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2026 KVKK Financial Penalties Clarified: Revaluation Rate at 25.49%
With the inflation figures now finalized, the revaluation rate to be applied in the new year has been set at 25.49%. Accordingly, administrative fines under the Law No. 6698 on the Protection of Personal Data ("KVKK") will also increase in 2026 based on this rate. It should be noted that the President has the authority to reduce or increase this figure. If no adjustment is introduced, the administrative fines will be updated for the new year as outlined in the table.
First Data Transfer Authorisation Abroad from the KVKK: Migration Administration- UNHCR Agreement Approved
The Personal Data Protection Board has issued its first authorization decision under the cross-border data transfer provisions of the KVKK, which were amended last year. In this context, the agreement signed between the Directorate General of Migration Management of the Ministry of Interior and UNHCR, the UN Refugee Agency, which does not qualify as an international treaty, was deemed an appropriate legal basis for the transfer of personal data abroad. The Board evaluated the text within the scope of Article 9/4(a) of Law No. 6698 on the Protection of Personal Data and Article 11 of the Regulation on the Procedures and Principles for the Transfer of Personal Data Abroad, and approved it on 21 October 2025. This decision sets an important precedent for Türkiye's data-sharing processes with international organizations and constitutes the first example of the practical application of the new regulatory framework on cross-border data transfers.
The 11th Judicial Reform Package Introducing Comprehensive Amendments to Law No. 5651 on Content Removal and Protection of Personality Rights Has Been Submitted to the Grand National Assembly of Türkiye
The draft law amending the Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed Through Such Publications ("Law No. 5651") has been prepared in line with the provisions annulled by the Constitutional Court and the Court's reasoning and was submitted to the Grand National Assembly of Türkiye on 27 November 2025.
- The term "removal of content" under Law No. 5651 is redefined: it will no longer mean "deletion from the server," but rather "removal of access to the content on the internet."
- The "notice procedure" is limited to alleged rights-infringing situations, and such notices may now be issued not only by the person alleging the violation but also by the Information and Communication Technologies Authority ("BTK").
- The provisions on violations of personality rights are substantially revised. Individuals may apply directly to the criminal judgeship of peace to request content removal or access blocking. If the violation is prima facie evident, the judge must issue a decision within 24 hours; otherwise, the application will be rejected.
- Upon request, the decision may also be notified to search engines, activating the de-indexing / search result removal / right to be forgotten mechanism.
- The decision may target only the specific URL at issue or, if necessary, impose access blocking for the entire website. These decisions will be communicated to access providers and must be implemented without delay.
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