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“Law Proposal on Amendments to the Social Services Law and Certain Other Laws” (the “Law”) entered into force on 1 May 2026. The Law introduces significant amendments to Law No. 5651 on the Internet and Fighting Against Crimes Committed through Internet Broadcasting Law (“Law No. 5651”), regarding protection of children in digital environments, the introduction of new rules for the gaming sector, and obligations imposed on large scale social network providers.
1): The Gaming Ecosystem Now Falls Within the Scope of Law No. 5651
The Law introduces new definitions to the definitions section of Law No. 5651, clarifying the roles within the gaming ecosystem. Under the Law, a game is defined as a digital game that is distributed, played, or updated via the internet. Developers of games or in-game components are classified as game providers, while those who enable the distribution or playing of such games are defined as game distributors. A game platform is defined as a real or legal person that enables the online presentation, distribution or playing of digital games and additional content via internt, and manages user acces and interactions.
2) Obligations Imposed on Social Network Providers
Upon entry into force of the Law, the obligations of social network providers have been extended. Social network providers will now be required to respond not only to applications concerning violations but also to other requests provided for under the Law
The Law also broadens their reporting obligations. In addition to decisions on content removal and/or access blocking, the six-monthly reports will also need to include statistical and categorical data on practices relating to the obligation to proactively prevent the publication of the relevant content on the provider’s own website, as well as statistical and categorical data relating thereto.
The Law also introduces restrictions on the provision of services to minors. In this respect, the provision of social network services to children under the age of 15 is now prohibited entirely. Social network providers are thereforerequired to implement age verification systems to ensure compliance with this restriction. For users who have reached the age of 15 but are still minors, the Law requires social network providers to offer child-specific safe services and to publish the measures implemented in this regard on their websites.
The time limit for social network providers to the Information and Communication Technologies Authority regarding compliance with Law No. 5651 is reduced from three months to fifteen days.
Social network providers are also be required to provide clear and user-friendly parental control tools. These tools must include essential functions such as enabling parental control over account settings, making purchases and paid transactions subject to parental approval, and monitoring and limiting usage time.
Social network providers are required to take measures to prevent deceptive advertising on their platforms.
Large-scale social network providers with more than 10 million daily accesses from Türkiye are required to implement decisions issued under Article 8/A in cases where delay would be prejudicial immediately and no later than within one hour.
Social network providers with more than 10 million daily accesses from Türkiye are required to establish the necessary technical infrastructure, including artificial intelligence and automated systems, to proactively prevent the re-upload of content that has previously been determined to be unlawful and ordered to be removed or blocked.
In the event of a breach of key obligations—such as data security, protection of children, cooperation with judicial authorities, crisis planning, and the prevention of deceptive advertising—the relevant social network provider may be subject to an administrative fine of up to 3% of its global turnover in the preceding calendar year.
3) Obligations Imposed on Game Developers and Game Distributors
The Law also introduces obligations for actors in the gaming sector, in addition to social network providers.
Game providers are required to classify games according to age criteria. Game distributors will not be permitted to offer games that have not been properly classified. However, distributors may offer games that have not been classified by the game provider, provided that such games are classified according to the highest age category.
Foreign-based game distributors with more than 100,000 daily accesses from Türkiye will be required to appoint a natural or legal person as a representative in Türkiye and notify the Authority of such representative.
Game distributors, similarly to social network providers, will be required to provide parental control tools. At a minimum, these tools must enable parental control over account settings and require parental approval for purchases and paid transactions.
The Authority may request all types of explanations from game developers and game distributors, including information regarding their corporate structure, information systems, algorithms, data processing mechanisms, and commercial practices. The requested information and documents must be submitted to the Authority immediately and no later than within fifteen days.
A gradual sanction mechanism will apply in cases where obligations are not fulfilled:
Stage 1: If the obligation is not fulfilled within 30 days following notification, an administrative fine between TRY 1,000,000 and TRY 10,000,000 may be imposed.
Stage 2: If the obligation is still not fulfilled within 30 days following the notification of the first fine, a second administrative fine between TRY 10,000,000 and TRY 30,000,000 may be imposed.
Stage 3: If the obligation remains unfulfilled within 30 days following notification of the second fine, an application may be made to the criminal judgeship of peace for the reduction of internet traffic bandwidth by 50%.
Stage 4: If the obligation remains unfulfilled within 30 days following the implementation of the bandwidth reduction decision, a second application may be made for reducing bandwidth by up to 90%.