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September 2026 – The Bill on Foreign Digital Accommodation Platforms (the “Bill”), submitted to the Presidency of the Grand National Assembly of Türkiye on 10 August 2026, aims to subject the activities of digital accommodation platforms established abroad to an authorisation and supervision framework in Türkiye.
The main points of the Bill are summarised below:
- The Bill captures service providers and intermediary service providers established abroad that operate domestically through an electronic commerce environment, irrespective of whether they sell on their own account. In this context, the Ministry of Culture and Tourism (the “Ministry”) is designated as the competent authority.
- Platforms may operate only upon obtaining a permit certificate from the Ministry. Valid for two years and non-transferable, the certificate carries a fee of five million Turkish liras, increased annually at the revaluation rate, which the President may double or reduce by half. A platform holding a certificate is not required to obtain any further operating or permit certificate for activities within the scope of the Law. Where a platform forms part of a consolidated group for financial accounting purposes, a separate certificate is to be issued for each platform that operates independently.
- An application for a permit certificate requires registration as a digital services taxpayer, the absence of any debt to the tax offices, notification of a domestic contact address for service of notices and of a responsible Turkish citizen or legal entity, together with a National Electronic Notification System address, and payment of the certificate fee. Platforms must also appoint at least one representative in Türkiye and display the representative's contact details in their electronic commerce environment. A natural person representative must be a Turkish citizen resident in Türkiye, while a legal entity representative must be incorporated as a capital company with at least one of the persons authorised to represent it meeting those same conditions.
- Under the permit certificate, platforms may directly sell only tourism-certified accommodation, certified tourism residences and air tickets. Services reserved to travel agencies may be offered only through certified agencies, and car rental only through undertakings authorised by the Ministry of Trade, which may require platforms to restructure their product offering. Conversely, sales combining at least two of transport, accommodation and unrelated services will not be treated as package tours, and platforms operating within the matters for which they are exclusively authorised will not be regarded as e-commerce intermediary service providers or e-commerce service providers under Law No. 6563 on the Regulation of Electronic Commerce.
- Any disputes arising out of or in connection with activities within the scope of the permit certificate will be governed exclusively by Turkish law, and Turkish courts will have jurisdiction.
- Platforms may not operate beyond the scope of the permit certificate or market other products. Activities covered by the certificate must be carried out solely through an electronic commerce environment used exclusively for those activities. They must notify changes to the underlying information and documents within fifteen days, respond to the Ministry's information requests within the same period, and verify and display establishment certificate numbers in their listings. Platforms must also use, and keep operational, the hardware, programs and software designated by the Ministry.
- The Bill regulates the commercial relationship between platforms and service providers. Platforms may not restrict service providers from offering different prices through alternative channels or from advertising, may not compel them to participate in promotional sales, and may not demote, suspend or terminate a service provider absent an objective criterion or on the ground that it has applied to public authorities or judicial bodies. Intermediation agreements may not contain provisions permitting such practices.
- The amount platforms may charge over the sales price, under whatever name, may not exceed 17% of the price excluding VAT, and no fee may be charged where no service has been rendered or the fee is not specified in the intermediation agreement. Breaches attract an administrative fine of either TRY 200,000 or TRY 500,000 depending on the provision infringed, and a fine of ten times the amount unlawfully collected where the commission cap is exceeded or a fee is charged unlawfully. Failure to provide, or incomplete provision of, a service promised to a customer attracts a fine of between TRY 50,000 and TRY 100,000 per contract. Repetition within the same calendar year increases the fine by 50%, and a third determination results in cancellation of the permit certificate. Activities contrary to the national interest, undermining public confidence or damaging the country's tourism constitute a separate ground for cancellation, and a platform whose certificate is cancelled may not apply for a new one for six months. Operating without a certificate, or following its cancellation or expiry, triggers an access blocking order by the Ministry, which must be submitted for the approval of a criminal judge of peace within twenty-four hours. The principal exposure therefore lies not in the fines but in cancellation and access blocking.
- The Bill includes platforms among the parties liable for the tourism share, payable at a rate of 0.075% and calculated on the basis of the digital services tax base.
- If enacted, the Bill will enter into force on the date of publication, without any additional preparation period. Platforms operating as at the date the law enters into force must apply for a permit certificate within three months; the access blocking provisions will apply to those failing to comply or whose applications are rejected.
The Bill has been referred to the Committee on Public Works, Reconstruction, Transport and Tourism as the principal committee, and the final text remains subject to change.
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.
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