect not only applicants but also publishers, journalists, platforms and users. Therefore, objection and defence rights are important.
A publisher or platform may argue that the content is lawful, newsworthy, within freedom of expression, based on public interest, or not a privacy violation. It may also argue that the measure is disproportionate, that the entire website should not be blocked, that the URL is incorrectly identified, or that the applicant’s claim requires ordinary civil proceedings rather than urgent blocking.
The Constitutional Court has criticized access-blocking procedures where they do not provide sufficient procedural safeguards, adversarial review or proportionality. Therefore, both applicants and respondents should address proportionality clearly.
A strong objection should identify the content, explain why the legal basis is not met, show public interest or lawful basis where applicable, challenge urgency, and argue for narrower measures if any restriction is necessary.
17. Proportionality and URL-Based Blocking
One of the central principles in Turkish internet-content disputes is proportionality. A measure should be limited to what is necessary to remove the violation. URL-based blocking is generally more proportionate than domain-wide blocking. Domain-wide blocking may be justified only where the violation cannot technically be prevented by blocking the specific URL or where the unlawful structure affects the entire website.
This principle appears in multiple parts of Law No. 5651. For example, Article 9/A provides that blocking is applied to the specific content such as the relevant URL, image, video, section or part that violates privacy.
For applicants, this means the petition should identify exact URLs. For respondents, it means objections should focus on narrowing the measure if a full-site block is unnecessary.
18. Search Engine De-Indexing and Reputation Management
Historically, Article 9 allowed judges to decide that the applicant’s name should not be associated with certain internet addresses and to notify search engines through the Access Providers Association. The consolidated text still shows this historical provision, but Article 9 is marked as annulled.
After the annulment of Article 9, search-result de-indexing strategies require careful legal assessment. Depending on the facts, applicants may rely on data protection rights, civil-law remedies, platform policies, search-engine removal tools, privacy-based arguments or court injunctions. Where the content violates private life, Article 9/A may remain relevant for access blocking, but ordinary reputation-related de-indexing is more legally complex.
For professional reputation cases, a combined strategy may be necessary: evidence preservation, civil action, correction/response demands, platform requests, search-engine requests, and compensation claims.
19. Relationship with KVKK and Personal Data
Many online content cases involve personal data. Publishing identity numbers, addresses, phone numbers, medical data, photographs, private messages, bank information or customer data may create personal data issues under the KVKK and Turkish Penal Code.
If a data controller is responsible for the publication or data leak, the affected person may use KVKK rights. If personal data is unlawfully obtained or published by an individual, criminal complaint under Turkish Penal Code Article 136 may be appropriate. If private life is violated, Article 9/A may also be used to seek access blocking.
Therefore, online content cases should not be analyzed only under Law No. 5651. The correct strategy may also involve data protection law, criminal law, civil law and platform policy.
20. Practical Checklist for Applicants
A person or company seeking content removal or access blocking in Turkey should follow a structured approach:
Identify the exact content and URL.
Determine whether the content involves privacy, catalogue crimes, public-order urgency or personality rights.
Preserve evidence before requesting removal.
Take screenshots showing URL, date, account and content.
Collect witness statements if needed.
Determine whether criminal complaint is necessary.
Use Article 9/A for private-life violations where applicable.
Use Article 8 for catalogue crimes where applicable.
Evaluate Article 8/A only where delay is genuinely detrimental.
Consider civil-law remedies after Article 9 annulment.
Submit platform and hosting provider complaints.
Monitor copies and republications.
Document damage for compensation claims.
Seek urgent action where private images, fraud or safety risks are involved.
21. Practical Checklist for Platforms and Publishers
Platforms and publishers should also follow a compliance-oriented approach:
Maintain a reliable notice-and-action system.
Respond to lawful requests promptly.
Preserve logs where legally required.
Review whether a decision is valid and specific.
Implement URL-based decisions accurately.
Avoid overblocking lawful content.
Keep records of implementation.
Prepare objection petitions where a decision is unlawful or excessive.
Protect user rights and freedom of expression.
Monitor 2026 social network provider obligations.
Ensure crisis and urgent-response teams are ready.
Large social network providers should pay particular attention to the obligations entering into force on 1 November 2026, including one-hour implementation of Article 8/A urgent decisions for providers exceeding ten million daily access from Turkey.
Conclusion
Internet content removal and access blocking under Law No. 5651 is a complex and fast-changing area of Turkish law. The current system requires a careful distinction between different legal bases. Article 8 applies to listed catalogue crimes. Article 8/A applies to urgent situations where delay would be detrimental for reasons such as life, safety, public order, national security, crime prevention or public health. Article 9/A applies to violations of privacy of private life. Article 9, which formerly regulated personality-right violations, was annulled by the Constitutional Court, creating a practical need to use civil-law remedies and other legal routes carefully.
For victims, speed and evidence are essential. The exact URL must be identified, screenshots and original records must be preserved, and the correct legal basis must be selected. For companies, online content disputes may involve commercial reputation, fraud, trademark misuse, customer deception, personal data and cybercrime. For platforms and publishers, proportionality, freedom of expression, timely compliance and objection rights are central.
Turkish internet law provides powerful remedies, but those remedies must be used precisely. A successful content removal or access-blocking strategy depends on selecting the correct article, proving urgency or privacy where required, preserving digital evidence, avoiding overbroad requests and combining Law No. 5651 remedies with criminal, civil and data protection procedures when necessary.
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