AI systems entered the daily operations of Turkish companies rapidly after 2024 — customer service chatbots, credit scoring engines, content generation tools and decision-support systems now operate at the intersection of multiple regulatory regimes. With regulatory pressure from Europe and AI legislation moving through Turkey's parliament, AI law has become one of the fastest-developing legal fields in the country.
Turkey does not yet have a dedicated AI law in force. The existing legal infrastructure addresses AI-related issues through general legislation:
Three separate AI-related legislative proposals were submitted to the Turkish Grand National Assembly in late 2025. The stated approach is to create a framework aligned with the EU AI Act through amendments to existing laws rather than a standalone statute.
The EU's Regulation 2024/1689 (AI Act) entered into force on 1 August 2024. Key dates:
Important for Turkish companies: A Turkish company that serves the EU market — providing APIs, software or AI-based products to EU users — may qualify as a "provider" under AI Act Article 2 and be subject to compliance obligations.
If an AI system processes personal data — and most do — all KVKK obligations apply in full. Training data sets, disclosure obligations and automated decision-making mechanisms require particular attention.
The copyright status of AI-generated content is not yet settled under Turkish law. Training data containing third-party content may give rise to infringement claims. The text and data mining exception under FSEK Article 38/A does not provide a safe harbour for commercial models.
When an AI system causes harm, who is responsible? The allocation of liability among developer, operator and user has not been definitively resolved under Turkish law. The core principle: those who use AI as a tool, operate it or profit from it cannot escape liability.
Deepfake content that infringes personality rights can attract both civil damages and criminal sanctions under the Turkish Penal Code.
Note: AI law is evolving very rapidly. The EU's high-risk system requirements take full effect in August 2026, and Turkey is expected to take legislative action. If you use AI in your sector, we recommend assessing your legal position now.
At Koru Legal, we provide advisory on KVKK compliance for AI systems, IP assessment and EU AI Act scope analysis.
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