Introduction
Advertising to children is one of the most sensitive areas of Turkish advertising law. Children are not ordinary consumers. They may not fully understand the persuasive purpose of advertisements, the difference between entertainment and commercial promotion, the economic consequences of a purchase, the value of money, the meaning of sponsorship or the risks of digital profiling. For this reason, Turkish law gives special protection to children in commercial advertising and unfair commercial practices.
The subject of advertising to children in Turkey has become increasingly important with the growth of digital platforms, mobile games, influencer content, video-sharing applications, toy reviews, educational apps, children’s food products, online marketplaces, social media challenges and personalized advertising systems. Children may now encounter advertising not only on television, but also on tablets, smartphones, video platforms, games, social media, in-app purchases, search results, streaming services and influencer accounts.
Turkish advertising law does not completely prohibit advertisements concerning children’s products or advertisements that may be seen by children. However, it imposes strict legal limits. Advertisements must not exploit children’s lack of experience, must not harm their physical or mental development, must not encourage unsafe behavior, must not pressure children to persuade their parents, must not mislead them about price or product features, and must not promote excessive consumption. The Ministry of Trade has expressly stated that commercial advertisements must not exploit consumers’ lack of knowledge or experience and must not be capable of abusing patients, elderly persons, children or persons with disabilities.
The importance of child protection in advertising was also emphasized in the Ministry of Trade’s announcement dated 19 October 2025, where the Ministry stated that the Advertising Board continues inspections against advertising content that targets children and exploits their perceptual vulnerabilities. The same announcement referred to rules prohibiting advertisements that direct children to dangerous situations, encourage excessive consumption or exploit children’s developmental level.
In 2026, the regulatory framework became even more significant for digital advertising. The Ministry of Trade announced that amendments to the Regulation on Commercial Advertising and Unfair Commercial Practices introduced new rules on targeted advertising, influencer marketing, AI-generated advertisements, discount advertising and other areas. Most importantly for children, targeted advertising directed at children through profiling methods based on personal data was prohibited.
This article explains the legal limits of advertising to children in Turkey, including consumer protection principles, misleading advertising risks, digital advertising, influencer marketing, targeted advertising, children’s personal data, in-app purchases, food and health-related advertisements, Advertising Board sanctions and practical compliance steps for businesses.
Legal Framework of Advertising to Children in Turkey
Advertising to children in Turkey is mainly regulated under Law No. 6502 on the Protection of Consumers and the Regulation on Commercial Advertising and Unfair Commercial Practices. These rules apply to commercial advertisements and unfair commercial practices directed at consumers through all media, including television, radio, newspapers, magazines, outdoor advertisements, websites, mobile applications, social media platforms, online marketplaces and video-sharing services.
The Ministry of Trade explains that commercial advertisements must be lawful, clearly identifiable as advertising and compliant with any special rules applicable to the relevant product or service. It also states that these rules apply to advertisements published in all media, including TV, radio, newspapers, magazines, internet, brochures and outdoor media.
The Advertising Board, known in Turkish as the Reklam Kurulu, is the main administrative authority responsible for supervising advertisements and unfair commercial practices. The Board may examine advertisements upon consumer complaints, competitor complaints, institutional applications or on its own initiative. The Ministry of Trade states that the Advertising Board may order suspension, correction, administrative fines and, where necessary, temporary suspension of advertisements.
In child-related advertising, the legal assessment is stricter because children are considered a vulnerable consumer group. The Ministry of Trade’s 2025 announcement specifically states that Article 24 of the Regulation, titled “Advertisements Directed at Children,” includes special provisions for advertisements affecting or directed at children. It also states that advertisements directing children to dangerous situations, encouraging excessive consumption or exploiting children’s developmental level are prohibited.
Therefore, businesses targeting children or families in Turkey should not apply ordinary advertising standards only. They must evaluate the advertisement from the perspective of a child’s developmental level, perception, experience and vulnerability.
Who Is Considered a Child in Advertising Law?
In general legal terminology, a child is a person who has not yet reached adulthood. In advertising law, however, the practical issue is not only the formal age definition. The key question is whether the advertisement is directed at children, likely to affect children, or uses children’s vulnerability as part of a commercial strategy.
An advertisement may be considered child-directed even if it is technically published on a general platform. For example, a toy advertisement placed before animated videos, a snack advertisement using cartoon characters, a mobile game advertisement using child-oriented visuals, or an influencer post targeting family and child audiences may be assessed as advertising affecting children.
The target audience can be identified through several factors. These include the product category, language, visuals, music, characters, platform, broadcast time, influencer audience, hashtags, game mechanics, animation style, colors, pricing structure, in-app purchase design and overall message. A product such as a toy, children’s clothing, school material, mobile game, snack, children’s supplement, educational app or cartoon-related merchandise naturally raises child advertising concerns.
Even where parents are the actual purchasers, the advertisement may still affect children. Many campaigns are designed to make children request products from their parents. Turkish advertising law is sensitive to such indirect pressure because children may influence household purchasing decisions despite not having full economic judgment.
Why Children Need Special Protection in Advertising
Children need special protection because they are still developing cognitively, emotionally and socially. They may not fully understand that advertisements are designed to persuade them. They may believe that claims in advertisements are completely true. They may not recognize hidden sponsorships, affiliate links, product placements or influencer marketing. They may also be more affected by popular characters, games, rewards, peer pressure and emotional messages.
For younger children, the distinction between entertainment and advertising may be especially unclear. A toy unboxing video, a game livestream, a cartoon character promotion, a family influencer post or a branded challenge may appear to be ordinary content. If the commercial purpose is hidden, children may be manipulated without understanding that they are being targeted by advertising.
Children are also more vulnerable to unfair commercial practices. They may be influenced by scarcity messages such as “only today,” “limited edition,” “collect them all,” “do not miss it,” or “your friends already have it.” They may feel social pressure if an advertisement suggests that owning a product makes a child more popular, successful, beautiful, strong or accepted.
The Ministry of Trade has expressly recognized the need to protect children from advertising that exploits their perceptual vulnerabilities and harms their health or safety. This approach reflects a broader consumer protection principle: commercial communication must not abuse the inexperience, lack of knowledge or vulnerability of the target audience.
General Principles for Advertisements Directed at Children
The first principle is truthfulness. Advertisements directed at children must not contain false or exaggerated statements. A product should not be shown as having abilities it does not have. A toy should not be presented as moving, speaking or performing functions that it cannot actually perform. A food product should not be advertised as creating health, strength or intelligence benefits beyond what is legally permitted.
The second principle is clarity. Children must be able to understand the advertisement according to their age and development level. Important information should not be hidden in fast-moving subtitles, small print, complex conditions or technical language. The Ministry of Trade states that exceptions to the main promise and other information included in subtitles or footnotes must be readable and presented at an appropriate speed.
The third principle is non-exploitation. Advertisements must not exploit children’s imagination, trust, lack of experience, emotional dependency or social insecurity. They must not create fear, guilt or pressure. They must not suggest that children will be inferior, excluded or unhappy if they do not buy a product.
The fourth principle is safety. Advertisements must not encourage dangerous behavior. A child should not be shown using a product unsafely, entering dangerous places, imitating risky acts, consuming harmful quantities or acting without adult supervision where supervision is necessary.
The fifth principle is respect for parental authority. Advertisements should not directly pressure children to ask parents to buy a product. They should not undermine parents’ decisions, create conflict within the family or suggest that a good parent must purchase the advertised product.
Misleading Advertising to Children
Misleading advertising is a major risk in child-focused campaigns. Because children have limited experience, even ordinary marketing exaggeration may be problematic when directed at them. A child may interpret fantasy, animation, humor or exaggeration more literally than an adult.
For example, a toy advertisement may be misleading if it uses animation to show the toy performing actions it cannot perform. A game advertisement may be misleading if it shows gameplay that is not part of the actual game. A food advertisement may be misleading if it implies that consuming the product makes children stronger, smarter or more popular. A school-related product may be misleading if it suggests guaranteed academic success.
Misleading omissions are also important. If a product requires batteries, subscription fees, accessories, adult assembly or in-app purchases, this information should not be hidden. If a digital game is free to download but contains paid features essential to gameplay, the advertisement should not create the impression that the full experience is free.
Advertisements should also avoid unrealistic social messages. A campaign suggesting that a child will gain friends, popularity, athletic success or parental approval by purchasing a product may exploit children’s emotional vulnerability.
Advertising, Games and In-App Purchases
Mobile games and online games are among the most important child advertising environments. Children may be exposed to rewarded ads, in-game product placements, loot boxes, virtual currencies, character skins, limited-time offers and in-app purchases. These practices can blur the line between play and commercial persuasion.
A game may advertise an item as necessary to progress, create urgency through countdown timers, or encourage repeated purchases through reward mechanics. If the design pressures children into spending money or asking parents for payment, it may raise consumer protection concerns.
In-app purchase advertisements should be clear. Children should not be misled into thinking that virtual items are free if payment is required. The real-money cost of virtual currency should be understandable. If a game uses randomized rewards, the advertisement should not mislead children about the likelihood of obtaining valuable items.
Parents should also receive clear information. If an app is marketed as free but relies heavily on in-app purchases, this should be visible before download. Subscription renewals, trial periods and paid upgrades should not be hidden behind child-friendly visuals or confusing interface design.
Targeted Advertising to Children and Personal Data
One of the most important developments in Turkish advertising law is the prohibition of personal data-based profiling for targeted advertising directed at children. In 2026, the Ministry of Trade announced that targeted advertising practices based on analyzing consumers’ online behavior and personal data were regulated. Advertisers may generally conduct targeted advertising if they provide direct and easily accessible information about the criteria used and how those criteria can be changed; however, targeted advertising directed at children through profiling based on personal data was expressly prohibited.
This is a major rule for digital platforms, games, educational apps, video-sharing services, toy brands, children’s food brands, family influencers and e-commerce businesses. Businesses should not create behavioral advertising profiles of children based on browsing history, interests, location, app usage, video watching behavior, search history, purchase behavior or engagement data.
The rule is especially important because children may not understand how their data is being used. A child may not know that watching certain videos, clicking certain characters or playing certain games can result in personalized ads. Therefore, Turkish law now creates a strong child-protection barrier against profiling-based targeted advertising.
Businesses should review all advertising technologies used in child-facing digital services. This includes cookies, pixels, mobile SDKs, analytics tools, retargeting systems, custom audiences, lookalike audiences, device identifiers and third-party ad networks.
Cookies and Children’s Data
Targeted advertising often depends on cookies and similar tracking technologies. In Turkey, the Personal Data Protection Board has stated that strictly necessary cookies may be used without explicit consent where they are required for a website or application to function, but advertising, marketing and performance cookies require explicit consent if no other legal processing condition applies. The Board also emphasized an opt-in mechanism where such non-essential cookies should not run by default before the user’s active consent.
This principle is important for all users, but it becomes more sensitive where children are involved. Child-facing platforms should not use advertising or marketing cookies in a way that profiles children. Even where a platform seeks parental consent for certain data processing, the separate advertising-law prohibition on profiling-based targeted advertising directed at children must be considered.
A child-friendly website or app should use privacy-protective default settings. It should avoid third-party advertising trackers, behavioral ad cookies, unnecessary analytics tools and cross-site retargeting technologies. If data processing is necessary for safety or core functionality, it should be limited to what is necessary and clearly explained to parents or legal guardians.
Social Media Influencers and Child Audiences
Influencer marketing is one of the most difficult areas for child advertising compliance. Children may follow YouTubers, TikTok creators, gaming streamers, toy reviewers, family influencers, cartoon-related accounts and young celebrities. Sponsored content may appear as entertainment, daily routine, game play, challenge, unboxing, review or personal recommendation.
Turkish advertising law prohibits hidden advertising. The Ministry of Trade states that advertising must be clearly identifiable, and that hidden advertising through all communication channels is prohibited. In 2026, the Ministry also announced that where a social media influencer receives a benefit such as payment, discounted goods or services, or event participation, posts must clearly indicate their advertising nature with expressions such as “advertisement” or “promotion.”
When the audience includes children, disclosure must be even clearer. A vague hashtag hidden at the end of a caption is not enough. The disclosure should be visible, simple and understandable. In videos, the influencer should communicate the advertising nature in a way that child viewers can understand. In live streams, disclosure may need to be repeated because viewers may join at different times.
Brands should also ensure that influencers do not pressure children to buy products, use discount codes, join campaigns, participate in paid challenges or persuade parents. Influencer contracts should include child-protection clauses, prohibited claims, disclosure rules and content approval procedures.
Toy Advertising and Product Demonstrations
Toy advertising is one of the classic areas of child advertising law. Toys often involve imagination, fantasy and play. Advertisers may use animation, sound effects, special effects and storytelling. However, the advertisement must not misrepresent what the toy actually does.
A toy should not be shown moving independently if it cannot do so. Accessories should not be shown as included if they are sold separately. The size of the toy should not be exaggerated. If batteries are required, this should be clear. If assembly is needed, the advertisement should not create the impression that the child can immediately use the toy without assistance.
Collectible toys and limited-edition products require special care. Advertisements should not pressure children to “collect all” products in a way that encourages excessive consumption. Campaigns should not create anxiety that the child will miss out or be socially excluded.
Toy advertisements should also consider safety. Children should not be shown using toys in unsafe environments, with unsafe objects or in a manner contrary to age recommendations. If a product is suitable only for certain age groups, the advertisement should not target younger children.
Food Advertising to Children
Food advertising directed at children is sensitive because it may affect eating habits, health perceptions and family purchasing decisions. Children may be influenced by cartoon characters, games, toys, collectible promotions, colorful packaging and celebrity endorsements.
Food advertisements should not mislead children about nutritional value. They should not suggest that a food product makes children stronger, smarter, more successful or more popular unless such claims are legally permitted and substantiated. They should not encourage excessive consumption or unhealthy eating patterns.
If a food advertisement uses gifts, games or toys, the commercial message should remain clear. Children should not be induced to buy or ask for a product primarily because of a toy or promotional reward without understanding the product itself.
Food supplement advertisements directed at children or parents require additional care. The Ministry of Trade has announced that food supplements may not be advertised in a way that creates the impression that they replace foods consumed as part of normal nutrition. This is important for children because parents may be anxious about nutrition, immunity, development and school performance. Advertisements should not exploit parental fear or suggest that supplements replace a balanced diet.
Health and Wellness Advertising Involving Children
Health-related advertising involving children is highly sensitive. Products such as vitamins, supplements, hygiene products, wellness products, medical devices and healthcare services may be advertised to parents or families. However, these advertisements must not exploit fear, illness or parental anxiety.
Risky claims include “protects your child from disease,” “guarantees healthy growth,” “essential for intelligence,” “prevents infection,” “improves school performance,” or “every child needs this.” Such statements may be misleading if they are not legally permitted and strongly supported.
Advertisements should not make parents feel guilty or irresponsible for not purchasing a product. They should not imply that a child’s health, success or development depends on the advertised product unless that implication is legally and scientifically justified.
The Ministry of Trade’s consumer guidance states that advertisements for medicines, medical devices, health services, foods, food supplements, cosmetics and similar regulated products must also comply with the relevant sector-specific advertising and promotion provisions. Therefore, child-related health advertising should always be reviewed under both general advertising law and product-specific rules.
Educational Products and Success Claims
Educational products, language courses, online learning platforms, tutoring services, exam preparation materials and child development apps frequently use advertising directed at parents and children. These advertisements often promise improvement, success, confidence or future advantage.
Advertisements should not guarantee academic success unless the claim is objectively provable. Statements such as “guaranteed exam success,” “your child will become fluent in three months,” “increases intelligence,” “makes your child the best in class,” or “scientifically proven to improve IQ” may be risky.
Educational advertising should provide realistic information about the service, content, duration, method, age suitability and expected learning outcomes. It should not exploit parental anxiety about exams, competition or future opportunities. If a success rate is advertised, the methodology, sample group and conditions should be clear.
Digital education platforms should also avoid profiling-based targeted advertising directed at children. If a platform collects learning behavior data, it should not use that data to target children with personalized commercial ads.
Advertising and Parental Pressure
One of the key concerns in child advertising is “pester power,” meaning advertisements that encourage children to pressure their parents or caregivers to buy a product. Turkish consumer protection principles prohibit the exploitation of children’s lack of experience and developmental vulnerabilities. The Ministry of Trade’s 2025 announcement also emphasizes that advertising activities encouraging excessive consumption or exploiting children’s developmental level are prohibited.
Advertisements should not directly tell children to ask their parents to buy a product. They should not suggest that parents who do not buy the product are unfair, uncaring or outdated. They should not create conflict between children and parents.
Risky expressions include:
“Tell your parents to buy it now.”
“Do not let your friends have it before you.”
“Convince your family today.”
“Every good parent chooses this.”
“You cannot be part of the game without it.”
“Your friends will love you more with this.”
Such messages may exploit children’s emotional dependency and social sensitivity.
AI-Generated Advertising and Children
Artificial intelligence introduces new risks in advertising to children. Brands may use AI-generated characters, virtual influencers, synthetic voices, personalized stories, game characters or deepfake-like visuals. Children may find these characters especially persuasive and may not understand that they are artificial.
The 2026 amendments introduced disclosure requirements for advertisements using AI-generated digital characters that cannot be distinguished from real humans. Such use must be clearly, understandably and distinguishably disclosed. The amendments also prohibit advertisements using the AI-generated digital copy of a real person in a way that creates the impression that the person personally experienced or recommended a product or service.
In child-directed advertising, AI-generated characters should not be used to manipulate trust. A virtual child, teacher, doctor, cartoon friend or game character should not create false product experiences. AI-generated content should not be personalized based on a child’s behavioral data for targeted advertising.
Businesses should also consider whether children can understand AI disclosures. A technical statement may not be enough. The disclosure should be simple and age-appropriate.
Hidden Advertising in Children’s Content
Hidden advertising is particularly harmful in children’s content because children may not understand sponsorship. A toy review, game video, family vlog, cartoon segment or challenge video may be commercial even if it appears to be entertainment.
The Ministry of Trade states that advertisements must be clearly identifiable and that hidden advertising is prohibited. This rule applies strongly to child-facing content. If a brand provides free toys to a child influencer channel, sponsors a game video, pays a family account or gives affiliate codes, the commercial relationship should be disclosed.
The disclosure should be clear to both parents and children. If the content is primarily watched by children, the disclosure should not rely only on written hashtags that young children may not read or understand. Video and audio disclosure may be more appropriate depending on the platform.
Brands should monitor child influencer content carefully. Children appearing in advertisements may themselves need special protection, and the content should not exploit child performers, viewers or family relationships.
Advertising Board Sanctions
The Advertising Board has broad powers to sanction unlawful advertisements. The Ministry of Trade’s 2025 child-focused announcement states that, in child-related advertising violations, the Board may impose advertisement suspension, correction by the same method, administrative fines and, where necessary, temporary suspension for up to three months. If the violation occurs online, access blocking may also be decided.
The Ministry’s general consumer information page also states that the Advertising Board may determine advertising principles, protect consumers against unfair commercial practices, conduct examinations and impose sanctions including suspension, correction, administrative fines and temporary suspension.
Administrative risk should not be underestimated. Child-related advertising is a reputationally sensitive area. A company sanctioned for exploiting children may suffer serious public reaction, especially if the advertisement involves health, safety, digital manipulation, excessive consumption or hidden sponsorship.
Businesses should therefore conduct pre-publication review for any advertisement likely to reach children. Legal review should include not only the text but also the visuals, platform, audience targeting, data practices, influencer relationship, product category and overall child perception.
Consumer Complaints and Evidence
Consumers, institutions and competitors may file complaints against unlawful advertisements, and the Advertising Board may also initiate ex officio examinations. The Ministry of Trade explains that complaints may be made by consumers, institutions, organizations and rival firms, and that applications can be made in writing or electronically.
In digital advertising, evidence may include screenshots, videos, links, influencer posts, story recordings, app screens, game mechanics, ad targeting explanations, cookie banners, product pages and payment screens. Parents may complain if they believe an advertisement manipulated their child, encouraged excessive spending or used hidden sponsorship.
Businesses should preserve records showing compliance. This may include advertising approvals, scripts, disclosures, age-targeting settings, data protection assessments, influencer contracts, screenshots, product evidence, campaign dates and records of corrective action.
Practical Compliance Checklist for Advertising to Children in Turkey
Businesses should apply a strict compliance checklist before publishing advertisements directed at or likely to affect children.
First, determine whether the advertisement is child-directed or likely to be seen by children.
Second, assess the child’s likely perception according to age, development level and experience.
Third, avoid misleading product demonstrations, exaggerated claims and unrealistic visuals.
Fourth, do not encourage unsafe behavior, excessive consumption or social pressure.
Fifth, do not directly pressure children to persuade parents.
Sixth, ensure that the advertising nature is clear, especially in influencer content, games, videos and social media.
Seventh, avoid profiling-based targeted advertising directed at children.
Eighth, review cookies, SDKs, pixels and third-party ad tools used in child-facing digital services.
Ninth, avoid health, nutrition or development claims unless legally permitted and substantiated.
Tenth, check sector-specific rules for food, supplements, cosmetics, healthcare, toys, games and education products.
Eleventh, avoid manipulative in-app purchase designs, fake urgency and confusing virtual currency systems.
Twelfth, ensure AI-generated characters or digital content are disclosed where required and do not exploit children’s trust.
Thirteenth, preserve all compliance documents, approvals, screenshots and campaign records.
Best Practices for Businesses
A good child advertising compliance program should involve legal teams, marketing teams, product teams, data protection officers, agencies and platform managers. Child protection should not be treated as a final legal check; it should be part of campaign design from the beginning.
Businesses should create internal rules for child-directed advertising. These rules should define prohibited messages, required disclosures, data protection limits, influencer requirements, game advertising standards, product demonstration rules and approval procedures.
Agencies should receive clear instructions. Influencers should be contractually required to disclose sponsorship and avoid child-manipulative messages. Digital teams should avoid behavioral targeting of children and should disable advertising trackers in child-facing environments where necessary.
A child-focused campaign should be tested from the perspective of a child, not only from the perspective of an adult lawyer or marketer. If the advertisement may make a child feel fear, pressure, exclusion, urgency or unrealistic desire, it should be revised.
Conclusion
Advertising to children in Turkey is subject to strict legal limits because children require special protection as consumers. Turkish law allows businesses to advertise products and services, but advertisements affecting children must be honest, clear, fair and responsible. They must not exploit children’s lack of experience, developmental vulnerabilities, emotional dependency or limited understanding of commercial persuasion.
The Ministry of Trade has emphasized that advertisements targeting children and exploiting their perceptual vulnerabilities are closely monitored. The Advertising Board may impose suspension, correction, administrative fines, temporary suspension and, in online cases, access blocking measures for violations.
Digital advertising has made child protection more complex. Children now encounter commercial messages in games, social media, influencer content, video platforms, mobile apps and e-commerce environments. The 2026 amendments introduced a particularly important rule by prohibiting targeted advertising directed at children through profiling methods based on personal data.
For businesses operating in Turkey or targeting Turkish consumers, child advertising compliance should be treated as a high-priority legal and ethical responsibility. A lawful campaign should not only avoid false claims; it should also respect children’s development, safety, privacy and family relationships.
The safest approach is simple: do not manipulate children, do not hide advertising, do not profile children for targeted ads, do not pressure them into consumption and do not exploit parental anxiety. Advertising to children must be transparent, age-appropriate, fair and protective. In the Turkish market, responsible child advertising is not only a legal requirement; it is also an essential part of consumer trust and corporate responsibility.
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