In the last few years, Turkey has found itself increasingly in the crosshairs of bad actors. In Q3 2023, phishing rose sharply with a 20% jump from the previous quarter and a 47% spike year-on-year. The country is also a key target for cyberattacks on industrial control systems.
Cyber threats travel fast, while laws usually do not, but in Turkey, that gap is narrowing.
What started as a bunch of fragmented policies and sectoral obligations has now merged into a national posture that fuses digital sovereignty with regulatory oversight. Businesses with operations in Turkey, or even those that process Turkish citizens’ data, must take careful note. In a country where regional tensions are known to run high and cyber risk is national risk, compliance is no longer optional.
It is a directive, and it comes with teeth.
The Laws That Shape the Landscape
In March, Turkey enacted Cybersecurity Law No. 7545, forming a comprehensive framework for cybersecurity. This consolidated and expanded the patchwork of sector-specific laws, data protection requirements, and national certification mandates before it.
It also established the Cybersecurity Directorate and the Cybersecurity Presidency, which now have regulatory and enforcement powers over cybersecurity-related certifications, audits, and penalties.
Law No. 6698, the Law on the Protection of Personal Data (KVKK), is at the heart of this. It requires data controllers to implement layered technical and business safeguards. These include the expected measures, like encryption, access controls, intrusion detection, and regular software patching. Entities that fail to comply risk harming their reputations, losing customer trust, and facing steep monetary fines.
Regulatory guidance has also expanded the scope. The 2018 Guideline on Technical and Organizational Measures clarifies expectations: encryption at rest, network segmentation, logging and monitoring, and incident response. This is not a wish list; it’s critical for companies that want to be audit-ready.
The expectations go further for firms operating in critical sectors. For energy, telecommunications, healthcare, and finance, ISO/IEC 27001 certification is mandatory. Banks must adopt COBIT standards. Credit card processors have to meet PCI DSS. Public companies must have CISA-certified auditors. These are all non-negotiable obligations.
Certification as a Legal Requirement
The Digital Transformation Office (DTO), operating under the Presidency, has defined compliance in Turkey. Its Cybersecurity Certification Framework mandates that public institutions and critical sectors work only with nationally certified cybersecurity vendors, including tools, platforms, and even service providers.
Penalties for using uncertified solutions vary between TRY1 million and TRY10 million. The message is clear: compliance starts with procurement.
Compliance is even more stringent in healthcare. The Ministry of Health (MoH) enforces detailed requirements through its InfoSec Directive and InfoSec Guideline. Providers need to establish cybersecurity commissions, appoint security officers, and implement risk-based data protection.
Medical data stored in the cloud has to meet strict safeguards, including encryption, data residency on KamuNet (a closed virtual network to enable safe data sharing between public institutions in Turkey), and fine-grained access controls.
This is cybersecurity by design and by law.
Who Enforces, and How
Turkey has built a multi-agency ecosystem to oversee compliance and enforcement.
The Personal Data Protection Authority (KVKK Authority) is the central body charged with enforcing data protection and all associated security standards. It conducts inspections, issues guidance, and issues fines. Law No. 7545 also imposes revenue-based penalties for the first time, up to 5% of gross sales revenue for commercial entities.
Specialized agencies handle sectoral oversight:
The Cybersecurity Directorate, under the DTO, certifies tools and experts.
The Banking Regulation and Supervision Agency (BRSA) oversees financial sector entities.
The Capital Markets Board (CMB) mandates cybersecurity audits for listed firms.
The MoH governs health sector compliance.
The Turkish Medicines and Medical Devices Agency (TMMDA) addresses cybersecurity in clinical and pharmacological systems.
Unlike in the past, enforcement is no longer theoretical. More audits are being held. Guidance has turned into policy. And policy is becoming practice.
Trends from 2024–2025: Toward AI and Beyond
Turkey is expanding regulatory attention to emerging trends such as artificial intelligence (AI). In October 2024, Parliament formed a commission to study AI legislation. The draft AI Law proposes mandatory risk assessments, transparency obligations, and compliance audits for ‘high-impact’ AI systems. While this has not yet been enacted, it signals intent and is a step in the right direction.
The National Artificial Intelligence Strategy (2021–2025) also includes cybersecurity as a foundational pillar.
Key actions planned for this year include:
Developing a legal framework for ethical AI deployment.
Drafting technical guides for risk management.
Building capacity for AI governance in public institutions.
This is in line with the government’s broader digital vision: sovereignty, security, and certified control.
How Turkey Aligns with the World
Turkey’s cybersecurity regulations reflect both international alignment and local flavor. They borrow from ISO 27001, COBIT, and GDPR, but adapt them to fit the country’s unique institutional structures.
Like the EU’s GDPR, Turkey requires breach notifications and processor accountability. However, data transfers face stricter conditions, often needing either data subject consent or official approval.
Unlike the U.S. model of decentralized sectoral regulation, Turkey centralizes oversight through powerful agencies and top-down frameworks. In many ways, it mirrors the cyber regimes of countries where the state plays an active role in digital infrastructure. But again, it does this with a local slant.
What Global Businesses Must Do
Certify or Step Aside: If you operate in critical sectors or sell cybersecurity solutions to Turkish institutions, certification through the DTO is required. Without it, contracts may be rendered illegal.
Get ISO 27001 If You Don’t Already Have It: In Turkey, this gold standard is not just best practice but the price of entry.
Treat Third Parties Like Internal Risks: Controllers are liable for the failures of their processors. Review your contracts, insist on strict compliance, and conduct regular audits.
Watch the AI Horizon: As in the rest of the world, AI regulation is coming. Get ahead of it by implementing explainability and risk controls in high-risk systems.
Prepare for Breach Reporting: There are no safe harbors for silence. The KVKK Authority expects swift, accurate reporting of breaches. Have a plan in place.
Healthcare and Finance Require Extra Caution: These sectors are technically and procedurally tightly regulated. If you operate here, study the guidelines, follow the protocols, and document every step.
Turkey is building its cybersecurity regime with one law, guideline, and audit at a time. It is not waiting for incidents to dictate policy. It is moving before the damage is done.
For global companies, this is a challenge and an opportunity. Get it right and build trust, resilience, and operational continuity. If you get it wrong, you could be fined heavily, lose business, and damage your reputation.
Cybersecurity compliance in Turkey is now part of the business landscape. Understand it. Prepare for it. And operate with eyes open.
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