Automatic Subscription Renewals, Digital Memberships and Refund Rights Under Turkish Consumer Law

Automatic renewal has become the default business model for many digital services.

Consumers increasingly subscribe to:

• video and music streaming platforms;
• mobile applications;
• cloud-storage services;
• online education platforms;
• software and SaaS products;
• fitness applications;
• gaming services;
• digital newspapers;
• dating applications;
• premium social-media memberships; and
• other online services

by entering their credit-card information once and allowing the provider to charge them periodically.

The problem usually appears months later.

A consumer purchases a one-year subscription for TRY 3,000. Twelve months later, the company automatically charges another TRY 6,000 to the same credit card.

The consumer says:

“I never agreed to renew it.”

The company replies:

“Automatic renewal was included in our terms and conditions.”

Under Turkish consumer law, that answer may not be sufficient.

The crucial distinction is between:

a fixed-term subscription that is automatically renewed, and

an indefinite subscription that was validly established from the beginning with recurring periodic payments.

The legal consequences are very different.

For fixed-term consumer subscriptions, Turkish law provides particularly strong protection: the contract cannot simply contain a provision stating that it will automatically renew for another fixed period.

Under Article 52 of Consumer Protection Law No. 6502, a fixed-term subscription can generally be extended only if, after the subscription contract was concluded and before its expiry, the consumer specifically requests or approves the extension.

This means that, in appropriate circumstances, a consumer whose card has been charged following an unlawful automatic renewal may be entitled to demand a refund.

However:

Not every recurring subscription charge is automatically unlawful, and forgetting to cancel a valid indefinite subscription does not necessarily create a right to recover every payment already made.

The contractual structure must first be identified correctly.

1. What Is a Subscription Contract Under Turkish Law?

Article 52 of Law No. 6502 defines a subscription contract as an agreement allowing a consumer to obtain a particular good or service continuously or at regular intervals.

The Ministry of Trade’s current consumer guidance expressly confirms that this concept can cover much more than traditional electricity, telephone and internet subscriptions.

Examples include:

• digital broadcasting platforms;
• online education;
• video and music services;
• computer games;
• software;
• parking services; and
• various regularly supplied products and services.

Therefore, a subscription does not stop being a legally regulated subscription merely because the service is provided through an app.

A monthly software membership can potentially constitute a subscription.

So can a video-streaming membership.

So can an annual online-education membership.

The first legal question is therefore not:

“Is this Netflix, SaaS or an app?”

It is:

“Does the agreement allow the consumer to receive a good or service continuously or periodically?”

2. The Most Important Rule: Fixed-Term Subscriptions Cannot Simply Auto-Renew

Article 52/3 of Law No. 6502 contains an extremely important rule.

A fixed-term subscription agreement cannot contain a clause providing that the agreement will automatically extend for the same predetermined period.

An extension is possible where, after the original agreement has been concluded and before it expires, the consumer requests or approves the extension.

The Abonelik Sözleşmeleri Yönetmeliği contains the same principle.

It also states that where the provider continues providing goods or services after expiry without obtaining the consumer’s explicit request or approval, it cannot demand payment for those goods or services.

This rule can have major consequences for annual subscription models.

3. Example: One-Year Subscription Automatically Renewed for Another Year

Suppose a consumer purchases:

One-Year Premium Membership — TRY 4,000

The terms state:

“At the end of each annual term, your membership will automatically renew for another year unless cancelled.”

No further approval is obtained.

At the end of the year, the provider charges:

TRY 7,500

to the consumer’s stored credit card.

This structure should be carefully examined under Article 52/3.

The provider cannot necessarily defend itself merely by saying:

“The consumer accepted our terms when signing up twelve months ago.”

The statute specifically contemplates an extension approval occurring after conclusion of the original subscription and before expiry.

Accordingly, a standard automatic-renewal clause included at the beginning of a fixed-term subscription may not provide a sufficient legal basis for another fixed term.

The consumer may therefore have a strong basis to challenge the renewed fee.

4. A Pre-Ticked “Automatic Renewal” Box May Not Solve the Problem

Imagine that the checkout page contains:

☑ Automatically renew my annual subscription.

and the box is already selected.

This structure creates additional consumer-law problems.

Under the Distance Contracts Regulation, additional payments beyond the principal agreed price require the consumer’s express consent. The Ministry of Trade states that where an additional payment results from a pre-selected option without the consumer’s express approval, the amount must be refunded.

Although the precise legal characterization depends on the subscription structure, the broader principle is important:

silence, inactivity and pre-selected options should not be treated as equivalent to an informed affirmative payment decision.

For a fixed-term renewal, the specific requirements of Article 52 remain particularly important.

5. But Monthly Recurring Subscriptions Are Not Necessarily Illegal

Consider a different contract.

The consumer signs up for:

“TRY 299 per month until cancelled.”

The agreement is not described as a twelve-month contract that renews every month.

Instead, it is an indefinite subscription relationship under which the consumer pays monthly until termination.

That structure is fundamentally different.

There may not legally be a new “renewal” every month.

Instead, the original indefinite subscription simply continues.

Consequently:

A recurring monthly charge is not automatically unlawful merely because the consumer did not click a new consent button every month.

The key questions become:

• Was the recurring-payment structure clearly disclosed?
• Was the price clear?
• Was the consumer informed that payments would continue until cancellation?
• Can the consumer easily terminate the subscription?
• Were later price changes lawfully implemented?
• Did the provider continue charging after termination?

6. “I Forgot to Cancel” Does Not Always Mean “I Am Entitled to a Full Refund”

This distinction is critical.

Suppose a consumer knowingly subscribed to:

“TRY 200/month until cancelled.”

The terms were clearly displayed.

The consumer used the service for eight months and simply forgot to cancel.

It will usually be much more difficult to argue that all eight months of charges must be refunded merely because the consumer later stopped using the service.

Non-use alone does not automatically mean that the service was not provided.

For example, if a streaming platform kept the account active and available throughout the month, the fact that the consumer chose not to watch anything is different from the provider failing to provide access.

Accordingly, a validly established indefinite subscription should not be confused with an unlawfully renewed fixed-term agreement.

7. When Is a Refund Claim Particularly Strong?

A refund claim becomes considerably stronger where one or more of the following circumstances exist:

1. A fixed-term subscription was renewed without new approval

This is the clearest case under Article 52/3.

2. The consumer cancelled but charging continued

Amounts charged after the lawful termination period may be recoverable.

3. The provider concealed that the subscription would continue

For example, the checkout page prominently states:

“TRY 99 trial”

while recurring monthly charges are hidden in lengthy terms.

4. The renewal price was not adequately disclosed

The consumer may have agreed to one price but subsequently been charged a materially different amount without proper contractual basis.

5. The subscription was created without authorization

For example, a child, fraudster or third party activates a service without the cardholder’s authorization.

6. The service was never actually supplied

The provider generally cannot charge for a service it has not provided.

7. The provider makes cancellation practically impossible

For example, signup requires one click but cancellation requires visiting a physical branch.

8. The consumer was charged after the company confirmed cancellation

This normally creates particularly strong documentary evidence.

8. Cancelling an Online Subscription Must Not Be Made Unreasonably Difficult

Article 52 contains another important protection.

The provider cannot require a termination method that is more burdensome than the method used to establish the subscription.

The Ministry of Trade gives a straightforward example:

A subscription established online cannot require the consumer to visit a physical branch or use a notary merely to terminate it.

This is highly relevant to digital subscriptions.

A consumer should not face a situation such as:

Subscribe:

One click.

Cancel:

Call between 09:00 and 11:00.

Wait forty minutes.

Speak to three representatives.

Send a signed petition.

Upload identity documents.

Wait fifteen days.

Such cancellation architecture may create significant consumer-law risk.

9. How Quickly Must the Provider Process Cancellation?

According to the Ministry of Trade’s current 2026 guidance, a provider must generally execute a consumer’s subscription termination request within seven days after receiving it.

If the provider fails to terminate the subscription within the legally prescribed period, it may not continue demanding fees after that period even if the consumer continued to have access to the service.

This creates an important practical distinction.

Suppose:

1 March: Consumer clicks “Cancel Subscription.”

8 March: Statutory termination period has passed.

20 March: Provider charges another monthly fee.

The provider cannot automatically justify the charge by saying:

“But your account remained active.”

If the account remained active because the provider failed to execute the cancellation request in time, the consumer’s position is significantly stronger.

10. What Happens to Prepaid Subscription Fees After Cancellation?

This is another major refund category.

Suppose a consumer pays:

TRY 12,000 in advance for a subscription period.

The contract is lawfully terminated while a portion of the prepaid period remains unused.

The Ministry of Trade’s current guidance states that, following termination, the provider must return the prepaid amount corresponding to goods not delivered or services not yet provided within 15 days, without deduction, subject to the rules applicable to committed subscriptions.

Therefore, a consumer may sometimes be entitled not merely to stop future billing but also to receive the unused prepaid portion back.

This is different from recovering amounts for periods in which the service was already validly available.

11. Can a Company Say “Annual Subscription Fees Are Non-Refundable”?

A provision stating:

“All payments are final and non-refundable under all circumstances.”

should not automatically be assumed to be enforceable.

Consumer contracts are subject to the rules on unfair contractual terms.

Under Article 5 of Law No. 6502 and the Regulation on Unfair Terms in Consumer Contracts, a standard contractual term may be unfair where:

1. it was not individually negotiated; and
2. contrary to good faith, it creates a significant imbalance in the parties’ contractual rights and obligations against the consumer.

Unfair terms are legally ineffective.

Accordingly, a provider cannot necessarily neutralize mandatory consumer rights by inserting:

“No refunds under any circumstances.”

into a thirty-page terms-of-service document.

Mandatory statutory rights prevail over standard contractual wording.

12. “You Accepted the Terms and Conditions” Is Not the End of the Analysis

Digital companies frequently rely on click-wrap agreements.

For example:

“By clicking Continue, you accept our Terms of Service.”

That may establish contractual consent.

But it does not make every clause lawful.

Consumer legislation separately requires contractual provisions to comply with mandatory rules.

A clause may therefore have been technically “accepted” and still be legally ineffective as an unfair term or as a provision contrary to mandatory consumer legislation.

The correct legal inquiry is:

Was the clause accepted?

and then:

Was the clause itself legally valid?

These are separate questions.

13. The 14-Day Withdrawal Right Can Help—but Not in Every Digital Subscription

Distance contracts generally provide consumers with a 14-day withdrawal right without giving a reason or paying a penalty.

For service contracts, the period generally begins on the date the contract is concluded.

However, digital subscriptions create important exceptions.

The Distance Contracts Regulation excludes the withdrawal right in certain situations, including:

• electronically supplied services performed instantly;
• intangible digital content delivered instantly; and
• services that begin before expiry of the withdrawal period with the consumer’s approval, subject to the applicable statutory conditions.

Accordingly:

“I purchased an online subscription less than 14 days ago” does not automatically guarantee a withdrawal refund.

The exact service and how performance began must be examined.

More importantly, the 14-day withdrawal right and the rules governing automatic renewal are different legal mechanisms.

Even where the consumer cannot use the withdrawal right, an unauthorized fixed-term renewal may still be challenged under Article 52.

14. Example: Online Education Subscription

Suppose an online education platform sells:

One-Year Premium Course Membership — TRY 9,000.

The consumer watches lessons throughout the year.

At the end of the year, the card is automatically charged:

TRY 14,000 for Year Two.

The company relies on an automatic-renewal clause included in the original signup terms.

The consumer did not separately request or approve another year before expiry.

The fact that the initial educational service may have involved digital content and potentially an exception to the distance-contract withdrawal right does not necessarily answer the renewal issue.

The legal analysis should separately ask:

Was the second one-year subscription validly extended under Article 52/3?

That distinction can determine whether the TRY 14,000 must be refunded.

15. Free Trials Can Create Significant Legal Risk

Automatic conversion from a free trial into a paid subscription is another common source of disputes.

For example:

“7 Days Free”

appears prominently.

In much smaller text:

“After seven days your card will automatically be charged TRY 2,999 for a one-year membership.”

The legal risks may include:

• insufficient pre-contractual information;
• misleading commercial practice;
• lack of sufficiently clear payment consent;
• unfair contractual terms; and
• automatic-renewal issues depending on how the subsequent agreement is structured.

The Distance Contracts Regulation requires the consumer to be informed clearly immediately before placing an order that the transaction creates a payment obligation; otherwise, the consumer is not bound by the order.

A business should therefore not design a free trial in a manner intended to make the consumer forget that a substantial charge will follow.

16. What If the Subscription Price Increases?

Suppose the consumer signs up for:

TRY 99 per month

and six months later receives a charge for:

TRY 499 per month.

The provider cannot assume that storing the consumer’s credit card gives it an unlimited right to determine future prices.

Consumer-contract principles require contractual terms to be transparent, while unfair terms creating an unjustified imbalance may be ineffective.

The Ministry of Trade also confirms generally that contractual provisions in consumer agreements cannot simply be changed against the consumer during the contract period.

In committed subscriptions, the Abonelik Sözleşmeleri Yönetmeliği expressly prohibits changes to the consumer’s detriment during the commitment period.

Price-increase disputes therefore require examination of:

• the contractual structure;
• whether the term is fixed or indefinite;
• how the price-change mechanism was drafted;
• whether advance notice was given;
• whether the consumer had a meaningful opportunity to terminate; and
• whether the new charge was actually authorized.

17. What If the Consumer Never Used the Renewed Subscription?

Non-use can be important evidence, but it is not automatically decisive.

Consider two scenarios.

Scenario A — Unauthorized Annual Renewal

The consumer did not approve the second fixed annual period.

The card is charged.

The account is never used after renewal.

This can be a particularly strong refund case.

The absence of use supports the argument that the consumer did not knowingly accept or benefit from the renewed term.

Scenario B — Valid Indefinite Monthly Subscription

The consumer knowingly subscribes to a service that continues until cancelled.

The consumer simply does not log in for three months.

This does not necessarily mean the provider failed to provide the service.

The refund analysis is therefore much weaker.

The legal basis of the charge remains more important than login statistics alone.

18. Can the Consumer Ask the Bank to Reverse the Charge?

Potentially.

A card dispute and a consumer-law refund claim are not exactly the same thing.

The Ministry of Trade’s current guidance expressly notes that where a card payment connected with a subscription is believed to have occurred without the consumer’s knowledge or authorization, the consumer may submit a transaction objection to the card-issuing institution under the Bank Cards and Credit Cards Law No. 5464.

Therefore, where a disputed subscription fee appears on a credit-card statement, the consumer should consider acting quickly.

Relevant documents may include:

• credit-card statement;
• cancellation confirmation;
• subscription agreement;
• email correspondence;
• renewal notification;
• screenshots;
• service-usage records; and
• the original offer page.

A chargeback process does not necessarily replace the right to bring a consumer-law claim.

19. What Evidence Should the Consumer Keep?

Automatic-renewal disputes are heavily document-based.

A consumer seeking a refund should preserve:

1. the original subscription offer;
2. screenshots of the signup page;
3. terms and conditions applicable on the purchase date;
4. confirmation emails;
5. invoices;
6. bank or credit-card statements;
7. renewal emails;
8. price-increase notifications;
9. cancellation requests;
10. customer-support correspondence;
11. cancellation confirmation;
12. login and usage history where available;
13. screenshots showing difficulty cancelling;
14. advertisements describing the subscription period; and
15. evidence of any refund rejection.

This evidence can establish the central question:

Did the consumer actually authorize the charge that the provider collected?

20. The Business Should Be Asked to Produce Proof of Renewal Consent

Where a fixed-term subscription has been renewed, the consumer should not merely say:

“I don’t remember accepting it.”

A stronger written demand is:

“Please provide the date, method, content and electronic record proving my request or approval to extend the fixed-term subscription after conclusion of the original contract.”

This focuses the dispute on Article 52/3.

The provider may be able to produce:

• a renewal button clicked by the consumer;
• an authenticated in-app approval;
• an email confirmation;
• an SMS approval;
• another reliable electronic record.

If it cannot do so and relies exclusively on a clause accepted at the beginning of the original fixed term, the consumer’s position may be substantially stronger.

21. What If the Company Sent a Renewal Email but the Consumer Did Nothing?

This is an important practical question.

Suppose the company sends:

“Your subscription will renew automatically in seven days. No action is required.”

The consumer does nothing.

The company charges the annual renewal fee.

For a fixed-term subscription, the critical issue remains whether the consumer actually requested or approved the extension within the meaning of Article 52/3.

Sending a notice and treating silence as approval is not necessarily equivalent to obtaining an affirmative request or consent.

The legal analysis should therefore distinguish:

notification

from

approval.

They are not always the same thing.

22. A Better Renewal Structure for Businesses

A compliant business selling fixed-term subscriptions should consider using an active renewal process.

For example:

Your annual subscription expires on 30 September.

Renew for another year for TRY 4,990?

[Renew Subscription]

The consumer actively selects the renewal option.

The system records:

• date;
• time;
• user account;
• relevant subscription;
• renewal price;
• renewed term; and
• consent record.

This creates substantially stronger evidence than relying on:

“Automatic renewal was mentioned somewhere in the original terms.”

23. Does Consumer Law Apply to Business SaaS Subscriptions?

Not necessarily.

This distinction is extremely important.

Consumer Protection Law No. 6502 applies where the customer acts for purposes outside commercial or professional activity.

The Ministry of Trade’s 2026 guidance expressly states that subscriptions obtained for commercial or professional purposes fall outside the consumer-protection framework.

For example, where a company purchases internet or another subscription service for its business operations, the dispute does not fall within the jurisdiction of consumer arbitration committees or consumer courts merely because the contract is called a subscription.

The same issue can arise with SaaS products.

Personal subscription

An individual subscribes to cloud storage for private photographs.

Consumer law may apply.

Commercial subscription

A law firm subscribes to cloud software for client management.

The transaction may be commercial rather than consumer-related.

In a B2B subscription, automatic renewal must instead be assessed mainly through:

• the Turkish Code of Obligations;
• the Turkish Commercial Code;
• standard terms;
• contractual interpretation;
• notice requirements; and
• the specific SaaS agreement.

Therefore:

The same automatic-renewal clause may produce different legal consequences in B2C and B2B contracts.

24. Where Can the Consumer Seek a Refund?

The first step should usually be a written refund request to the provider.

The consumer should state:

• subscription number;
• original contract date;
• original term;
• disputed renewal date;
• amount charged;
• whether renewal approval was given;
• cancellation date if applicable;
• legal basis for the objection; and
• requested refund.

If the dispute remains unresolved, a consumer may apply to the appropriate consumer dispute mechanism.

For 2026, disputes below TRY 186,000 fall within the monetary jurisdiction of Consumer Arbitration Committees.

Higher-value disputes are generally brought before consumer courts, subject to the applicable procedural and mandatory mediation rules.

A bank-card transaction objection may also be considered in parallel where the payment is alleged to have been unauthorized.

25. Practical Refund Risk Matrix

26. A Practical Example

Consider the following case.

A consumer purchases a twelve-month fitness application subscription on 1 September 2025 for:

TRY 1,999.

The checkout terms state:

“Membership automatically renews annually.”

The consumer does not interact with the application for several months.

On 1 September 2026, the company automatically charges:

TRY 5,999.

There was:

• no renewal button;
• no affirmative in-app approval;
• no SMS confirmation;
• no new consent before expiry.

The consumer notices the charge the next day and immediately requests cancellation and a refund.

The company responds:

“Your original contract contained automatic renewal. Refunds are not available.”

The consumer’s case should not be analysed merely under the company’s refund policy.

The central legal question is:

Did the provider satisfy Article 52/3 and obtain the consumer’s request or approval for extension after the original contract was established and before it expired?

If the answer is no, the company’s reliance solely on the original automatic-renewal clause may be seriously problematic.

The consumer should demand:

1. cancellation;
2. refund of the renewal payment;
3. proof of any alleged renewal approval;
4. preservation of electronic transaction records; and
5. where necessary, consumer arbitration or judicial relief.

27. Five Questions That Usually Decide an Automatic-Renewal Dispute

Question 1 — Was the subscription fixed-term or indefinite?

This is the starting point.

Question 2 — If fixed-term, did the consumer later approve renewal?

Not merely when originally subscribing.

Question 3 — Was the renewed price clearly disclosed?

Especially if the renewal price differs substantially from the initial promotional price.

Question 4 — Did the consumer attempt to cancel?

If yes, when and through which channel?

Question 5 — What happened after the alleged renewal?

Was the service used? Was the account inactive? Was the charge immediately disputed?

These facts usually determine the strength of the refund claim.

28. What Subscription Businesses Should Do to Reduce Legal Risk

A digital subscription business operating in Turkey should consider implementing:

1. clear classification of fixed and indefinite subscriptions;
2. transparent recurring-payment information;
3. active renewal consent for fixed-term extensions;
4. renewal price disclosure before payment;
5. records proving consumer approval;
6. simple online cancellation;
7. no cancellation method more burdensome than signup;
8. timely execution of termination requests;
9. automatic calculation of unused prepaid refunds;
10. lawful free-trial conversion mechanisms;
11. clear price-change procedures;
12. separate B2C and B2B terms;
13. retention of electronic consent records; and
14. legally reviewed refund policies.

The phrase:

“All subscriptions automatically renew and no refunds are given.”

is not an adequate Turkish consumer-law compliance strategy.

Conclusion: Automatic Renewal Does Not Automatically Mean the Charge Is Valid

Consumers in Turkey have significant protection against unauthorized subscription renewals.

The strongest statutory rule concerns fixed-term subscriptions.

Under Article 52 of Law No. 6502, a fixed-term subscription cannot simply be extended for another fixed period through an automatic-renewal provision. The extension generally requires the consumer to request or approve it after the original subscription has been concluded and before it expires.

Where no such approval exists, a provider that continues supplying the service after expiry cannot automatically demand payment merely because an old contractual clause said:

“Your membership automatically renews.”

However, this rule should not be overextended.

A clearly disclosed indefinite monthly subscription that continues until cancellation is legally different from a fixed annual contract that renews for another year.

Therefore, the practical question is not simply:

“Was my card automatically charged?”

The correct questions are:

Was this a fixed-term or indefinite subscription?

What exactly did I consent to?

When was renewal consent obtained?

What price did I authorize?

Did I cancel before the disputed charge?

Did the provider continue charging after cancellation?

And can the provider actually prove my consent to the renewed obligation?

Where the provider cannot prove a lawful basis for the renewed charge, the consumer may seek cancellation, repayment of the subscription fee, recovery of unused prepaid amounts and, where appropriate, a card-payment objection or consumer-law proceedings.

The most useful practical principle is therefore:

A stored credit card is a payment method—not permanent permission to charge the consumer whenever the provider decides to renew the contract.