I. Scope
This memorandum explains, in questions and answers, the rules that businesses trading in real estate must follow when publishing listings through electronic and physical channels, and the sanctions that may apply for breaches. The assessment concerns listings published in Türkiye; legislation and practice were checked as of 1 October 2026. The 2026 regulations are used for penalty amounts.
II. Rules for publishing listings
1. What authority and documents must be obtained before listing a property?
The business must hold a real estate trade authorization certificate and conclude a written authorization agreement with the client covering the property concerned. For an electronic listing, the owner must additionally grant EİDS listing authority to the business through e-Devlet, and the listing platform must complete identity and authority verification. The business's professional authorization certificate and its authority to list a particular property are different matters. 1
2. Does EİDS authority replace a written agreement or a power of attorney?
No. EİDS authority verifies the authority to publish an electronic listing. It neither replaces the written authorization agreement nor authorizes a sale at the land registry, collection of the price, or any other transaction on the owner's behalf. The necessary representation authority must separately exist for those transactions. 1
3. Can property listings be shared on Instagram, Facebook and WhatsApp?
Yes. Under the Ministry's practice, listings on these channels are also electronic listings. The post must include the link to the EİDS-verified listing and price information. Photographs, videos and descriptions may be included provided they concern the same property as the verified listing. Posting only an image, or saying that the price will be provided by private message, does not meet these conditions. 2
4. Does including a verified listing link make the advertising content lawful as well?
No. EİDS verification and the accuracy of advertising are separate obligations. Area, price, location, title characteristics, zoning and occupancy status must be stated accurately. Net and gross area must be clearly distinguished, and approximate distances or dimensions must not be presented as exact data. Documents supporting verifiable advertising claims must be retained. 1 3
5. Can different images or prices be used for the same property?
Images of the property taken from different angles may be used. Photographs or videos of another property must not be used. Images and descriptions must be consistent with the verified listing, and price changes must be reflected on the listing platform, social media and other channels. Promotion at different prices without explaining the current offer conditions creates a risk of misleading advertising. 1 3
6. How should Google Ads, the business's website and digital brochures be handled?
Google Ads, websites and digital brochures are also digital channels. Accordingly, content promoting a particular property for sale or rent must comply with the listing and advertising rules in the Regulation.
7. Must office window displays and printed brochures include an EİDS link?
EİDS concerns identity and authority verification for electronic listings. The link requirement stated for social media does not apply in exactly the same way to physical listings. Nevertheless, window displays and brochures must use accurate, current information consistent with the authorization agreement and comply with the Regulation's listing-content obligations. 1 3
8. Is the owner's permission sufficient for a building banner, sign or billboard?
It may not be sufficient on its own. The right to use the advertising space, any necessary permissions for common areas, and the relevant municipality's advertising regulations must be considered together. Permit, tax and fee conditions may vary by location, type and size of the advertisement. Paying tax does not mean that a separately required advertising permit has been obtained. 5
9. When must a listing be removed after sale, rental or expiry of authority?
If the property is sold or rented, the sale or rental is abandoned, or the authorization agreement is terminated or expires, listing activity must end within three days following the date of that event. This obligation must be considered for the business's other continuing listing activities as well as the entry on the listing platform. 1
10. What records must be retained after publication?
A physical or electronic file must be created for every authorization agreement; the agreement and other agreements and documents drawn up within the services provided must be retained for at least five years. To explain matters during an inspection, it is also recommended to retain records of EİDS authorization, published listings, price changes and the date of removal. 1
III. Violations and sanctions
11. What happens if a social-media listing omits the EİDS-verified link or price?
The post breaches the Ministry's listing rules. The Ministry's letter on social-media posts states that persons posting non-compliant listings will be subject to administrative fines of up to TRY 286,206 for each breach. This is not a fixed fine automatically applied in every case. In its statement dated 22 August 2026, the Ministry also announced fines of TRY 100,000 per business imposed on 42 real estate businesses for unlawful social-media listings. 2
12. Is an EİDS fine imposed only on the listing platform?
No. Although listing platforms are responsible for identity and authority verification, businesses posting listings also have their own obligations. Article 22(4) of the Regulation refers platform breaches under Article 12(2) to Article 12(1)(d) of Law No. 6563, and other breaches of the Regulation to Article 18 of Law No. 6585. The legal basis and addressee of a platform fine and a real estate business fine must therefore be assessed separately. 1 4
13. What happens if a listing is posted without a certificate or written authorization?
Trading in real estate without an authorization certificate, providing services without an authorization agreement, or listing a property that the business has no authority to market breaches the Regulation. Following inspections by the Ministry and provincial trade directorates, an administrative fine under Article 18 of Law No. 6585 may arise. The amount depends on the nature of the breach and the relevant year's penalty regulations. Subsequent authorization by the owner does not automatically eliminate the earlier breach. 1 4
14. What sanctions apply to advertising with incorrect area, occupancy or title information?
For misleading property advertising, the Advertising Board may order the advertisement stopped or corrected by the same method, or impose an administrative fine. Where necessary, it may also order a precautionary suspension for up to three months. Sanctions may apply together or separately depending on the breach. EİDS authority does not remove this liability. 3
15. How is the fine for misleading advertising determined?
The fine varies according to the channel in which the advertisement is published. Within the relevant statutory lower and upper limits, the Advertising Board considers the seriousness of the breach, the benefit obtained or harm caused, fault, and the person's economic circumstances. The 2026 amounts apply under the Communiqué published in Official Gazette No. 33116 dated 23 December 2025. Under this Communiqué, the range for internet and social-media advertising is TRY 1,083,706 to TRY 10,837,065. For advertising classified as other channels, such as banners and billboards, it is TRY 108,370 to TRY 1,083,706. These are the 2026 limits; the maximum is not imposed in every case. The TRY 286,206 maximum stated for EİDS is not the general maximum for misleading-advertising fines. 2 3
16. Can internet content be removed or access blocked because of misleading advertising?
Yes. Under Article 77(12) of Law No. 6502, a notice to remove content may be issued for online breaches. If the content is not removed within twenty-four hours despite the notice, access may be blocked. If the addressee cannot be notified, a direct access-blocking order is also possible. As a rule, the order is limited to the unlawful content. If the statutory conditions are met, an access block covering the entire website may be imposed. 3
17. Does immediately deleting an unlawful listing prevent a penalty?
Removal or correction ends the continuing breach but does not automatically prevent sanctions for a breach that has already occurred. The listing's duration, content and removal date may be considered in an inspection. Publishing the same advertisement on another account after a suspension or content-removal order also does not constitute compliance. 1 3
18. Can breaches of listing rules lead to cancellation of the authorization certificate?
Yes. Under Article 9(1)(ç) of the Regulation, the certificate is cancelled if a breach is not remedied within the period set by the Ministry, which must be at least ten days, or if it is repeated within the same calendar year. Not every finding of a missing link automatically and immediately leads to cancellation. The conditions for a fine and for cancellation of the certificate must be assessed separately. 1
19. What happens if a listing remains after sale or expiry of authority?
Failure to comply with the three-day period breaches Article 14(2)(h) of the Regulation and may lead to administrative sanctions under Article 22 of the Regulation and Article 18 of Law No. 6585. If the listing continues in a manner misleading consumers, it may also be examined under advertising legislation. The conditions explained in question 18 also apply to cancellation of the certificate. 1 3 4
20. What consequences may follow a banner or billboard advertisement without permission?
Depending on the relevant municipality's regulations, removal and applicable administrative sanctions may follow. Failure to declare taxable advertisements or pay the tax may also give rise to tax, penalties and late-payment obligations subject to tax legislation. There is no single penalty amount applicable to every banner throughout Türkiye. The municipality's current regulations and tariff for the advertising location must be checked. 5
21. Can one listing involve several sanctions or responsible parties?
Depending on the circumstances, yes. For example, a social-media listing without a link and an incorrect statement of area may breach different obligations. Advertising legislation may hold the advertiser, advertising agency and media operator responsible. However, whether several administrative fines can apply to the same act must be assessed under the relevant provisions, including Article 15 of the Misdemeanours Law No. 5326. Fines should not be assumed to be automatically added together in every case. 3 6
IV. Legal grounds and sources
Footnotes
1 Real Estate Trade Regulation, Articles 5, 9(1)(ç), 12, 14(2), 15 and 22: authorization certificates, listing authority and content, written agreements, the three-day removal period, document retention and inspection. Official text: https://www.mevzuat.gov.tr/mevzuat?MevzuatNo=24645&MevzuatTur=7&MevzuatTertip=5
2 Ministry of Trade statements and letters on EİDS social-media practice: letter No. E-33579531-439.99-00123238870 dated 17 June 2026 and the subsequent social-media statement. These concern links, images and descriptions of the same property, and notice of sanctions up to TRY 286,206 for each breach. The announcement reproducing the Ministry's letter is at https://atonet.org.tr/IcerikDetay/25543_eids-sosyal-medya-paylasimlari. The Ministry's press statement of 22 August 2026 requires a verified listing link and price in social-media posts and reports fines of TRY 100,000 each on 42 real estate businesses. This example of enforcement is not a fixed tariff for every breach. Source: Ministry of Trade News, statement on identity and authority verification for all electronic listings under EİDS.
3 Consumer Protection Law No. 6502, Articles 61, 63, 77(12) and 78; Regulation on Commercial Advertising and Unfair Commercial Practices, Articles 6, 7 and 9; Communiqué on Administrative Fines Applicable in 2026 under Article 77 of Law No. 6502, Official Gazette of 23 December 2025, No. 33116. See https://www.resmigazete.gov.tr/eskiler/2025/12/20251223-6.htm.
4 Law No. 6585 on the Regulation of Retail Trade, Article 18, and Article 22 of the Regulation. For platform breaches under Article 12(2) of the Regulation, also Articles 11(1) and 12(1)(d) of Law No. 6563 on the Regulation of Electronic Commerce and the 2026 penalties Communiqué, Official Gazette of 25 December 2025, No. 33118. The grounds for sanctions on the listing business and on the platform must be distinguished.
5 Municipal Revenues Law No. 2464, Articles 12–16, and the relevant municipality's listing, advertising and promotion regulations and current tariffs. For tax breaches, the applicable provisions of Tax Procedure Law No. 213. No assessment of permits or amounts for a particular municipality or advertising space has been made.
6 Misdemeanours Law No. 5326, Articles 15 and 17(7): a single act constituting several misdemeanours and annual revaluation of administrative fines.
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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