Running Paid Media in Turkey: A Practical Setup Guide

Start With the Data Question, Because It Decides Your Stack

Turkey's data protection law is Law No. 6698 on the Protection of Personal Data, known by its Turkish initials KVKK, which is also the name of the regulator. The authority publishes the legislation and its decisions at kvkk.gov.tr, and an English translation of the law is available on the same site.

The part that changed recently, and that most foreign marketing teams have not caught up with, concerns sending personal data outside Turkey.

Law No. 7499 was published in the Official Gazette on 12 March 2024 and amended Articles 6, 9 and 18 of the KVKK. The amended transfer rules entered into force on 1 June 2024. The old route, which allowed transfers abroad on the basis of the individual's explicit consent, was permitted only until 1 September 2024.

Since then a transfer abroad has to rest on one of three things:

• An adequacy decision issued by the Board for the destination country
• An appropriate safeguard, meaning standard contractual clauses, binding corporate rules, or a written undertaking approved by the Board
• One of a narrow set of exceptional cases set out in the law

The standard contractual clauses have to be used in the form the Board publishes, in Turkish, and notified to the authority within five business days of signature. That notification step is the one that gets missed, because it has no analogue in the European process most teams are used to.

Why this matters to a media team rather than a legal team: advertising platforms, analytics, customer data platforms, email tools and call tracking commonly involve sending personal data outside Turkey. Whether a given tool does so, and on what basis, is a question for Turkish counsel with your contracts in front of them. The point for planning is that the answer may have changed since 2023, so it is worth asking rather than assuming.

One more practical point. Turkish consent is explicit consent, defined narrowly, and it has to be specific and freely given. Marketing teams arriving from a market where legitimate interest carries a lot of weight should not assume the same reasoning transfers.

Check Whether ETBIS Registration Applies

Turkey operates ETBIS, the Electronic Commerce Information System, through the Ministry of Trade. Certain electronic commerce businesses are required to register, and registered providers are listed publicly on the Ministry's e-commerce registry.

The obligation is generally framed around service providers selling through their own electronic commerce platform, intermediary service providers, and certain providers based outside Turkey that take orders through an intermediary. Whether it catches your business depends on your model, where you are established and how you sell, so confirm the position with a Turkish adviser rather than assuming either way. Where it does apply, registration is expected before activity begins and non-registration can attract administrative fines.

The governing framework is the Law on the Regulation of Electronic Commerce, No. 6563, and the secondary regulation issued under it. The Ministry of Trade publishes both through the Ministry of Trade site.

There is a marketing consequence beyond the compliance one. A registered, verifiable trader is visible to Turkish consumers as legitimate. In a market where trust in unknown online sellers is a real conversion barrier, that visibility earns its keep.

Advertising Rules Have Teeth Here

Advertising in Turkey is supervised by the Advertising Board, the Reklam Kurulu, which sits under the Ministry of Trade and operates under Law No. 6502 on Consumer Protection and the Regulation on Commercial Advertisement and Unfair Commercial Practices.

The Board reviews advertising, publishes its decisions, and can order suspension of an advertisement as well as issuing fines. Its decisions are published through the Ministry of Trade's consumer protection pages.

Three areas produce most of the problems for foreign advertisers:

• Comparative and superlative claims. Statements such as best, first or number one need substantiation, and the standard applied is stricter than many advertisers expect.
• Price and discount presentation. Rules govern how a reduced price is shown against a previous price, including how long the previous price must have applied.
• Influencer content. The Board has issued specific guidance on influencer advertising, including how commercial relationships must be disclosed. Treat a paid creator post as an advertisement subject to the same rules as a television spot.

Budgeting in Lira Is an Active Task

This is a straightforward operational point that costs money when it is ignored.

The Turkish lira has moved substantially over recent years. The Central Bank of the Republic of Turkey publishes official exchange rates and inflation data through its website and the EVDS statistical database, and the Turkish Statistical Institute publishes consumer price index releases at tuik.gov.tr. Those are the numbers to plan against rather than a figure someone remembers from last year.

What this means in an ad account:

• Decide your billing currency deliberately. An account billed in a foreign currency and spending against Turkish auctions will show you movement that has nothing to do with campaign performance.
• Review budgets monthly, not annually. A daily budget set twelve months ago may now buy a fraction of what it did.
• Separate real performance change from currency change in reporting. If your cost per acquisition rises in reporting currency but is flat in lira, that is a finance story rather than a media one, and the two need different responses.
• Watch target cost per acquisition settings. Automated bidding against a target that has drifted out of date will quietly throttle delivery.

Worked example: what budget drift looks like

The figures below are illustrative and exist to show the mechanism. Pull the actual index from TurkStat and the actual auction costs from your own account.

Suppose you set a daily budget of TRY 5,000 in January at a cost per acquisition of TRY 250, giving 20 conversions a day. Assume auction costs rise 30 per cent over the following twelve months while the nominal budget stays untouched.

Volume falls by roughly a quarter with nobody changing a setting and nothing wrong with the campaign. Holding 20 conversions a day at month twelve needs about TRY 6,500.

Two things follow. First, an annual budget signed off in nominal lira is a shrinking budget, so review it on a schedule rather than when someone notices. Second, if you report to a head office in another currency, separate the two effects before drawing conclusions: a cost per acquisition that is flat in lira but rising in euros is a currency movement, and cutting the campaign is the wrong response to it.

Write Turkish, Do Not Translate Into It

Turkish is agglutinative, which means grammatical information is carried by suffixes stacked onto word stems. A single Turkish word can carry what English needs a phrase for. This has direct consequences for advertising work.

• Character counts behave unpredictably. A headline that fits comfortably in English may overflow in Turkish, or come in far shorter. Check every ad format against the real limits.
• Keyword matching is affected by suffixes. One concept can appear in many inflected forms. Broad and phrase match behave differently from what you would expect in English, and your negative keyword list needs to account for inflection.
• Machine translation reads as machine translation. In a market where local competitors write natively, that difference is visible to the reader and it shows up in click-through rate.
• Dotted and dotless i. Turkish distinguishes them, and case conversion in software frequently gets this wrong. Check your automated ad text, your feed and your form validation.

Where People Actually Are

Google is the dominant search engine in Turkey, so search campaign practice transfers reasonably well. Ecommerce is different. A large share of online buying happens on domestic marketplaces rather than on brand websites, so an acquisition plan that only considers your own storefront may be aiming at the smaller half of the market.

Decide early between a direct storefront, marketplace selling, or both, because that decision changes the entire measurement setup. Marketplace sales generally will not appear in your own analytics, and reconciling them requires deliberate work.

Which Route Are You Taking

Three common setups, and what each one changes:

The Order to Do It In

1. Establish which entity holds Turkish customer data, then confirm with counsel which tools involve a transfer abroad and on what basis under the amended KVKK
2. Where standard contractual clauses are the chosen route, adopt the Board's published form and file the notification within five business days
3. Check with a Turkish adviser whether ETBIS registration applies to your model, and register before trading if it does
4. Review ad claims, pricing presentation and any influencer contracts against Advertising Board rules
5. Set the account billing currency deliberately and put a monthly budget review in the calendar
6. Commission Turkish copy from a Turkish writer, then check it against every ad format's character limits
7. Build the negative keyword list with inflected forms in mind
8. Decide the marketplace question and design measurement around the answer

Turkey rewards preparation. The market is large, digitally active and competitive, and the difference between a campaign that reads as local and one that reads as imported is mostly the groundwork above.

This is an operational summary rather than legal advice. Where the compliance points apply to you, take Turkish legal advice on the specifics.

Sources

• Personal Data Protection Authority of Turkey (KVKK)
• KVKK guidance on the 2024 cross-border transfer amendments, Law No. 7499, published 12 March 2024
• Republic of Turkey Ministry of Trade, ETBIS electronic commerce information system
• Central Bank of the Republic of Turkey
• Turkish Statistical Institute (TurkStat)