Introduction
Digital advertising has become one of the most important parts of commercial life in Turkey. Businesses no longer rely only on television, newspapers, billboards or traditional media campaigns. Today, brands reach consumers through websites, search engine advertisements, social media platforms, mobile applications, e-commerce marketplaces, sponsored content, influencer collaborations, push notifications, SMS campaigns, e-mail marketing, affiliate links, targeted ads, remarketing tools and artificial intelligence-generated promotional content.
This transformation has created a new legal field commonly described as Digital Advertising Law in Turkey. Although Turkish law does not regulate digital advertising through a single separate statute, online advertising activities are subject to a combination of consumer protection law, commercial advertising rules, unfair commercial practices regulations, personal data protection law, electronic commerce law and sector-specific restrictions.
The main purpose of Turkish digital advertising law is to ensure that consumers are protected against misleading, hidden, manipulative or unfair commercial communications. Consumers must be able to understand when they are exposed to advertising, who is responsible for the advertisement, what product or service is being promoted, whether the claims are accurate, whether the discount is real, whether personal data is used for targeting and whether the advertisement contains hidden conditions.
The legal importance of digital advertising has increased significantly in 2026. The Ministry of Trade announced that amendments published in the Official Gazette on 1 July 2026 introduced new rules concerning targeted advertising, social media influencer promotions, AI-generated advertisements, discount advertising, environmental claims and consumer reviews. These changes show that Turkish regulators are closely following digital markets and adapting advertising law to online consumer behavior.
For businesses operating in Turkey or targeting Turkish consumers, digital advertising compliance is no longer optional. A legally risky online campaign may lead to administrative fines, suspension decisions, access blocking measures, consumer complaints, unfair competition claims, data protection investigations and serious reputational harm. Therefore, every brand, e-commerce platform, advertising agency, influencer and digital marketing team should understand the key rules of digital advertising law in Turkey.
Legal Framework of Digital Advertising in Turkey
Digital advertising in Turkey is primarily regulated under Law No. 6502 on the Protection of Consumers and the Regulation on Commercial Advertising and Unfair Commercial Practices. Under Article 61 of Law No. 6502, commercial advertisements must comply with the principles determined by the Advertising Board and must be compatible with general morality, public order, personal rights, honesty and truthfulness. The Ministry of Trade expressly states that commercial advertisements must be honest and accurate under this framework.
The Advertising Board, known in Turkish as the Reklam Kurulu, is the main administrative authority responsible for examining commercial advertisements and unfair commercial practices. It operates under the Ministry of Trade and may order the suspension or correction of unlawful advertisements, impose administrative fines and decide on access blocking measures for certain online advertisements.
Digital advertising may also fall under other legal regimes. For example, targeted ads and remarketing campaigns may involve the processing of personal data and cookies, making Law No. 6698 on the Protection of Personal Data relevant. The Turkish Personal Data Protection Law requires personal data processing to comply with general principles such as lawfulness, fairness, accuracy, specified and legitimate purposes, data minimization and limited retention.
Commercial e-mails, SMS messages and promotional calls are also regulated under Law No. 6563 on the Regulation of Electronic Commerce and the legislation on commercial electronic messages. The Message Management System, known as İYS, is a national platform for managing commercial electronic message permissions and complaint processes.
Therefore, digital advertising compliance in Turkey requires a layered legal analysis. A single online campaign may raise issues under advertising law, consumer law, personal data law, e-commerce law, intellectual property law, unfair competition law and sector-specific legislation.
What Is Digital Advertising?
Digital advertising refers to any commercial communication published through electronic or online channels for the purpose of promoting goods, services, brands, commercial activities, platforms or businesses. The form of the content does not determine whether it is advertising. What matters is the commercial purpose and the likely effect on consumers.
Digital advertising may include search engine ads, banner ads, sponsored social media posts, influencer videos, marketplace product listings, native advertising, affiliate marketing, retargeting ads, mobile app ads, sponsored articles, commercial e-mails, SMS campaigns, push notifications, product recommendation algorithms, online video ads, podcast sponsorships and AI-generated promotional visuals.
A key feature of digital advertising is that it may look less formal than traditional advertising. A consumer may encounter an advertisement while scrolling through social media, watching a video, reading a blog post, comparing products on an e-commerce platform or checking user reviews. For this reason, Turkish law places strong emphasis on transparency. Consumers must not be deceived into believing that a commercial message is independent editorial content, ordinary consumer opinion or a spontaneous personal recommendation.
General Principles for Online Advertising
The first principle of digital advertising law in Turkey is truthfulness. Online advertisements must not include false or inaccurate statements. A product cannot be promoted as having features it does not actually have. A service cannot be advertised as guaranteed if the result depends on uncertain factors. A platform cannot claim that a product is the cheapest, fastest, safest or most preferred without reliable evidence.
The second principle is substantiation. Advertisers must be able to prove factual claims used in digital campaigns. Expressions such as “clinically proven,” “number one,” “lowest price,” “best-selling,” “100% natural,” “eco-friendly,” “scientifically tested,” “doctor recommended” or “limited stock” may create legal risk if they are not supported by objective, current and verifiable evidence.
The third principle is transparency. Consumers must understand that the content is advertising. Hidden advertising is prohibited in written, visual and audio content across all communication channels. The Ministry of Trade states that hidden advertising is prohibited and that footnotes or subtitles containing exceptions to the main promise must be readable and presented at an appropriate speed.
The fourth principle is fairness. Digital advertising must not exploit consumers’ lack of experience, lack of knowledge, fear, age, illness, financial hardship or emotional vulnerability. Advertisements directed at children, elderly consumers, patients or financially distressed individuals are examined more strictly.
The fifth principle is legal compatibility with the medium. Digital advertising is not exempt from law because it is published online. A claim that would be unlawful on television or in a newspaper may also be unlawful on Instagram, TikTok, YouTube, Google Ads, an e-commerce marketplace or a mobile application.
Misleading Online Advertising
Misleading advertising is one of the most common risks in digital marketing. An online advertisement may be misleading not only when it contains false information, but also when it omits essential information, presents conditions ambiguously, hides additional costs or creates a false overall impression.
For example, an e-commerce website may advertise a product as “50% off” although the previous price was artificially increased before the campaign. A mobile application may advertise a “free trial” while hiding automatic renewal rules. A hotel booking platform may emphasize a low room price but add mandatory service fees at checkout. A subscription service may make cancellation difficult despite advertising “cancel anytime.” A cosmetic product may be shown with filters that exaggerate its effect.
The legal assessment focuses on the likely perception of the average consumer. Small-print disclaimers, late-stage checkout information or hidden terms may not be enough if the dominant impression of the advertisement is misleading. Businesses should review the full consumer journey, not only the wording of the advertisement. Landing pages, checkout screens, campaign banners, pop-ups, filters, comparison tools and user interface design may all affect whether a digital advertisement is lawful.
Social Media Advertising in Turkey
Social media advertising is one of the most dynamic areas of Turkish digital advertising law. Brands use Instagram, TikTok, YouTube, X, Facebook, LinkedIn, blogs, podcasts and live streams to promote products and services. These campaigns may be published directly by brands or through influencers, celebrities, content creators and affiliate partners.
The key legal issue is whether the commercial nature of the post is clear. If a brand publishes an advertisement through its own account, the commercial nature may often be obvious. However, when an influencer or content creator shares a post, story, reel, video or live broadcast, consumers may believe that the content is a personal recommendation. If there is a commercial relationship, this must be clearly disclosed.
The Ministry of Trade’s guide on social media influencers states that influencer advertisements must be clear, understandable and distinguishable, and that hidden advertising on social media is prohibited. The guide also states that where an influencer receives payment, free or discounted goods or services, the commercial relationship must be disclosed according to the relevant platform.
The 2026 amendments strengthened these obligations. According to the Ministry of Trade, where an influencer receives any benefit such as payment, discounted products, services or event participation, the advertising nature of the post must be clearly indicated with expressions such as “advertisement” or “promotion.”
For compliance purposes, disclosure should be visible, understandable and placed where consumers can notice it at first glance. It should not be hidden among many hashtags, placed only at the end of a long caption, displayed in tiny font or shown too briefly in a video. In live broadcasts, disclosures may need to be repeated because viewers may join at different times.
Influencer Marketing and Brand Responsibility
Influencer marketing creates responsibility not only for influencers but also for brands and agencies. A brand cannot avoid liability by claiming that the influencer prepared the content independently if the brand paid for the campaign, provided products, approved the content, gave a discount code, supplied creative instructions or benefited from the promotion.
Brands should ensure that influencers do not make claims that the brand itself could not lawfully make. For example, an influencer should not say that a product cures a disease, guarantees weight loss, permanently removes wrinkles, provides medically proven results or is the “best” product in the market unless such statements are legally permitted and supported by reliable evidence.
Influencer agreements should include detailed provisions on advertising disclosures, content approval, prohibited claims, use of filters, genuine product experience, evidence requirements, takedown obligations, cooperation in regulatory investigations and liability allocation. However, contractual clauses alone are not sufficient. Brands must monitor whether influencers actually publish content in accordance with legal requirements.
Targeted Advertising and Personal Data
Targeted advertising allows advertisers to show personalized ads based on user behavior, browsing history, location, purchase habits, interests, demographic data, cookies and profiling tools. This practice is widely used in e-commerce, social media advertising, search engine marketing and mobile applications.
Turkish law does not prohibit targeted advertising as a general rule, but it requires transparency and compliance with data protection rules. The 2026 amendments introduced specific rules for targeted advertising. According to the Ministry of Trade, advertisers may conduct targeted advertising if they provide consumers with direct and easily accessible information about the criteria used to show the advertisement and how those criteria can be changed. The amendments also prohibit targeted advertising directed at children through profiling based on personal data.
This rule is particularly important for platforms using behavioral targeting, retargeting, lookalike audiences, custom audiences and interest-based advertising. A business should be able to explain why a consumer is seeing an advertisement and how the consumer can modify advertising preferences.
Targeted advertising also requires compliance with Turkish personal data protection law. If personal data is processed for advertising purposes, the data controller must identify the legal basis, provide proper information notices, obtain explicit consent where required and comply with the principles of purpose limitation, data minimization and storage limitation.
Cookies, Tracking Technologies and Remarketing
Cookies are one of the most important tools in digital advertising. They may be used for analytics, personalization, remarketing, behavioral advertising and measuring campaign performance. However, cookies may also involve personal data processing and therefore require legal compliance.
The Turkish Personal Data Protection Authority’s Cookie Practices Guide defines advertising and marketing cookies as cookies used to show personalized advertisements and content in the online environment, conduct marketing activities and measure the effectiveness of advertisements on users.
From a compliance perspective, not all cookies are treated the same. Strictly necessary cookies used for basic website functions are different from advertising and marketing cookies used for behavioral advertising. When cookies are used for advertising, remarketing, profiling or tracking users across websites, explicit consent may be required depending on the concrete processing activity.
Cookie banners should not be designed in a manipulative way. Users should be able to make a free and informed choice. Pre-ticked boxes, unclear buttons, forced consent, confusing rejection mechanisms or hiding the “reject” option may create legal risk. The cookie consent mechanism should be integrated with the privacy notice and advertising preference management system.
E-Commerce Advertising Rules
E-commerce advertising is a major part of digital advertising law in Turkey. Online sellers, marketplaces and platforms must ensure that product listings, campaign pages, discount banners, search results, sponsored rankings and checkout flows do not mislead consumers.
One major risk is price transparency. If a product is advertised with a discount, the previous price and discount rate must be accurate. Businesses should keep price history records and should not artificially increase prices before campaigns. The Ministry of Trade has also published guidance on advertisements containing price information and discount sales advertisements under the consumer protection framework.
Another risk is hidden costs. If delivery fees, service charges, taxes, membership conditions, installation costs or cancellation fees are mandatory, they should be disclosed clearly before the consumer makes a transactional decision. A platform should not advertise a low price while revealing significant additional costs only at the last stage of checkout.
E-commerce platforms should also be careful with sponsored rankings and product recommendations. If a product appears higher in search results because of paid promotion, consumers should be able to understand that the placement is advertising. Otherwise, the ranking may create the impression of organic popularity or objective quality.
Product reviews are also important. Fake reviews, manipulated ratings, selective removal of negative reviews or unverified testimonials may mislead consumers. The 2026 amendments introduced rules requiring consumer reviews to be handled transparently and limiting the publication of reviews obtained from platforms where the purchase process cannot be verified.
Commercial Electronic Messages: E-Mail, SMS and Calls
Digital advertising often includes direct marketing through e-mail, SMS, automated calls and similar communication channels. These activities are regulated under electronic commerce legislation and the Message Management System.
The Ministry of Trade states that İYS was established as an electronic system for obtaining commercial electronic message approvals and enabling the exercise of the right to refuse such messages. The official İYS platform also describes itself as a national platform through which commercial electronic message permissions and complaint processes can be managed.
Businesses should therefore ensure that commercial electronic messages are sent only where valid consent exists or where a legal exception applies. Consumers must have a clear and easy opt-out mechanism. Sending promotional messages without proper permission may lead to administrative sanctions and consumer complaints.
The content of commercial electronic messages must also comply with advertising law. Even if the message permission is valid, the campaign may still be unlawful if it contains misleading discount claims, false statements, hidden conditions or prohibited sector-specific promotions.
AI-Generated Digital Advertising
Artificial intelligence is rapidly changing digital advertising. Brands now use AI-generated visuals, synthetic voices, virtual influencers, digital humans, automated product descriptions, personalized ad copy and deepfake-style promotional content. These technologies create new opportunities but also new legal risks.
The main concern is deception. If an AI-generated character looks like a real human, consumers may believe the person actually exists. If a digital copy of a real person is used, consumers may believe that the person personally experienced or recommended the product. If AI-generated visuals exaggerate product performance, consumers may be misled about the real characteristics of the product.
The 2026 amendments introduced specific rules in this area. According to the Ministry of Trade, if advertisements use AI-generated digital characters that cannot be distinguished from real humans, this must be clearly, understandably and distinguishably disclosed. The amendments also prohibit advertisements where the AI-generated digital copy of a real person creates the impression that the person personally experienced or recommended a product or service.
Businesses using AI in digital advertising should therefore adopt a transparency-first approach. They should disclose AI use where required, obtain consent for the use of real persons’ image or voice, avoid false endorsements and ensure that AI-generated content does not exaggerate product effects.
Dark Patterns and Manipulative Digital Interfaces
Digital advertising law is not only about words and visuals. User interface design may also create unfair commercial practice risks. Manipulative digital designs, often called dark patterns, may influence consumers into making decisions they would not otherwise make.
Examples include pre-selected paid add-ons, confusing subscription cancellation flows, misleading countdown timers, false urgency messages, hidden rejection buttons, difficult opt-out procedures, forced consent mechanisms, automatic renewals hidden in free trial offers and checkout screens that make additional costs hard to notice.
The Advertising Board has specifically addressed manipulative interface designs. In its 369th meeting held on 14 May 2026, the Board stated that manipulative interface designs that negatively affect consumers’ decision-making are treated as unfair commercial practices.
For e-commerce and digital platforms, this means that compliance should include UX and interface review. A technically accurate disclosure may still be ineffective if the design pushes consumers toward an unintended commercial decision.
Advertising to Children in Digital Environments
Children are particularly vulnerable in digital advertising. They may not distinguish clearly between entertainment and advertising, especially in games, videos, influencer content, toy reviews, educational applications and social media content. They may also be influenced by rewards, characters, peer pressure, in-app purchases and personalized recommendations.
The 2026 amendments expressly prohibit targeted advertising directed at children through profiling based on personal data. This rule is highly relevant for gaming companies, children’s content platforms, toy brands, education technology platforms, mobile applications and social media campaigns.
Businesses should avoid using children’s behavioral data for personalized advertising. They should also ensure that content directed at children does not exploit inexperience, encourage unsafe behavior, pressure children to persuade parents or create unrealistic expectations about products.
Sanctions for Unlawful Digital Advertising
Unlawful digital advertising may lead to serious sanctions in Turkey. The Advertising Board may order the suspension or correction of advertisements, impose administrative fines and decide on access blocking measures for certain online advertisements.
Recent enforcement figures show that the Advertising Board is active. In its 369th meeting held on 14 May 2026, the Board reviewed 156 files, found 146 files unlawful and imposed approximately 23 million Turkish liras in administrative fines. It also decided to block access to 17 advertisements.
Administrative fines can be significant. The Ministry of Trade announced that in 2026, fines for misleading advertisements and unfair commercial practices may range from 99,339 TL to 39,916,524 TL, depending on factors such as the medium, the unfairness of the violation, the benefit obtained, the harm caused, fault and the economic situation of the violator.
In addition to administrative sanctions, unlawful digital advertising may lead to unfair competition lawsuits, consumer claims, data protection investigations, platform takedowns, contract disputes with influencers or agencies and reputational damage.
Digital Advertising Compliance Checklist in Turkey
Businesses targeting consumers in Turkey should create a preventive compliance process for digital campaigns. Before launching an online advertisement, the following questions should be asked:
Is the commercial nature of the content clear?
Can the average consumer understand that the content is advertising?
Are all factual claims accurate and provable?
Are discount rates and previous prices supported by records?
Are essential conditions visible before the consumer makes a decision?
Are influencers using clear advertising disclosures?
Are AI-generated characters or digital copies disclosed where necessary?
Are cookies and tracking technologies used lawfully?
Is explicit consent obtained where required?
Can consumers understand and change targeted advertising criteria?
Are children exposed to profiling-based targeted advertising?
Are sponsored rankings and paid placements clearly identifiable?
Are product reviews genuine, verifiable and fairly presented?
Are e-mail and SMS campaigns sent with valid commercial message permissions?
Does the campaign comply with sector-specific restrictions?
Does the user interface avoid manipulative design?
This checklist should be applied before publication. In digital advertising, unlawful content can spread rapidly and may be saved, shared, reposted or archived by consumers. Correcting a violation after publication may not eliminate responsibility.
Conclusion
Digital Advertising Law in Turkey is a fast-developing area shaped by consumer protection, advertising regulation, personal data protection, e-commerce rules and digital market practices. Online advertisements, social media posts, influencer promotions, e-commerce campaigns, commercial electronic messages, targeted ads, cookies, AI-generated content and consumer reviews are all subject to legal scrutiny.
The central principles are clear: digital advertisements must be honest, accurate, transparent, verifiable and fair. Consumers must not be misled by hidden sponsorships, false discounts, unverifiable claims, manipulative interfaces, fake reviews, undisclosed AI content or unlawful targeting practices. Businesses must also ensure that personal data and cookies are used in compliance with Turkish data protection rules.
The 2026 amendments show that Turkish regulators are focusing heavily on digital advertising practices, especially targeted advertising, influencer content, AI-generated ads, children’s protection, discount campaigns and consumer reviews. At the same time, recent Advertising Board decisions demonstrate that enforcement is active and sanctions can be substantial.
For brands, platforms, agencies and influencers, the safest approach is to integrate legal review into every stage of digital campaign planning. A compliant digital advertising strategy protects consumers, reduces regulatory risk and strengthens brand trust in Turkey’s competitive online market.
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