Buying an online course takes seconds.

A consumer sees an Instagram advertisement promising:

“Become fluent in English in three months.”

They pay TRY 30,000, receive a username and password and immediately obtain access to hundreds of recorded lessons.

The next morning, the consumer changes their mind and asks for a refund.

The company replies:

“Digital products cannot be refunded.”

Is that correct?

Sometimes yes — but not always.

A second consumer purchases a twelve-month digital membership. After three months, they no longer want the service. The company says:

“You cannot cancel until the end of the year.”

Again, that statement may be legally incorrect.

The most common mistake in disputes concerning online education, digital platforms and memberships is confusing two different concepts:

the right of withdrawal (cayma hakkı)

and

the right to terminate a subscription (abonelik sözleşmesinin feshi).

They operate differently.

Under Turkish consumer law, a consumer will generally have a 14-day withdrawal right in distance contracts. However, the Distance Contracts Regulation contains important exceptions for electronically supplied services, immediately delivered digital content and services whose performance begins with the consumer’s consent before the withdrawal period expires. At the same time, recurring digital memberships may also qualify as subscription contracts and can be subject to separate termination rules.

The practical question is therefore not simply:

“Was the product bought online?”

The correct questions are:

What exactly was purchased?

Was it downloaded or immediately activated?

Did the course start?

Was the consumer warned that the withdrawal right would be lost?

Is this a one-off purchase or a continuing subscription?

Was the service delivered as promised?

Those distinctions can determine whether the consumer is entitled to a full refund.

1. The General Rule: 14 Days to Withdraw From a Distance Contract

Article 48 of Consumer Protection Law No. 6502 and the Distance Contracts Regulation govern many contracts concluded through:

• websites;
• mobile applications;
• telephone;
• social media;
• online marketplaces;
• and other remote communication systems.

The Ministry of Trade confirms that a consumer entering into a distance contract generally has 14 days to withdraw without giving a reason and without paying a contractual penalty.

For service contracts, the 14-day period begins on the date the contract is concluded.

For example:

Contract concluded: 1 September

Online course scheduled to begin: 1 October

Provided that no statutory exception applies, a consumer who gives notice on 5 September would ordinarily still be within the 14-day withdrawal period.

The consumer does not have to prove that:

• the course was defective;
• the teacher was inadequate;
• the consumer became unemployed;
• the consumer changed cities;
• or the consumer has another justified reason.

That is the central feature of the withdrawal right.

It is a right to change one’s mind.

2. But Online Education Is One of the Most Important Exceptions

The analysis changes considerably once the digital service is immediately supplied.

Article 15 of the Distance Contracts Regulation contains contracts for which the consumer cannot normally exercise the statutory withdrawal right unless the parties have agreed otherwise.

The Ministry of Trade expressly identifies:

distance education and similar services performed instantly in an electronic environment

among the situations where the statutory withdrawal right does not apply. It similarly lists intangible digital products delivered instantly, such as downloaded software, films and music.

Therefore, the argument:

“Everything purchased online can be returned within 14 days”

is incorrect.

There are significant statutory exceptions.

3. Recorded Online Courses: Can the Consumer Get a Refund?

Consider the most common model.

A consumer pays TRY 20,000 for a recorded digital course.

Immediately after payment:

• an account is activated;
• 150 recorded videos become available;
• PDF materials become downloadable;
• practice examinations can be opened;
• and the consumer can access the complete course library.

This is very different from purchasing a course that will begin one month later.

Where the digital educational service has effectively been delivered immediately through electronic access, the provider may rely on the statutory exception concerning electronically supplied services.

Accordingly, the consumer may not automatically have a 14-day no-reason withdrawal right merely because only one or two videos were watched.

However, this does not mean that every clause stating:

“No refunds under any circumstances”

is automatically enforceable.

Other issues still have to be examined.

4. The Provider Must Correctly Inform the Consumer Before the Purchase

Distance-contract rules impose substantial pre-contract information obligations.

Among other matters, the consumer must be informed about:

• the principal characteristics of the service;
• total price;
• provider identity and contact information;
• payment and performance conditions;
• whether a withdrawal right exists;
• and, where the withdrawal right does not exist or may be lost, that fact and the relevant conditions.

This is particularly important for online courses.

Imagine a checkout page displaying:

BUY NOW — TRY 25,000

but nowhere before payment does it clearly explain that:

• access will be activated instantly; and
• the consumer will therefore lose or not benefit from the statutory withdrawal right.

The company should not assume that simply placing:

“Digital products cannot be refunded”

somewhere in a 30-page terms-and-conditions document will necessarily resolve every consumer-law issue.

The provider bears important evidentiary obligations regarding consumer information.

5. If the Consumer Was Not Properly Informed, the 14-Day Rule Can Change Dramatically

The Distance Contracts Regulation places the burden of proving proper information about withdrawal rights on the seller or provider.

Where a consumer who has a withdrawal right is not properly informed about that right, the consumer is not limited to the ordinary 14-day period; the extended period can continue until one year after the normal withdrawal period expires, subject to the Regulation’s mechanism for later proper notification.

For digital services, the precise nature of the statutory exception still needs to be assessed.

Nevertheless, providers should not treat pre-contract disclosure as a technical formality.

In a dispute, one of the first questions should be:

Can the business prove exactly what the consumer saw and approved before making payment?

Evidence may include:

• checkout screenshots;
• electronic logs;
• tick-box records;
• IP logs;
• timestamped consent records;
• the pre-information form;
• membership agreement;
• and the exact version of the terms applicable on the purchase date.

6. A Pre-Ticked Box May Create Problems

Suppose the website contains:

☑ I request immediate performance and waive my right of withdrawal.

But the box is automatically selected.

That may create a significantly weaker position than an affirmative action taken by the consumer.

Where a business relies on the consumer’s prior approval to begin supplying a service before expiry of the withdrawal period, it should be capable of proving real and informed approval rather than merely relying on an obscure contractual statement.

A stronger compliance model would require the consumer actively to select a clear statement before immediate access is activated.

7. Live Online Courses Can Produce a Different Result

A live Zoom course starting next month should not automatically be treated in exactly the same way as an immediately accessible library of recordings.

Suppose:

Purchase: 1 September

First live lesson: 25 September

Cancellation request: 8 September

No lesson has occurred.

In that scenario, there is a stronger basis for the ordinary 14-day withdrawal right because the service has not yet begun and may not fall within the immediate electronic-performance exception merely because the course itself will eventually be delivered online.

Now change the facts.

Purchase: 1 September

Consumer requests course to start immediately

First lessons attended: 2–5 September

Cancellation: 8 September

Article 15 also contains an exception for service contracts where performance has begun before the expiry of the withdrawal period with the consumer’s approval.

Accordingly, the exact chronology matters.

8. “I Logged In Once” Does Not Answer the Entire Legal Question

Online education companies often respond to refund requests by producing a technical record:

“The consumer logged in at 14:32, therefore no refund.”

That record may be relevant.

But it should not always be treated as decisive by itself.

Counsel should examine:

• what the login actually provided access to;
• whether the service had already been fully made available;
• whether the consumer requested immediate performance;
• what withdrawal information was provided;
• whether downloadable material was accessed;
• how much content was viewed;
• whether live education had commenced;
• and whether the contract itself complied with mandatory consumer rules.

Court of Cassation jurisprudence involving online/live educational services has also treated actual use of the educational system as a fact requiring examination. In Court of Cassation 13th Civil Chamber, E. 2017/2504, K. 2020/1401, the Court held that the lower court had to investigate whether the educational service had in fact been supplied and whether the student had continued accessing the system, including after giving cancellation notice.

The case arose under different contractual circumstances and should not be mechanically applied to every modern digital subscription, but it illustrates an important point:

Actual performance and actual use matter.

9. Downloadable E-Books, Software and Digital Files Are Also Different From Ordinary Goods

Consumers frequently argue:

“I bought it online, so I can return it.”

But digital content delivered immediately does not operate like a pair of shoes delivered by courier.

The Ministry of Trade expressly lists intangible goods immediately delivered electronically — such as downloaded:

• music;
• films;
• and software

among contracts for which the statutory withdrawal right does not generally apply.

The same principle may become relevant to digital educational materials such as:

• downloadable video packages;
• e-books;
• test banks;
• software licences;
• digital templates;
• and other immediately supplied intangible content.

The exact contractual structure should nevertheless be examined.

10. Digital Subscription Cancellation Is Not the Same as Withdrawal

This distinction can completely change a dispute.

Suppose a consumer subscribes to an online language-learning platform for TRY 1,000 per month.

After five months the consumer decides:

“I don’t want this anymore.”

The initial 14-day withdrawal period may have long expired.

That does not necessarily mean the consumer is trapped in the subscription forever.

The Ministry of Trade expressly states that subscription contracts may include:

• digital broadcasting platforms;
• online education;
• video and music services;
• computer games;
• and software services.

Subscription termination is governed by separate rules.

11. The Provider Cannot Make Cancellation Deliberately Difficult

One of the strongest consumer protections concerning subscriptions is procedural.

According to the Ministry of Trade, a termination request may be sent:

• in writing;
• by SMS;
• by email;
• through the internet;
• or through another permanent data storage medium.

Where adequate security measures exist, telephone termination may also be possible.

Most importantly:

The provider cannot impose a more burdensome method for termination than the method used to create the subscription.

Therefore, if a consumer subscribed with three clicks online, the company generally cannot say:

“To cancel, you must personally visit our Istanbul office with a notarised petition.”

The Ministry specifically uses this type of example when explaining the prohibition.

12. Subscription Cancellation Must Normally Be Completed Within Seven Days

The Ministry’s current consumer guidance states that the seller or service provider must complete the termination request within a maximum of seven days after receiving it.

If the provider fails to complete termination during that period, the consumer cannot be charged for continued service after the relevant deadline merely because technical access remained available.

This can be highly relevant for:

• online fitness memberships;
• education platforms;
• paid communities;
• digital publishing services;
• SaaS-style consumer subscriptions;
• streaming platforms;
• and similar recurring memberships.

A provider should not be able to continue charging simply by ignoring the cancellation email.

13. What Happens to Money Paid in Advance?

Suppose the consumer has paid TRY 24,000 in advance for an eligible continuing subscription.

The subscription is lawfully terminated halfway through the relevant period.

The Ministry’s current guidance states that the provider must, within 15 days from termination, return the portion of prepaid amounts corresponding to goods not delivered or services not yet provided, together with certain security or deposit amounts where relevant.

A lawful early-termination charge arising from a properly structured committed subscription may potentially be deducted where the legislation permits it.

This is significantly different from a blanket clause stating:

“All prepaid membership fees are non-refundable under all circumstances.”

The legal character of the agreement must first be determined.

14. Can a Fixed-Term Digital Membership Automatically Renew?

Businesses frequently design memberships as follows:

“12-month membership — automatically renews unless you cancel.”

That practice should be examined carefully under Turkish subscription rules.

The Ministry of Trade states that a fixed-term subscription may only be extended after expiry where the consumer requests or approves the extension before the contract expires.

If the business continues providing goods or services after the fixed term expires without the consumer’s request or approval, it cannot demand payment merely on that basis.

This is particularly important for yearly:

• education packages;
• premium application memberships;
• digital newspaper subscriptions;
• professional learning platforms;
• and entertainment services.

15. “No Withdrawal Right” Does Not Mean “No Refund Under Any Circumstances”

This is perhaps the most important point for consumers.

Suppose a consumer has purchased a recorded course and therefore cannot rely on the no-reason statutory withdrawal right.

That does not give the provider permission to supply a defective service.

For example, the course is advertised as:

“100 hours of live instruction with native-speaking teachers.”

After payment, the consumer receives:

• 20 hours of old recordings;
• no live teacher;
• no promised certificate;
• and no individual support.

This is not merely a case of the consumer changing their mind.

It may be a case of defective service (ayıplı hizmet).

The Ministry of Trade states that subscription services may be defective where they:

• are not supplied as agreed;
• lack promised characteristics;
• begin late;
• fail to deliver the reasonably expected benefit;
• or differ from the characteristics stated in advertisements or promotions.

The consumer’s rights in such a situation are separate from the withdrawal right.

16. What Can the Consumer Claim When the Online Course Is Defective?

Where a consumer service is defective, Turkish consumer law provides remedies that may include:

• re-performance of the service;
• correction of the result produced by the service where appropriate;
• reduction of the price proportionate to the defect;
• or withdrawal from the contract.

The consumer may also claim compensation under the Turkish Code of Obligations where the relevant requirements are satisfied.

Therefore:

Scenario A

“The course is fine, but I changed my mind.”

This is primarily a withdrawal-right question.

Scenario B

“The company promised live education but provided recordings.”

This may be a defective-service question.

Scenario C

“I no longer want the monthly subscription.”

This is primarily a subscription-termination question.

These three situations should never be analysed as though they were identical.

17. Advertising Promises Can Become Legally Important

Many online education disputes begin with an advertisement rather than the contract.

Examples include:

“Guaranteed C1 English in 90 days.”

“Lifetime access.”

“Weekly one-to-one lessons included.”

“Officially recognised international certificate.”

“Guaranteed employment after graduation.”

If those characteristics materially induced the purchase but are not actually supplied, the consumer may argue that the service is defective.

The Ministry’s subscription guidance expressly states that a service can be defective where it does not possess characteristics advertised or promoted by the provider.

Therefore, consumers should preserve:

• Instagram advertisements;
• website screenshots;
• WhatsApp messages;
• sales calls;
• email offers;
• course descriptions;
• and landing pages.

The website may change after the dispute begins.

18. “Lifetime Membership” That Disappears After One Year

Consider the following example.

A consumer pays TRY 60,000 after seeing:

Lifetime Access — Pay Once, Study Forever.

One year later the company blocks access and asks for a renewal fee.

The primary issue is no longer whether the consumer could withdraw within 14 days.

The question is whether the provider has performed the service in accordance with the contractual and advertised commitment.

If “lifetime access” formed part of the contract or the advertising representation that influenced the purchase, termination of access may support a defective-service or breach claim.

19. What If the Course Is Simply Bad?

This is harder.

Consumer law does not guarantee that every educational service will produce the student’s desired result.

Suppose a course accurately states:

• 50 hours of recorded material;
• no personal coaching;
• B1 preparation course;
• access for six months.

The consumer receives exactly that but later says:

“The teacher is boring and I didn’t improve my English.”

That does not automatically establish a defective service.

The legal analysis should compare:

what was promised

with

what was actually provided.

Subjective dissatisfaction alone is not necessarily enough.

20. Promised Results Require Particular Attention

The result may be different where the provider made objective, measurable promises.

For example:

“Pass the IELTS exam or receive your money back.”

“Guaranteed 100-point improvement.”

“Guaranteed employment.”

“You will reach C1 level within 12 weeks.”

If the company markets the service through a specific result guarantee, the terms of that guarantee become highly relevant.

The provider cannot necessarily retreat to:

“Educational success depends entirely on the student”

if its advertising created a materially different contractual expectation.

21. Can a Provider Deduct the Lessons Already Used?

The answer depends on which legal mechanism is being used.

If a statutory withdrawal right validly exists and the consumer properly exercises it, the applicable distance-contract rules determine the consequences.

If the transaction is instead a continuing subscription being terminated after lawful use, the provider may be entitled to the portion attributable to services already supplied, while prepaid charges for services not yet provided may have to be returned depending on the subscription structure.

If the consumer is withdrawing because of a defective service, the appropriate refund or price reduction depends on the nature and seriousness of the defect.

There is therefore no universal rule stating:

“Once one lesson has been watched, the company may retain the entire annual fee.”

Nor is there a universal opposite rule:

“The consumer can watch half of the course and still demand 100% back.”

The legal basis matters.

22. Trial Periods Can Create Their Own Problems

Many digital services advertise:

“7 days free.”

The consumer enters credit-card details.

At the end of the trial, TRY 12,000 is automatically charged.

Whether that payment is lawful may depend on:

• whether the future payment was clearly disclosed;
• whether the consumer expressly agreed to it;
• how the subscription structure was presented;
• whether the total price and billing frequency were transparent;
• and whether cancellation was made unnecessarily difficult.

A business should not hide an expensive annual subscription behind a visually prominent “FREE” button while concealing the payment obligation in obscure terms.

The consumer should preserve screenshots of the sign-up flow.

23. What If the Company Continues Charging After Cancellation?

This is a common digital-subscription dispute.

Suppose the consumer sends a clear cancellation email on 1 March.

The company continues charging the card in:

• April;
• May;
• June.

The first evidentiary issue is proving the termination request.

Consumers should therefore cancel through a method that creates a permanent record.

Useful evidence includes:

• email;
• platform cancellation confirmation;
• SMS;
• support ticket;
• screenshot;
• or other permanent data record.

The Ministry states that subscription providers generally must implement termination within seven days and cannot continue claiming charges merely because the service remained technically accessible after they failed to process the request.

24. Consumers Should Distinguish “Cayma Bedeli” From “Cayma Hakkı”

The terminology can be confusing.

In Turkish practice, the expression “cayma bedeli” is often used to describe an early termination amount under a committed subscription.

This is not the same legal concept as the 14-day statutory right of withdrawal.

For certain committed subscriptions, a lawful early termination amount may be calculated according to the benefits or discounts obtained and remaining charges, subject to applicable legislation.

The Ministry explains the general principle by comparing:

• the total benefit or discounts already received; and
• the remaining subscription payments,

with the lower amount generally operating in the consumer’s favour in the relevant committed-subscription framework.

For online education and digital memberships, however, the applicability of any early termination fee should be tested against the exact contractual structure rather than copied mechanically from telecommunications contracts.

25. Foreign Digital Platforms Can Still Create Consumer Disputes

A Turkish consumer may subscribe to a service operated from:

• the United States;
• the United Kingdom;
• an EU member state;
• or another jurisdiction.

International contracts require an additional analysis concerning:

• applicable law;
• jurisdiction;
• platform terms;
• payment arrangements;
• and practical enforcement.

The Ministry of Trade also notes that consumers experiencing subscription disputes with foreign providers may, where the provider’s country participates in the international consumer-protection network ICPEN, use the econsumer.gov mechanism for cross-border complaints.

Domestic Turkish consumer remedies may additionally require an international private law analysis.

26. What Evidence Should a Consumer Preserve?

In an online course or digital-membership refund dispute, evidence is often entirely electronic.

A consumer should preserve:

1. the advertisement;
2. course or membership page;
3. checkout screen;
4. total price;
5. pre-information form;
6. distance contract;
7. membership agreement;
8. withdrawal-right disclosure;
9. any checkbox concerning immediate performance;
10. invoice;
11. credit-card payment;
12. login history where available;
13. course access records;
14. cancellation email;
15. WhatsApp correspondence;
16. support tickets;
17. advertised course programme;
18. promised certificates or guarantees;
19. proof of what was actually supplied;
20. and the provider’s refund rejection.

The question:

“What did the consumer actually agree to before clicking the payment button?”

is often decisive.

27. Where Can the Consumer Apply for a Refund?

The monetary value of the dispute determines the procedural route.

For 2026, disputes valued at less than TRY 186,000 fall within the jurisdiction of Consumer Arbitration Committees.

The Ministry of Trade expressly confirms the TRY 186,000 threshold for 2026.

For example:

TRY 25,000 online course refund

Consumer Arbitration Committee.

TRY 120,000 annual education package

Consumer Arbitration Committee.

TRY 220,000 professional training programme

The dispute exceeds the committee threshold. Subject to the applicable rules, mandatory mediation under Article 73/A and then proceedings before the Consumer Court may be required.

Applications to Consumer Arbitration Committees can also be submitted electronically through the e-Government/TÜBİS system.

28. A Practical Example: Recorded Course Accessed Immediately

Consider the following case.

A consumer purchases:

“Digital Marketing Masterclass” — TRY 40,000

Immediately after payment:

• 200 videos are unlocked;
• course PDFs can be downloaded;
• the consumer receives unlimited access.

Three days later the consumer says:

“I changed my mind. Refund me.”

The provider may have a strong argument that the service falls within the statutory exception applicable to immediately performed electronic services or instantly supplied digital content.

But counsel should still examine:

• whether the exception actually covers the contractual structure;
• what information the consumer received before payment;
• whether immediate performance was properly approved where approval was necessary;
• and whether the service corresponds to its advertising.

If the course was promised as a live mentorship programme but only old recordings were provided, the dispute may cease to be merely about withdrawal and become a defective-service claim.

29. A Practical Example: Course Has Not Started Yet

A consumer buys a six-month live English course for TRY 35,000 on 1 September.

Classes begin on 1 October.

The consumer sends a withdrawal notice on 8 September.

No lessons have begun and no substantial digital content has been delivered.

The ordinary 14-day withdrawal rule gives the consumer a much stronger position.

The company should not merely respond:

“It is online education, therefore there is never a withdrawal right.”

The facts must be analysed against the exact regulatory exception.

30. A Practical Example: Recurring Membership

A consumer subscribes to an online fitness platform.

Fee:

TRY 1,500 per month.

The consumer has used it for eight months.

The initial 14-day withdrawal period is irrelevant.

On 10 August the consumer emails:

“I terminate my subscription.”

The legal question is not whether the consumer can retroactively withdraw from eight months of service.

The issue is prospective termination of the subscription.

The provider cannot generally require a more burdensome cancellation procedure than the sign-up method, and the Ministry states that termination should be processed within a maximum of seven days.

31. A Practical Example: The Service Is Misrepresented

A parent buys a TRY 70,000 online exam-preparation package because the advertisement states:

“Five live private lessons every week.”

The child receives only one group lesson per week.

The company argues:

“Digital products are not refundable.”

That answer misses the legal issue.

The parent’s strongest argument may not be the 14-day withdrawal right at all.

It may be that the company supplied a defective service because the service materially differs from what was advertised and contracted.

The Ministry recognises services that fail to match advertised characteristics as potentially defective and confirms that consumers may seek remedies including price reduction or withdrawal from the contract.

32. What Should Online Education Companies Do?

Providers should not simply copy:

“No refunds”

into their terms.

A legally stronger digital sales process should clearly establish:

• what is being sold;
• whether the product is a service, digital content or subscription;
• when performance begins;
• whether full access is immediate;
• the duration of access;
• whether the consumer has a withdrawal right;
• when and why the right may be lost;
• affirmative approval for immediate performance where legally required;
• subscription termination procedures;
• renewal conditions;
• price and billing frequency;
• and the promised educational content.

Digital evidence of the transaction should also be retained.

33. The Best Legal Test: Ask Three Separate Questions

When a consumer asks:

“Can I get my money back from this online course or digital membership?”

the correct legal analysis should proceed in this order.

Question 1 — Withdrawal

Is the consumer still within a valid statutory no-reason withdrawal period?

If yes, exercise it immediately.

Question 2 — Termination

If this is a continuing subscription, can the consumer terminate future performance even though the withdrawal period has expired?

Often this is a completely separate right.

Question 3 — Defective Service

Did the business fail to provide what it promised?

If so, the consumer may have refund, price reduction or other remedies even where the ordinary withdrawal right does not exist.

This three-stage analysis avoids most mistakes.

Conclusion: “Digital Products Are Non-Refundable” Is Too Simplistic

Turkish consumer law does not establish a universal rule that every online purchase can be cancelled within 14 days.

But it also does not establish a universal rule that:

“Digital services can never be refunded.”

The correct outcome depends on the legal structure of the transaction.

A standard distance service contract may carry a 14-day withdrawal right.

An immediately supplied online course or instantly delivered digital content may fall within a statutory exception.

A service started during the withdrawal period with the consumer’s approval may also lose the benefit of ordinary withdrawal rules.

A recurring online education or digital membership may qualify as a subscription, giving the consumer separate termination rights even months after the original purchase.

And where the service is materially different from what was advertised or promised, the consumer may rely on defective-service remedies regardless of whether the 14-day withdrawal right has expired.

For consumers, the most important practical rule is therefore:

Do not simply say “I want to cancel.” Identify why you are entitled to the refund.

Is it because you are within the 14-day withdrawal period?

Because the subscription is being terminated?

Or because the service is defective?

For digital businesses, the opposite lesson applies:

Do not assume that writing “no refunds” into the terms overrides mandatory consumer law.

In online education and digital subscription disputes, the decisive evidence is usually found not in the final invoice, but in the screens immediately before payment:

what was promised, what was disclosed, what the consumer approved, when access began, and what was actually delivered.