A new era for digital gaming platforms: Key amendments to Law No. 5651

Law No. 7578 on Social Services and Amendments to Certain Laws, published in the Official Gazette on 1 May 2026, introduced wide-ranging amendments across several areas, including social services and the protection of children in online environments. Among these amendments are significant changes to Law No. 5651 on the Regulation of Publications Made on the Internet and the Combating of Offences Committed Through Such Publications (“Law No. 5651“), which introduce a number of provisions directly affecting the digital gaming sector.

For the first time, the amendments to Law No. 5651 establish a comprehensive, sector-specific regulatory framework for the digital gaming sector. The key changes are summarised below.

New statutory definitions relating to the digital gaming ecosystem

The amendments introduce, for the first time, statutory definitions of “game”, “game distributor”, “game developer” and “gaming platform” under Law No. 5651.

• “Game” refers to digital games distributed or updated via the internet, which can be played online or offline in an electronic environment.
• A “game distributor” means any natural person or legal entity that manages relationships with sales channels for the purpose of delivering digital games produced or published by a content provider to the end user; coordinates the production and management of licence keys; uses digital rights management systems; and provides financial or technical intermediary services during this process.
• A “game developer” means any natural person or legal entity that designs a digital game or game content, develops the software for such game or content, or manages the development process.
• A “game platform” is defined as any natural person or legal entity that provides the software or technical infrastructure for the display, sale, distribution, downloading or playing of digital games and related content via the internet; and facilitates or coordinates users’ access to games or content, licence management or interaction between users.

These new definitions are significant because they distinguish between the different participants operating within the digital gaming ecosystem. In particular, the separate statutory recognition of gaming platforms, game distributors and game developers will be important in determining which regulatory obligations apply to each category of market participant.

New obligations for gaming platforms

The amendments introduce a broad range of new obligations for gaming platforms, covering matters such as age rating, the appointment of a representative in Türkiye, parental control tools, and the provision of information and documentation to the Information and Communication Technologies Authority (“ICTA”).

• Age rating. Under the amendments, gaming platforms may not offer unrated games; they are required to remove such content from their platforms without prejudice to their responsibilities as content and hosting providers. However, the legislation allows gaming platforms to offer unrated games, provided that they are classified under the highest age category.
• Appointment of a representative in Türkiye. Overseas gaming platforms with more than 100,000 daily accesses from Türkiye are required to appoint a representative in Türkiye, who may be either a natural person or a legal entity. The identity of the appointed representative must be notified to the ICTA by the platform. The representative will be responsible for ensuring compliance with the statutory obligations under Law No. 5651 and responding to notices, notifications and requests issued by the ICTA or by judicial or administrative authorities. In addition, gaming platforms must publish the representative’s details on their websites in a manner that is easily visible and directly accessible. This requirement is intended to ensure that global platforms without a physical presence in Türkiye remain accessible to the competent authorities.
• Parental control tools. The amendments require gaming platforms to provide clear, comprehensible and user-friendly parental control tools. At a minimum, these tools must enable parents to manage account settings and require parental consent for fee-based transactions, including purchases, rentals and paid subscriptions.
• Provision of information and documentation. The amendments also empower the ICTA to request information and documentation from gaming platforms where such information is directly relevant to the implementation of the legislation, including information relating to corporate structure, information technology systems and data processing mechanisms. Platforms are required to comply with such requests without delay and within the period specified by the ICTA, which may not exceed fifteen days.

Consequences of non-compliance

The Law No. 5651 provides for a graduated system of sanctions in cases of non-compliance with the applicable obligations.

As a first step, the ICTA will issue a notice; and if the obligation is not fulfilled within 30 days despite the notice:

• an administrative fine of between TRY 1 million and TRY 10 million may be imposed on the gaming platform.

If the non-compliance continues for a further 30 days following notification of the administrative fine:

• a second administrative fine of between TRY 10 million and TRY 30 million may be imposed.

In determining the amount of the administrative fines, factors such as the nature and severity of the breach, its impact on users, and the damage caused will be taken into account.

If the relevant obligation remains unfulfilled despite the imposition of the second administrative fine, the legislation provides for a phased bandwidth restriction mechanism:

• If the breach in question continues for 30 days following notification of the second administrative fine, an application may be made to the criminal peace court to reduce internet bandwidth by 30%.
• If the breach continues for a further 30 days following the implementation of the court’s order, a request may be made to reduce the bandwidth by up to 50%.

The legislation also provides an incentive for subsequent compliance. If the breach is rectified:

• only one-quarter of the imposed administrative fines will be collected; and
• the bandwidth-restriction decisions will automatically become ineffective.

The amendments will come into force on 1 November 2026. The procedures and principles governing the implementation of the amendments, the details of the obligations to which gaming platforms will be subject, and the rating system based on age criteria will be set out in a regulation to be issued by the ICTA. Further details regarding the scope of the obligations and the implementation of the new regime are expected to become clearer once the secondary legislation comes into force.

Proposed transfer of authority to the Cybersecurity Directorate

On 3 July 2026, a draft law was submitted to the Grand National Assembly of Türkiye proposing that the authority currently vested in the ICTA under Law No. 5651 with respect to the supervision and implementation of gaming platforms’ obligations, as well as the imposition of administrative sanctions, be transferred to the Cybersecurity Directorate. If enacted in its current form, the draft legislation would designate the Cybersecurity Directorate as the competent authority responsible for supervising compliance with the obligation imposed on social network providers and gaming platforms to appoint a representative in Türkiye; determining the procedures and principles governing that obligation and the age-based rating system; imposing administrative fines; applying to the criminal peace court for bandwidth restriction orders; requesting information and documentation; and overseeing platforms.