Artificial intelligence is reshaping industries, economies, and legal systems around the world — and Turkey is no exception. As AI-powered tools become embedded in healthcare, finance, e-commerce, and public administration, the need for a clear and enforceable legal framework has never been more urgent. For foreign nationals doing business or living in Turkey, understanding how Turkish law approaches artificial intelligence is essential for compliance, investment planning, and protecting your rights.
Turkey’s Current Legal Landscape for AI
Turkey does not yet have a single, dedicated AI law. Instead, the regulation of artificial intelligence is distributed across several existing pieces of legislation, sector-specific rules, and emerging policy frameworks. This approach mirrors the early regulatory posture of many jurisdictions, including the European Union before it adopted the EU AI Act. However, Turkey is moving quickly to consolidate its position, and significant legislative developments are expected in the coming years.
The primary legal instruments currently governing AI-related activities in Turkey include the Personal Data Protection Law (KVKK, Law No. 6698), the Turkish Commercial Code, the Law on Electronic Commerce, the Turkish Penal Code, and sector-specific regulations issued by bodies such as the Banking Regulation and Supervision Agency (BDDK) and the Information Technologies and Communication Authority (BTK).
Personal Data Protection and AI: The KVKK Framework
One of the most significant legal constraints on AI systems in Turkey is the Personal Data Protection Law (KVKK), which closely mirrors the EU’s GDPR. Any AI application that collects, processes, stores, or analyses personal data must comply with KVKK requirements. This is particularly relevant for AI tools used in areas such as facial recognition, behavioural analytics, hiring algorithms, and customer profiling.
Key obligations under KVKK that directly affect AI developers and users include:
- Obtaining explicit consent from data subjects before processing personal data
- Registering data processing activities with the Personal Data Protection Authority (KVKK Kurumu) through the VERBIS system
- Ensuring data minimisation — collecting only what is strictly necessary
- Implementing adequate technical and administrative security measures
- Complying with rules on cross-border data transfers, which affect cloud-based AI services hosted outside Turkey
Automated decision-making is another critical area. Under KVKK, individuals have the right not to be subjected to decisions based solely on automated processing if those decisions produce legal or similarly significant effects. This provision has direct implications for AI-driven credit scoring, recruitment screening, and insurance underwriting systems operating in Turkey.
Intellectual Property Rights and AI-Generated Content
Turkish intellectual property law, governed primarily by the Law on Intellectual and Artistic Works (FSEK, Law No. 5846), does not currently recognise AI as an author or rights holder. Ownership of AI-generated content remains a complex and evolving issue. In practice, Turkish courts and the Turkish Patent and Trademark Office (Türkpatent) attribute authorship to the human or legal entity responsible for creating and directing the AI system.
For businesses deploying generative AI tools to produce content, software, or creative works in Turkey, this creates important considerations around licensing agreements, work-for-hire clauses, and the contractual allocation of IP rights. Foreign companies and entrepreneurs should ensure their contracts clearly define ownership of AI-generated outputs.
Liability for AI Systems Under Turkish Law
Turkish law does not yet have specific provisions addressing AI liability. Current cases are analysed under general principles of tort law as set out in the Turkish Code of Obligations (Law No. 6098), product liability regulations, and contract law. If an AI system causes harm — whether through a biased decision, a data breach, or a physical malfunction — liability may fall on the manufacturer, the developer, the deploying company, or in some cases the end user, depending on the circumstances.
The lack of a dedicated liability framework creates legal uncertainty, particularly for businesses deploying autonomous or semi-autonomous systems. As Turkish courts begin to encounter more AI-related disputes, case law will increasingly fill this gap until dedicated legislation is enacted.
Turkey’s National AI Strategy and Upcoming Legislation
Turkey published its National Artificial Intelligence Strategy (2021–2025) through the Ministry of Industry and Technology. The strategy outlines goals for AI investment, talent development, and regulatory infrastructure. It signals the government’s intention to position Turkey as a regional AI hub while developing a risk-based regulatory approach aligned with international standards.
Turkish lawmakers are closely monitoring the EU AI Act, which entered into force in 2024, and it is widely anticipated that Turkey — as an EU candidate country — will introduce harmonised AI legislation in the medium term. Foreign investors and businesses should prepare now by auditing their AI systems against both KVKK requirements and the risk-classification model established by the EU AI Act.
Sector-Specific AI Regulations in Turkey
Several Turkish regulatory bodies have begun issuing guidance specific to AI use within their sectors:
- Banking and Finance: The BDDK has issued circulars addressing the use of algorithmic models and machine learning in credit risk assessment and fraud detection.
- Healthcare: The Ministry of Health regulates AI-powered medical devices and diagnostic tools, requiring compliance with both Turkish medical device law and applicable EU standards under Turkey’s customs union obligations.
- Telecommunications: The BTK oversees AI applications within communication networks and has authority to audit algorithmic systems that affect consumer rights.
- Capital Markets: The Capital Markets Board of Turkey (SPK) monitors the use of automated trading systems and robo-advisors.
Practical Advice for Foreign Nationals and Businesses
Navigating AI law in Turkey requires a multi-layered legal approach. Whether you are a foreign entrepreneur launching an AI startup in Antalya, a multinational deploying AI-driven HR tools across your Turkish operations, or an individual whose rights have been affected by an automated decision, understanding your legal position is critical.
Mona Hukuk, an Antalya-based law firm with specialist expertise in AI Law and IT Law, advises foreign nationals and international businesses on all aspects of technology law in Turkey. The firm’s experience at the intersection of Turkish law and emerging technology makes it a practical first point of contact for anyone navigating this rapidly evolving field.
Get Expert Legal Advice on AI Law in Turkey
As Turkey’s AI regulatory environment continues to develop, staying informed and legally compliant is not optional — it is a business imperative. Whether you need guidance on KVKK compliance for your AI platform, intellectual property protection for AI-generated assets, or advice on upcoming legislative changes, professional legal support can make a decisive difference.
Contact Mona Hukuk today to speak with a qualified Turkish lawyer specialising in AI and technology law. Reach the team by email at info@monarights.com or by phone at +90 (532) 390 05 10. The firm serves clients across Turkey and is fully equipped to advise in English.