Subscription-based business models have become one of the most common ways for startups to generate predictable recurring revenue.

A startup may charge customers:

• monthly,
• quarterly,
• annually,
• or according to another recurring billing cycle.

This model is particularly common for:

• SaaS platforms,
• mobile applications,
• digital content services,
• online education platforms,
• fitness applications,
• gaming services,
• cloud software,
• artificial intelligence tools,
• music and video platforms,
• cybersecurity products,
• meal and product subscription services,
• and membership-based marketplaces.

From a commercial perspective, automatic renewal can be extremely attractive.

Instead of requiring the customer to manually purchase the service every month, the subscription continues and payment is collected automatically.

However, automatic renewal creates an important legal question in Turkey:

Can a startup automatically renew a consumer’s subscription and continue charging the customer’s credit card without obtaining a new approval?

The answer depends primarily on the type of subscription.

Under Turkish consumer law, a critical distinction must be made between:

fixed-term subscription agreements

and

indefinite-term subscription agreements.

For consumer contracts, Turkish law expressly prohibits inserting a clause into a fixed-term subscription agreement stating that the agreement will automatically extend for another equivalent period.

Article 52 of Law No. 6502 on Consumer Protection provides that a fixed-term subscription agreement cannot contain a provision automatically extending the contract for the originally agreed duration. The contract may be extended only if, after the original subscription agreement has been concluded and before it expires, the consumer requests or approves the extension.

The Subscription Agreements Regulation contains the same rule. It further provides that if the seller or service provider continues supplying goods or services after expiry without obtaining the consumer’s explicit request or approval, the provider cannot demand payment for those goods or services.

The Ministry of Trade confirmed this position again in its 15 June 2026 Subscription Agreements Consumer Guide. The Ministry expressly states that fixed-term subscriptions cannot be extended or renewed without the consumer’s request or approval before the existing term expires. It also confirms that where service continues after expiry without such approval, no payment may be demanded from the consumer.

For Turkish startups, this means that the familiar clause:

“Your 12-month subscription will automatically renew for another 12 months unless you cancel.”

can create serious problems in a B2C subscription agreement.

The legal analysis is different, however, where the subscription is genuinely established for an indefinite period and continues until the consumer terminates it.

This article explains whether automatic subscription renewal is legal in Turkey, how Turkish consumer protection law applies to startup subscription models, how fixed-term and indefinite subscriptions differ, when recurring card payments can be collected, how cancellation mechanisms should operate and what startups should do to build a legally compliant subscription system.

What Is a Subscription Agreement Under Turkish Law?

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

This concept covers much more than traditional utility subscriptions.

The Ministry of Trade’s June 2026 consumer guidance specifically identifies examples including:

• electricity,
• water,
• natural gas,
• telecommunications,
• internet,
• digital broadcasting platforms,
• online education,
• video services,
• music services,
• computer games,
• software,
• parking services,
• diet packages,
• and recurring pet-food deliveries.

Accordingly, a modern technology startup providing software or digital content through recurring payments can fall squarely within the Turkish subscription-contract framework when it contracts with consumers.

The fact that the business calls the contract a:

• Membership Agreement,
• Premium Plan,
• SaaS Terms,
• User Agreement,
• Pro Membership,
• Subscription Terms,
• or Service Agreement

does not determine whether consumer subscription rules apply.

The substance of the relationship is more important than the title.

The First Critical Distinction: B2C or B2B?

Before analysing automatic renewal, the startup should determine whether the customer is legally a consumer.

Under Law No. 6502, consumer protection rules apply to persons acting for purposes outside their commercial or professional activities.

The Ministry of Trade expressly confirmed in its 2026 subscription guide that subscriptions obtained for commercial or professional purposes fall outside the consumer protection regime of Law No. 6502.

This creates a fundamental difference between:

B2C Subscription

Example:

An individual purchases a personal fitness application subscription.

Consumer law applies.

B2B Subscription

Example:

A corporation purchases enterprise cybersecurity software for its employees.

The transaction is made for professional or commercial purposes.

Law No. 6502 generally does not govern that relationship.

Therefore, a subscription startup should never assume that one contract structure is appropriate for every customer.

Automatic Renewal in B2C Contracts Is Strictly Regulated

The strongest rule concerns fixed-term consumer subscription agreements.

Suppose a startup offers:

Premium Plan – 12 months – TRY 6,000

The contract states:

“The agreement will automatically renew for another 12 months unless the consumer cancels at least seven days before expiration.”

This is exactly the type of provision that Turkish consumer subscription law restricts.

Article 52(3) of Law No. 6502 provides that fixed-term subscription agreements cannot contain provisions stating that the contract will extend for the originally agreed period.

An extension is possible only if:

1. the subscription agreement has already been concluded;
2. the original term has not yet expired;
3. the consumer later requests the extension or gives approval.

Therefore, consent obtained merely through the original contract may not satisfy the statutory requirement for extension of a fixed-term consumer subscription.

Why Is the Timing of Consent Important?

The statute intentionally distinguishes between:

consent given when the original contract is signed

and

consent given later to extend the subscription.

Suppose a consumer purchases a 12-month application subscription on 1 September 2026.

The startup places the following clause in the initial contract:

“By subscribing, you agree that your subscription will automatically renew every year indefinitely.”

Under the Turkish fixed-term subscription rule, the startup cannot simply rely on that original provision to extend the fixed term automatically.

Instead, after the subscription has been established and before it expires, the consumer must later:

• request continuation;
• or provide approval for extension.

This structure protects consumers from forgetting about long-term subscriptions and unexpectedly becoming bound for another full contractual period.

Automatic Renewal and Automatic Payment Are Not the Same Thing

This distinction is extremely important.

There are actually two separate legal questions:

Question One:
Does the underlying subscription contract legally continue?

Question Two:
Can the startup automatically collect the next payment?

The existence of a stored payment card does not itself create a right to renew an expired fixed-term subscription.

Suppose a customer entered card information when purchasing the first twelve months.

The fact that the startup still possesses a valid payment token does not automatically mean:

“The consumer approved a second twelve-month contract.”

The company must first establish that the underlying subscription legally continues or has been validly renewed.

Only then should recurring payment be collected in accordance with the relevant authorisation and payment-service arrangements.

In other words:

payment technology cannot cure an invalid contractual renewal.

What Happens If the Startup Continues Service Without Approval?

The Subscription Agreements Regulation contains an unusually strong consequence.

If a fixed-term subscription expires and the provider continues supplying the relevant goods or services without obtaining the consumer’s explicit request or approval, the provider cannot demand payment for the continued service.

The Ministry of Trade restated this rule in its June 2026 consumer guide.

Consider the following example.

Consumer purchases:

Annual AI Writing Plan

Period:

1 January 2026 – 31 December 2026.

The startup obtains no renewal approval.

On 1 January 2027, the startup automatically extends access for another year and charges the customer’s card.

The consumer may argue that:

• the fixed-term contract was not validly extended;
• no renewal approval was given;
• and the startup had no basis to demand payment for the continued service.

For subscription businesses, this can create:

• refund claims,
• consumer complaints,
• chargebacks,
• administrative sanctions,
• and reputational damage.

Is an Indefinite Subscription Different?

Yes.

A genuine indefinite-term subscription does not have a predetermined expiry date requiring repeated renewal.

For example:

“The subscription begins on 1 September and continues on a monthly basis until terminated by either party in accordance with the agreement.”

In this structure, the contract is not necessarily being “renewed” every month.

Instead, there is one ongoing contractual relationship under which monthly payments become due periodically.

This distinction can be crucial.

The statutory prohibition relates specifically to automatic extension provisions in fixed-term subscription agreements.

An indefinite-term subscription naturally continues until termination.

However, this does not mean startups can disguise a fixed-term agreement as an indefinite subscription merely to avoid consumer protection rules.

The actual economic and contractual structure will matter.

Monthly Subscription Models

Many startups offer:

TRY 399 per month, cancel anytime.

The agreement begins when the consumer subscribes and continues until cancellation.

This structure is commercially different from:

TRY 4,788 for a fixed twelve-month agreement that automatically renews for another twelve months.

The first model is more naturally structured as an indefinite subscription with monthly billing.

The second is a fixed-term subscription with automatic extension.

The legal treatment can therefore differ significantly.

For consumer startups seeking recurring revenue, a properly structured indefinite subscription may often be easier to manage than a fixed-term contract containing automatic annual renewal.

Consumers Can Terminate Indefinite Subscriptions

Law No. 6502 provides strong termination rights for consumers.

A consumer may terminate:

• an indefinite-term subscription;
• or a fixed-term subscription lasting longer than one year

at any time without providing a reason and without paying a penalty, subject to special rules concerning commitment-based subscriptions and other applicable legislation.

The Subscription Agreements Regulation contains the corresponding termination framework.

This means a startup offering an indefinite recurring digital subscription must not create artificial obstacles preventing consumers from leaving.

Cancellation Cannot Be Harder Than Subscription

This is one of the most important practical requirements for digital startups.

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

The Ministry of Trade’s 2026 guidance gives a very clear example:

If a consumer subscribed online, the company cannot force the consumer to visit a physical branch or send a notarised notice merely to cancel.

The Ministry states that termination can generally be communicated through:

• writing;
• SMS;
• email;
• internet;
• another durable medium;
• and, where appropriate safeguards exist, recorded telephone channels.

For a mobile application startup, this means that an onboarding flow taking twenty seconds should not be paired with a cancellation flow requiring:

• telephone calls,
• printed forms,
• identity documents,
• postal delivery,
• and multiple customer service approvals.

A deliberately difficult cancellation process can create consumer-law risk.

“Dark Patterns” in Subscription Cancellation Are Dangerous

Although the legal analysis should always be based on the applicable legislation, startup interface design can itself create risk.

Examples of problematic practices may include:

• hiding the cancel button;
• repeatedly redirecting the consumer away from cancellation;
• using misleading labels;
• requiring irrelevant surveys before termination;
• providing only a telephone number that is rarely answered;
• requiring a consumer to contact multiple departments;
• or presenting a large “Continue Membership” button beside an almost invisible cancellation link.

Consumer law increasingly examines not only the written contract but also how digital interfaces influence consumer decisions.

A legally compliant subscription model should make:

signing up clear

and

cancelling reasonably accessible.

How Quickly Must a Startup Process Cancellation?

The Ministry of Trade’s June 2026 guidance states that the provider must generally complete a consumer’s termination request within seven days after receiving it.

Where cancellation is not completed within the legally required period, the provider cannot continue charging the consumer after expiration of that period even if the consumer continues technically accessing the service.

This is highly important for automated subscription platforms.

Suppose a consumer submits a cancellation request on 1 October.

The startup ignores it until 1 November.

The platform continues charging the consumer.

The company’s billing automation does not excuse the failure.

Subscription systems should therefore ensure that legally valid cancellation requests are automatically or operationally reflected in billing systems without unnecessary delay.

Refunds After Cancellation

The Ministry of Trade’s 2026 guidance also states that, following termination, the provider must generally return within 15 days the portion of prepaid fees corresponding to goods or services that have not yet been supplied, together with applicable deposits or security amounts.

For digital startups, this can matter where customers pay:

• six months in advance;
• twelve months in advance;
• or another prepaid amount.

The precise refund calculation should be compatible with the applicable subscription structure and statutory rules.

What About Commitment-Based Subscriptions?

A taahhütlü abonelik, or commitment-based subscription, has additional rules.

These arrangements commonly involve the customer agreeing to remain subscribed for a particular period in exchange for:

• a price discount;
• a free or discounted product;
• an installation benefit;
• or another commercial advantage.

Early termination may create legally permissible repayment or cancellation charges calculated according to the applicable rules.

However, a commitment period should not be confused with automatic renewal.

The fact that the consumer committed to the first twelve months does not automatically mean they have committed to another twelve months after expiry.

The startup should distinguish:

subscription relationship

from

commitment period

and

renewal approval.

The Ministry’s 2026 guidance itself notes that a commitment may expire while the underlying subscription relationship continues, depending on the structure and contract.

Free Trials Create Another Automatic Billing Risk

Many startups use a model such as:

“7 days free – then TRY 499 per month.”

This can be lawful if the consumer is clearly informed that:

• the trial converts into a paid subscription;
• when the first payment will be collected;
• how much will be charged;
• how frequently payments recur;
• how the subscription can be terminated.

The startup should not design the free trial so that the consumer reasonably believes:

“This is completely free and ends automatically”

while the company secretly converts it into a paid recurring relationship.

Transparency is essential.

Where the contract is concluded online, distance-contract rules may also require the consumer to receive clear pre-contractual information before becoming financially obligated.

Distance Contract Rules Also Apply to Many Startup Subscriptions

An online subscription purchased through:

• a website;
• mobile application;
• online platform;
• or other remote communication system

can qualify as a distance contract.

Under the Distance Contracts Regulation, consumers must receive prescribed information before becoming bound.

For internet transactions, specified information must be displayed clearly immediately before the consumer assumes a payment obligation, and the consumer must confirm that the required pre-contractual information has been received.

Therefore, a subscription checkout page should clearly show matters such as:

• service characteristics;
• provider identity;
• subscription price;
• recurring payment structure;
• contractual duration;
• termination conditions;
• and applicable withdrawal information.

The startup should not hide the recurring nature of payment several screens away in a long Terms of Use document.

A Button Saying “Start Free Trial” May Need Additional Information

Suppose the customer sees:

START FREE TRIAL

but the interface does not clearly state:

“TRY 599/month beginning seven days from today unless cancelled.”

The startup may face problems proving that the customer knowingly assumed the recurring financial obligation.

A safer interface would communicate the commercial terms directly around the acceptance mechanism.

For example:

7-day free trial. TRY 599/month afterwards. Cancel anytime before the trial expires to avoid the first charge.

The exact wording should reflect the legal and commercial structure.

Automatic Renewal Notices Are Good Practice Even Where Not Strictly Required

Startups should consider sending advance renewal notifications.

For example:

“Your annual subscription expires on 30 September. If you would like to continue for another year, please confirm renewal.”

For a fixed-term consumer subscription, the confirmation mechanism is particularly important because the startup needs a post-contract request or approval before extension.

For indefinite subscriptions, advance notifications can still improve:

• transparency;
• customer satisfaction;
• chargeback prevention;
• and evidence.

The system should preserve records showing:

• when the notice was sent;
• what terms were shown;
• whether the consumer approved;
• date and time of approval;
• renewal price;
• and applicable contract version.

Renewal Approval Should Be Provable

If a dispute arises, the startup may need to show that the consumer actually approved the renewal.

Therefore, renewal records should ideally include:

• customer account;
• date;
• timestamp;
• approved term;
• renewal duration;
• renewal price;
• acceptance mechanism;
• and relevant version of the subscription conditions.

A vague internal note saying:

“User probably accepted renewal”

is not a strong compliance system.

Pre-Ticked Renewal Boxes Are Risky

A startup should be cautious about presenting renewal approval through a pre-selected checkbox.

For example:

☑ Renew my subscription automatically for another year.

If the user is required to manually untick the box, the startup may later face questions regarding whether renewal reflected an actual, informed consumer decision.

A more defensible mechanism requires affirmative action.

For example:

☐ I want to extend my subscription for another twelve months at TRY 6,000.

The consumer actively selects the option.

This produces much clearer evidence of approval.

Can the Startup Change the Renewal Price?

Price increases create another legal issue.

Suppose:

Year One price: TRY 1,000.

Renewal price: TRY 3,000.

Even where renewal approval can lawfully be obtained, the customer should know the price that will apply.

Approval to renew the service should not automatically be treated as consent to an undisclosed future price.

For fixed-term renewals, the consumer should be given sufficient information about:

• the new price;
• renewal duration;
• service scope;
• and material contractual changes

before approving extension.

For indefinite subscriptions, unilateral price-change provisions should also be reviewed under consumer unfair-terms principles and the applicable contract.

Unfair Contract Terms Can Be Invalid

Consumer contracts are subject to unfair-term control.

A startup cannot avoid consumer legislation simply by putting an aggressive clause in standard Terms of Use.

For example:

“The startup may increase the subscription price by any amount at any time without informing the customer.”

or:

“The startup can extend the subscription for any duration it chooses and charge any payment method previously used.”

may raise serious issues.

A contractual clause should remain:

• transparent;
• proportionate;
• and consistent with mandatory consumer legislation.

General Terms Rules Also Matter in B2B Subscription Agreements

Although commercial subscriptions fall outside Law No. 6502, this does not mean standard contract terms face no legal controls whatsoever.

The Turkish Code of Obligations contains rules governing general transaction conditions.

Article 20 defines these as contractual provisions prepared unilaterally in advance for repeated use in multiple similar contracts.

Under Article 21, terms contrary to the counterparty’s interests generally become part of the contract only if the drafting party clearly informs the other party of their existence, provides an opportunity to learn their content and the counterparty accepts them. Unexpected provisions foreign to the nature of the agreement may be treated as unwritten.

Article 25 further prohibits general transaction conditions that, contrary to good faith, disadvantage the counterparty or aggravate its position.

Therefore, even in B2B SaaS contracts, automatic renewal clauses should be:

• visible;
• understandable;
• commercially reasonable;
• and drafted consistently with general contract law.

B2B Automatic Renewal Can Generally Be Structured Contractually

Commercial parties have considerably more contractual freedom than consumer relationships.

A B2B SaaS agreement may, for example, provide:

“The Initial Term is twelve months. Thereafter, the Agreement will automatically renew for successive twelve-month periods unless either party gives written notice of non-renewal at least 30 days before expiry.”

Such clauses are common in enterprise SaaS contracts.

However, the startup should still consider:

• how the clause is presented;
• whether it forms part of the contract;
• notice periods;
• unilateral price increases;
• termination rights;
• and general transaction conditions.

A clause buried in an obscure hyperlink and designed to surprise the corporate customer can still create disputes.

App Store Subscriptions

Mobile startups frequently rely on:

• Apple App Store;
• Google Play;
• or another application marketplace

to manage recurring subscriptions.

The startup may assume:

“The app store handles billing, so Turkish consumer law does not concern us.”

That assumption is too broad.

The distribution platform may control:

• technical subscription creation;
• payment collection;
• refund procedures;
• and cancellation interfaces.

However, the underlying legal relationship between the startup, platform and consumer must still be examined.

A startup should determine:

• who legally sells the subscription;
• who appears on the invoice;
• who controls renewal;
• who receives cancellation notices;
• who provides the digital service;
• and which party is responsible for consumer disclosures.

The app store’s global terms do not automatically eliminate mandatory Turkish consumer rights.

Card-on-File Billing

Startups also commonly store a payment token allowing recurring card charges.

The existence of a token should be treated as a payment mechanism, not as unlimited permission.

The startup should maintain evidence showing that the customer understood:

• recurring payment would occur;
• frequency;
• amount or calculation method;
• how to cancel;
• and how long the subscription continues.

If a consumer believes that a payment was processed without their knowledge or approval, the Ministry’s June 2026 guidance notes that cardholders may also use the dispute mechanisms available under Turkish card-payment legislation.

This creates additional commercial risk for startups because unlawful or poorly documented renewals can result not only in consumer disputes but also in payment chargebacks.

Automatic Renewal Can Create Administrative Fines

Violations of subscription rules can result in administrative penalties.

For 2026, the Ministry of Trade increased the relevant administrative fine to TRY 3,973 per non-compliant contract or transaction for various subscription-law breaches, including:

• failure to comply with information and approval obligations;
• violation of the prohibition on automatic extension of expired subscription agreements;
• unlawful changes in commitment terms;
• and failure to process termination requests within the prescribed period.

For a startup with only ten affected customers, the amount may appear manageable.

For a platform with:

• 10,000;
• 100,000;
• or one million

subscriptions, per-transaction violations can become extremely serious.

The risk is therefore scalable in the same way as the startup’s revenue.

Refund Exposure Can Be Larger Than the Fine

Administrative penalties are not necessarily the largest financial problem.

Suppose 100,000 consumers are unlawfully charged TRY 1,000 because annual subscriptions were automatically renewed without proper approval.

Potential refund exposure could reach:

TRY 100 million

before considering:

• administrative fines;
• litigation;
• chargebacks;
• customer support costs;
• and reputational damage.

Subscription compliance should therefore be treated as a core product-design issue.

Subscription Compliance Should Be Built Into the Software

A startup should not rely entirely on manual legal processes.

The product itself can automate compliance.

For example, the system can:

• identify approaching fixed-term expiry dates;
• send renewal notices;
• request affirmative approval;
• store renewal evidence;
• prevent billing without valid approval;
• provide one-click cancellation;
• automatically stop future invoices;
• generate refund calculations;
• and preserve historical contract versions.

This is a good example of legal compliance by design.

The best subscription agreement will not protect the startup if the software ignores it.

The Billing System Should Know the Contract Type

The startup’s database should ideally distinguish between:

Fixed-Term Subscription

and

Indefinite Subscription.

It may also record:

• subscription start date;
• expiry date;
• renewal approval status;
• billing cycle;
• cancellation status;
• cancellation effective date;
• refund amount;
• renewal price;
• and customer category.

Without such information, the company can accidentally apply the same automated billing logic to legally different subscription relationships.

A Practical Fixed-Term Renewal Flow

For a Turkish B2C fixed-term digital subscription, a compliant process may look conceptually like this:

The customer purchases a twelve-month service.

The system records:

Start: 1 September 2026
End: 31 August 2027

Before expiry, the startup sends:

“Your subscription ends on 31 August 2027. If you wish to continue for another year at TRY X, please approve renewal.”

The consumer actively approves.

The company stores:

• approval date;
• subscription duration;
• renewal price;
• acceptance record.

The new period then begins.

This is much safer than relying exclusively on a clause accepted twelve months earlier.

A Practical Indefinite Subscription Flow

An indefinite monthly subscription could instead state:

“Your membership begins when you subscribe and continues until cancelled. The monthly subscription price is TRY X and will be charged each billing period in accordance with the agreement.”

The customer can terminate through the same digital environment.

The relationship continues because it is indefinite, not because a new fixed contract is automatically created every month.

The consumer’s termination rights and applicable price-change rules must still be respected.

Startup Subscription Checklist

Before launching an automatically billed product in Turkey, founders should ask:

1. Is the customer a consumer or business?
2. Is the subscription fixed-term or indefinite?
3. If fixed-term, does the contract contain automatic extension language?
4. Is post-contract renewal approval obtained?
5. Is renewal approval obtained before expiry?
6. Can the startup prove approval?
7. Is the renewal price clearly disclosed?
8. Is the renewal duration clearly disclosed?
9. Are recurring payments clearly explained?
10. Is a card stored for future billing?
11. Does payment authorisation match the contractual relationship?
12. Is the subscription purchased online?
13. Do distance-contract rules apply?
14. Is pre-contractual information displayed before payment?
15. Does the consumer actively confirm the required information?
16. Is there a free trial?
17. Is conversion from free to paid clearly disclosed?
18. When is the first paid charge made?
19. Can the customer cancel digitally?
20. Is cancellation harder than signup?
21. Does cancellation require unnecessary telephone calls?
22. Are cancellation requests processed within the required period?
23. Does billing stop after cancellation?
24. Are unused prepaid amounts refunded where required?
25. Can refunds be completed within the statutory period?
26. Are price increases properly communicated?
27. Are standard terms potentially unfair?
28. Are app-store subscriptions treated consistently with Turkish law?
29. Are B2B and B2C contracts separated?
30. Are automatic renewal records preserved?
31. Can customer service view renewal approval?
32. Can the startup respond to chargebacks?
33. Are contract versions archived?
34. Is the startup prepared for consumer authority inspections?
35. Could the entire subscription system survive due diligence from an investor or acquirer?

If several of these questions cannot be answered, the startup’s recurring revenue model may contain significant legal risk.

Frequently Asked Questions About Automatic Subscription Renewal in Turkey

Can a startup automatically renew a consumer’s annual subscription?

A fixed-term consumer subscription cannot contain a provision automatically extending it for the agreed period. It may be extended where, after the original contract is established and before expiry, the consumer requests or approves continuation.

Can the startup continue charging after a fixed-term subscription expires?

If the provider continues supplying the service after expiry without the consumer’s explicit request or approval, the Subscription Agreements Regulation provides that no payment may be demanded for that continued service.

Can monthly subscriptions continue automatically?

A genuine indefinite-term subscription can continue until terminated because there is no fixed expiry requiring repeated contractual renewal. However, recurring billing, transparency and consumer termination requirements must still be satisfied.

Can a consumer cancel an indefinite subscription whenever they want?

Law No. 6502 generally gives consumers the right to terminate indefinite subscriptions at any time without providing a reason or paying a penalty.

Can a startup force an online subscriber to cancel at a physical office?

Generally no. The Ministry of Trade states that cancellation cannot be made subject to conditions more burdensome than those used to establish the subscription. An online subscriber should not, for example, be required to visit a branch or use a notary merely to terminate.

How quickly must cancellation normally be processed?

The Ministry of Trade’s June 2026 guidance states that providers must generally complete the termination process within seven days after receiving the request.

What happens if cancellation is not processed within seven days?

The Ministry states that after the applicable period expires, the provider cannot demand further payment even if the consumer continues technically using the service.

How quickly must unused prepaid amounts be refunded?

The Ministry’s 2026 guidance states that prepaid amounts corresponding to unprovided goods or services must generally be returned within fifteen days following termination.

Are B2B subscription renewals subject to the same prohibition?

No. The Ministry expressly states that subscriptions entered into for commercial or professional purposes fall outside Law No. 6502. B2B automatic renewal can therefore generally be structured contractually, subject to the Turkish Code of Obligations and other applicable law.

Can a startup hide automatic renewal in the Terms of Use?

This is risky. Consumer disclosure obligations and, for general contract terms, the Turkish Code of Obligations require important provisions to be properly incorporated and not unfairly disadvantage the counterparty.

Is there an administrative fine for unlawful automatic renewal?

Yes. For 2026, the Ministry of Trade announced a TRY 3,973 administrative fine per relevant non-compliant contract or transaction for specified subscription violations, including breach of the automatic-extension prohibition.

Conclusion: Is Automatic Renewal Legal for Subscription-Based Startups in Turkey?

Automatic renewal is not categorically prohibited under Turkish law.

However, the legality of a recurring subscription model depends on how the contractual relationship is structured.

The first question should always be:

Is the customer a consumer?

If the customer purchases the service for commercial or professional purposes, Law No. 6502 generally does not apply. The parties have considerably greater freedom to establish B2B automatic-renewal arrangements, subject to general contract law and general transaction conditions.

If the customer is a consumer, a second question becomes critical:

Is the subscription fixed-term or indefinite?

For fixed-term consumer subscriptions, Turkish law contains a clear restriction.

Article 52 of Law No. 6502 does not permit the original fixed-term contract simply to state that the subscription will automatically renew for another equivalent period.

The agreement may be extended only where, after the original subscription has already been established and before it expires, the consumer requests or approves the extension.

The Subscription Agreements Regulation goes further.

Where the fixed term expires and the provider continues supplying services without obtaining explicit consumer request or approval, the provider cannot demand payment for those services.

The Ministry of Trade reconfirmed both principles on 15 June 2026, making the current regulatory position particularly clear.

For indefinite subscriptions, the structure is different.

A contract that begins today and continues monthly until cancellation is not necessarily being legally renewed every month. It is an ongoing contractual relationship.

This makes indefinite subscriptions particularly suitable for many digital business models.

However, an indefinite model does not allow the startup to trap consumers permanently.

Consumers generally have strong termination rights, and cancellation must not be made more burdensome than subscription.

The Ministry of Trade specifically states that an online subscription cannot be made cancellable only through burdensome mechanisms such as branch visits or notarised notices.

Termination requests must generally be implemented within seven days, and where this deadline is missed, continued service after that point cannot simply be used to justify continued billing.

Unused prepaid amounts generally need to be returned within fifteen days following termination.

This means subscription compliance must be reflected not only in the contract but in the software architecture.

The startup’s product should know whether a customer has:

• a fixed term;
• an indefinite term;
• a valid renewal approval;
• an active cancellation request;
• a pending refund;
• or an expired subscription.

Billing automation should never operate independently of this information.

For fixed-term subscriptions, the system should be capable of:

• sending renewal notices;
• requesting affirmative approval;
• recording that approval;
• preventing unauthorised renewal;
• and stopping automatic billing if approval is missing.

For indefinite subscriptions, the system should provide:

• clear recurring price information;
• transparent billing intervals;
• accessible termination tools;
• rapid cancellation processing;
• and appropriate refund mechanisms.

Startups should also pay particular attention to free trials.

A seven-day free trial followed by recurring billing can be commercially effective, but the conversion to paid status should be clear before the consumer accepts the offer.

The consumer should know:

when payment begins,

how much will be charged,

how often the charge will recur,

and

how the subscription can be cancelled.

The fact that a credit card was entered during the free trial should not be treated as unlimited permission to impose an unclear paid relationship.

The same principle applies to stored cards generally.

A payment token is not a contract.

The startup must first have a legally valid subscription or renewal relationship before using the payment mechanism.

Consumer startups should also understand that unlawful renewal can create more than individual refund claims.

For 2026, the Ministry of Trade set the relevant administrative fine at TRY 3,973 per non-compliant contract or transaction for specified subscription violations, expressly including failure to comply with the automatic-renewal prohibition.

For a startup operating at scale, the financial consequences can therefore multiply rapidly.

A recurring revenue business with 500,000 customers must think differently from a company negotiating one subscription manually.

An error in product design can be repeated hundreds of thousands of times automatically.

This is why subscription compliance should be built according to the principle of:

compliance by design.

Legal, engineering, product, payment and customer-support teams should agree on:

• what contract type is being sold;
• what the customer sees;
• what constitutes renewal approval;
• how approval is stored;
• when charges are created;
• how cancellation is requested;
• when cancellation becomes effective;
• and how refunds are processed.

For Turkish startups, the safest conclusion is therefore not:

“Automatic renewal is illegal.”

Nor is it:

“If it is written in the Terms, automatic renewal is always legal.”

The correct answer is more precise:

A fixed-term B2C subscription cannot simply be automatically extended for another fixed period under a clause accepted at the beginning of the relationship. The consumer must request or approve the extension after the subscription has been established and before it expires.

A genuine indefinite subscription may continue periodically until termination, but transparency, recurring billing and consumer cancellation requirements must be respected.

B2B subscriptions provide greater contractual freedom, but automatic-renewal clauses should still be clearly incorporated and comply with general Turkish contract law.

For subscription-based startups, this distinction is fundamental.

Recurring revenue is valuable only when the underlying recurring relationship is legally sustainable.

A business model that produces high monthly recurring revenue through unclear renewals, difficult cancellation and unauthorised charges may eventually produce:

• refunds,
• chargebacks,
• administrative fines,
• consumer litigation,
• reputational damage,
• and serious problems during investment due diligence.

A well-designed subscription model should therefore make four things unmistakably clear:

when the subscription starts,

how long it continues,

when and how payment will recur,

and

how the customer can leave.

When those four questions are answered transparently and the software follows the contract, automatic billing can form part of a sustainable startup revenue model in Turkey.

When they are not, “automatic renewal” can become one of the startup’s largest consumer-law risks.