July 2023 – On July 25, 2023, the Personal Data Protection Board (the "Board") made an amendment that affects data controllers' registration requirements with Data Controller Registry (VERBIS) with a decision published in the Official Gazette.

With the amendment, the "annual financial balance sheet total" criterion, which allows certain exemptions from VERBIS registration, has been updated. The threshold for this criterion has been raised from TRY 25 million (approx. EUR 836,827) to TRY 100 million (approximately EUR 3,347,310).

As a result, currently, data controllers that provide the following criteria have become obliged to register with VERBIS.

  • data controllers having more than 50 employees in a year; or
  • data controllers with a total annual balance sheet amount of more than TRY 100 million (approx. EUR 3,347,310);
  • data controllers residing abroad;
  • data controllers whose main activity is processing sensitive personal data; and
  • public institutions and organisations.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.