E-Commerce Law
in Turkey

01 / Online Business

E-Commerce Law in Turkey

An online business needs clear responsibilities from the first product listing to the final refund. The website, contracts, payment arrangements and customer support should tell the same story about who sells the product and how problems are handled.

Legal Istanbul advises on online sales documents, website practices, commercial relationships and disputes. A review may cover a new store, an established marketplace account or a particular complaint. The starting point is the actual order process, including what customers see on mobile devices.

The Ministry of Trade's framework includes Law No. 6563 and its implementing rules. Consumer Protection Law No. 6502, the Distance Contracts Regulation and Personal Data Protection Law No. 6698 address different parts of the operation. Product-specific rules can also apply.

02 / Scope Of Advice

Legal Support for Sellers and Platforms

The engagement identifies the business, channels, countries and documents covered. A contract review does not automatically include technical testing, all historical orders or ongoing representation.

Legal drafting should be connected to implementation. Agree who changes checkout screens, updates software settings and trains support staff. A written policy cannot establish that the underlying system works as described.

03 / Identifying The Parties

Direct Sales, Marketplaces and Business Customers

Identify the contracting seller, payment recipient and fulfilment provider for each channel. These may be different businesses. A supplier shipping directly to the customer does not answer who owes the contractual duties.

Consumer protections concern purchases outside commercial or professional purposes. A wholesale order for resale needs a different analysis from a household purchase. Calling every buyer a business customer in the terms does not settle the question.

04 / Different Systems

ETBIS, IYS and VERBIS

ETBIS records relevant e-commerce activity. IYS concerns commercial electronic-message permissions. VERBIS is the data-controller registry. Their purposes and entry conditions differ; completing one does not resolve the others.

The Ministry's ETBIS guidance distinguishes own-site sellers and intermediaries from sellers operating only through domestic marketplaces. The latter do not have an ETBIS duty merely because of those marketplace sales. Other channels and overseas-platform activity require separate assessment.

VERBIS registration depends on the controller's circumstances and applicable exemptions. The Authority's registry guidance explains the distinction. An exemption from registration does not remove the underlying data-protection duties.

Record the reason for each registration decision and review it when turnover, staffing, activities or sales channels change. Company establishment and accounting registrations need their own work plan with the responsible advisers.

05 / Before An Order

Customer Information and Distance-Sales Documents

Prepare the customer documents around the real checkout. Check seller contact details, product description, total price, extra charges, delivery arrangements and the applicable withdrawal information before payment. These are central points in the Ministry's distance-contract guidance.

Walk through a sample purchase with the operations team. Compare the product page, basket, final approval screen and email confirmation. Note where the customer can correct an address or quantity and where the accepted documents are stored.

Keep dated versions linked to orders. If the customer complains months later, today's terms may not show what was agreed. Avoid a process in which one team updates a return policy while another continues sending an older confirmation template.

Translations should preserve legal meaning and match the actual service language. Identify which document controls where permitted, without assuming a language clause can remove mandatory customer rights.

06 / Return Decisions

Withdrawal Rights and Statutory Exceptions

The ordinary consumer withdrawal period is 14 days, generally from delivery for goods and contract formation for services. Statutory exceptions apply. Merely writing "non-returnable" does not create an exception.

Separate withdrawal from returning goods and paying the refund. Under current guidance, the refund clock for returned goods depends on dispatch through the designated carrier or receipt when another carrier is used. Return costs cannot be imposed when the designated carrier is used or none was identified.

A practical review should classify products before support staff answer customers. Bespoke products, sealed hygiene items and digital supplies need different questions about the product and circumstances. Record the legal reason for any refusal and the evidence supporting it.

Do not copy a supplier's return restriction into customer terms without checking it. A supplier's willingness to take stock back and the online seller's duties to a customer are separate issues.

07 / After The Order

Delivery Problems and Defective Products

A defect claim is different from a change-of-mind return. The Ministry's defective-goods guidance explains remedies including repair, replacement, price reduction and ending the contract, subject to the relevant conditions. An expired withdrawal period does not itself defeat a defect claim.

Collect the order, listing, delivery record, photographs and correspondence. Distinguish missing delivery, transport damage, the wrong item and a product that does not perform as described. A support response should address the actual complaint.

Agree how the warehouse preserves returned items and records inspections. Ask who can authorise a refund and how that decision reaches the payment team. Avoid closing a complaint simply because one internal department has completed its part.

08 / Commercial Relationships

Marketplace, Supplier and Logistics Contracts

Read the platform agreement together with its fee schedules, account policies and notices. Focus on settlement deductions, payment reserves, access to order records, suspension, termination and routes for challenging decisions.

Under the e-commerce framework, marketplace relationships are also subject to rules addressing unfair commercial practices. A contractual power should therefore be assessed against the governing law and the way it was used.

For operators, additional duties and licensing questions depend on statutory categories and scale. Check the current ETBIS notices and threshold updates; the same checklist should not be applied to every store and platform.

Supplier and logistics agreements should explain product documentation, stock information, damaged goods, customer complaints and reimbursement between the businesses. The Commercial Contracts service covers these commercial terms in greater detail.

09 / Customer Information

KVKK Notices, Processing Grounds and Cookies

Under the Personal Data Protection Law, each use of personal data needs an applicable legal basis. Consent is not the only basis. Order fulfilment, legal records and optional advertising should be assessed separately, with clear information for the individual.

Map what the store sends to couriers, payment providers, support tools and advertising services. Limit access, address individual requests and set justified retention periods. Keeping every record indefinitely is not a sound default.

The Authority's cookie decision and guidance distinguish necessary functions from processing requiring consent. Where consent is required, obtain it before that processing starts and offer a real choice. A notice saying that continued browsing means acceptance is insufficient.

Ask the technical team to show what loads before a choice, after rejection and after withdrawal. The legal review and technical findings should describe the same behaviour, including third-party tools added after launch.

10 / Overseas Services

Foreign Hosting, Data Transfers and GDPR

Overseas storage or access can engage Turkey's transfer rules. Under the current transfer framework, review adequacy, appropriate safeguards and the limited exceptions for incidental transfers. A routine cloud arrangement should not simply rely on a general consent checkbox.

Where standard contracts are appropriate, identify the parties' roles, select the correct form and address the notification requirement. List the actual service providers and destinations before choosing the mechanism.

GDPR is a separate assessment. The EDPB's territorial-scope guidance considers establishment, offering goods or services to people in the EU and monitoring behaviour there. A website being accessible from Europe does not alone establish applicability.

Confirm whether foreign counsel or additional technical work is needed. Turkish documentation should not be presented as automatic compliance with every country's privacy rules.

11 / Customer Communications

Electronic Marketing and IYS Permissions

Review promotional email, SMS and calls separately from necessary order communications. The Ministry's messaging guidance explains prior permission and the merchant or tradesperson exception. That exception does not remove the right to refuse further marketing.

Check the applicable IYS registration and permission-recording duties. Keep evidence of how a permission was obtained, the sender and channel covered, and any refusal. Accepting sales terms should not be treated as blanket permission for every campaign.

Review the content as well as the mailing list. An order update containing a promotional offer may need different treatment from a simple delivery notice. Agree who updates suppression lists when an opt-out arrives through customer support rather than the marketing tool.

12 / Connected Duties

Product Safety, Brand Rights and Payment Records

Website terms do not establish that a product may lawfully be offered. The remote-sales product-safety regulation has applied since 1 April 2025. Review the relevant product category, responsible businesses, listing information and any required documentation.

Check who supplied brand names, photographs and descriptions, and what permissions support their use. Preserve licences and supplier assurances. A marketplace accepting a listing should not be treated as a legal opinion on brand rights; separate trademark advice may be appropriate.

Reconcile orders, commissions, refunds and amounts paid by providers. Agree with the accountant how invoices and adjustments are handled. The Tax And Legal Compliance service addresses the related legal questions. Payment processing, bookkeeping and legal advice have different scopes.

13 / Responding To A Claim

Consumer Complaints and Commercial Disputes

Identify whether the issue is a consumer claim, a dispute with a supplier or platform, or an official investigation. Each may require a different response. A payment-provider chargeback is also a separate process with its own evidence requirements.

Consumer arbitration committees and consumer courts have different roles. The Ministry's current procedure guidance sets out the annually updated financial boundary. Certain consumer court claims require prior mediation, with statutory exceptions. Business disputes need their own jurisdiction and procedure analysis.

Preserve the complete notice, proof of service and the transaction record. Calculate each response, objection or court deadline from the relevant document and rule. Discussions with a customer or platform should not be assumed to preserve a formal deadline.

Where a settlement is considered, record what it covers, who pays, how any returned goods are handled and whether separate proceedings remain open.

14 / Preparing The Review

Documents and Access Needed

Begin with the business identity, website addresses, sales countries and a short description of the concern. A focused sample order is often more useful than an unexplained export of all customer data.

Use a suitable transfer method and redact unrelated personal information where possible. Do not send account passwords. Agree controlled access or a demonstration when screens cannot be understood from documents alone.

15 / Working Arrangements

Review Process and Professional Fees

1. Define the Scope

   Confirm channels, products, jurisdictions and any urgent notice.

2. Follow an Order

   Examine customer screens, contracts, payment and support records.

3. Explain the Findings

   Identify required changes, missing facts and decisions for the business.

4. Prepare Agreed Work

   Draft documents, advise on implementation or handle authorised proceedings.

5. Confirm Responsibilities

   Record completed work and who maintains documents and monitors notices.

Fees depend on document volume, channels, languages, technical complexity and whether a dispute is included. Legal fees, development work, accounting, translation, court expenses and external specialist advice are separate items. The engagement should identify included work and approval of additional costs.

Agree which website version is being reviewed and how later changes will be reported. Delivery dates depend on access, missing documents and the work required. Sending an enquiry does not appoint the firm to monitor deadlines; urgent representation requires express acceptance.

16 / Questions And Answers

Common Questions About E-Commerce Law