bt_bb_section_bottom_section_coverage_image

E-Commerce Law and ETBİS Compliance for Foreign Online Sellers in Turkey

E-Commerce Law and ETBİS Compliance for Foreign Online Sellers in Turkey

E-Commerce Law and ETBİS Compliance for Foreign Online Sellers in Turkey

There is a Turkish e-commerce rule that directly bans a standard paid search tactic, applies to every online seller regardless of size, and appears almost nowhere in English-language guidance. Under the Law on the Regulation of Electronic Commerce, an e-commerce service provider may not run search engine advertising using the brand of a domain name registered in ETBİS by a party it is not connected to, without that party’s consent.

If your Turkish paid search strategy includes bidding on competitor brand terms — normal practice in most markets — that is the rule to check before your first campaign, not after a complaint.

It sits inside a broader compliance picture that foreign sellers routinely underestimate. Selling online to Turkish consumers engages three separate regimes: registration and platform obligations under Law No. 6563 and ETBİS, distance selling obligations under consumer protection law, and commercial messaging rules through İYS — alongside data protection, which is a fourth.

This guide covers what a foreign online seller has to register, what your site has to display, the withdrawal right that can extend from fourteen days to over a year, the thresholds that trigger heavier obligations, and where marketplaces sit in the liability chain.

Table of Contents

The layers you have to satisfy

Foreign teams tend to think of “Turkish e-commerce compliance” as one project. It is four, with different authorities and different failure modes.

Layer Main instrument What it governs
E-commerce regulation Law No. 6563, as amended by Law No. 7416 ETBİS registration, platform obligations, advertising restrictions, licensing
Distance selling Law No. 6502 and the Distance Contracts Regulation Pre-contract information, withdrawal right, refunds, delivery
Commercial messaging Law No. 6563 and the associated regulation, via İYS Consent for email, SMS and calls
Data protection KVKK (Law No. 6698) Processing of personal data, transfers, consent

Satisfying one does not satisfy the others. The data protection layer is covered in our guide to KVKK compliance for foreign brands, and the messaging layer in our guide to email marketing in Turkey. This article covers the first two.

ETBİS: the registry that comes first

ETBİS — the Electronic Commerce Information System — is the official registry maintained by the Ministry of Trade for e-commerce activity in Turkey. Service providers register through the Ministry’s e-commerce portal with details including their domain name, contact information, registered electronic mail address and trade registry data.

Two things make ETBİS more consequential than a routine filing.

It is the reference point for other obligations. The domain name registered in ETBİS is what the search advertising prohibition below attaches to. Registration is not only administrative; it defines a protected asset.

It is the Ministry’s reporting infrastructure. Transaction volume data flows through ETBİS, and that data determines which tier of obligations applies to a business. The e-commerce volume figures the Ministry publishes annually come from this system.

For a foreign brand, the practical question is which entity in your Turkish structure carries the registration. If you sell through a Turkish company, that company registers. If you sell through a distributor or a marketplace seller of record, the registration sits with them — which means the protected domain and the compliance record sit with them too. That is worth settling deliberately rather than by default.

The search advertising prohibition

This is the provision with the most direct effect on a marketing plan, and the one foreign teams are least likely to know.

Law No. 6563 provides that an e-commerce service provider may not carry out search engine advertising using the brand of a domain name registered in ETBİS by persons with whom it has no connection, without the consent of that party. Legal analysis of the provision notes that this obligation applies to all e-commerce service providers, with no volume or transaction threshold attached.

Three implications for a foreign seller:

  • Competitor brand bidding is not a free tactic here. A practice treated as ordinary competitive behaviour in many markets is addressed directly by Turkish e-commerce law. Before running Turkish paid search on brand terms belonging to other e-commerce businesses, get a legal read on where the line sits for your specific campaign.
  • The protection works in your favour too. If competitors are bidding on your registered domain brand in Turkey, you are not limited to platform trademark complaints — there is a statutory obligation available to you as well.
  • It is a reason to register properly and early. The protection attaches to the ETBİS-registered domain name brand, which makes registration a defensive asset rather than paperwork.

This interacts closely with how you structure Turkish paid search generally, covered in our guide to Google Ads and Meta Ads in Turkey, and it is a good example of why compliance literacy matters when choosing a digital marketing agency in Turkey. An agency running a standard international brand-bidding playbook here is creating exposure you will own.

The tiered regime, and why thresholds are not one number

Law No. 7416, published in the Official Gazette of 7 July 2022, restructured Turkish e-commerce regulation into a tiered system. Obligations escalate with scale, measured by net transaction volume and transaction count.

The structure distinguishes between electronic commerce intermediary service providers — marketplaces — and electronic commerce service providers, meaning sellers. Thresholds differ between the two, and additional obligations layer on at successive levels. Legal summaries describe, for example, marketplaces above certain volume and transaction thresholds facing advertising and discount budget limits, restrictions on offering connected financial or payment services, and requirements to separate logistics and listing activities. Sellers above their own thresholds can face analogous application of parts of the regime.

A warning that matters more than the numbers. Turkish legal commentary is explicit that there is no single “e-commerce threshold” you can look up. Thresholds differ between marketplaces and direct sellers, differ again for advertising budgets and licence calculations, and several obligations carry a separate transaction-count condition alongside the volume figure. Assessing your position from one number found online produces the wrong answer.

The figures also move. Thresholds are indexed to consumer price inflation, and the Ministry of Trade announced in 2026 that the annual change in e-commerce volume as at the end of 2025 was 48.07 percent, with thresholds applicable to 2025 net transaction volumes increased accordingly.

For most foreign brands entering Turkey, these thresholds are far above your scale and the practical relevance is different: they explain the behaviour of the marketplaces you sell through. If your marketplace partner’s advertising budget is capped by law and usable only in quarterly instalments, that shapes when platform-funded promotion is available to you.

Advertising and promotion budget caps

The mechanism is unusual enough to be worth understanding even if it does not apply to you directly.

For businesses caught by the relevant thresholds, Law No. 6563 caps advertising expenditure by formula: net transaction volume is adjusted by the twelve-month average consumer price index change for the same calendar year, and advertising spend in the following calendar year is capped at up to 2 percent of the first TRY 30 billion of that adjusted amount and up to 0.3 percent of the portion above it.

The same calculation basis applies to promotions — the law refers to promotions, rewards, points, coupons, gift vouchers and similar benefits offered in the following calendar year.

Two further features shape how these budgets behave in practice. The calculated amount forms a total budget shared between the intermediary and the sellers within its economic integrity operating on the marketplace, distributed in proportion to their contribution to net transaction volume. And no more than one quarter of the budget may be used in any three-month period of a calendar year.

That quarterly constraint is the part with visible commercial consequences. It limits how much promotional firepower a large marketplace can concentrate into a single peak period — which is worth knowing when planning around Turkish sales events. The seasonal picture is covered in our Ramadan and Black Friday marketing calendar for brands in Turkey.

What a marketplace may not do to you

One provision is straightforwardly protective of sellers, and foreign brands frequently do not realise they have it.

Law No. 6563 provides that an e-commerce intermediary service provider may not restrict a seller’s commercial relationships, may not restrict the seller from offering goods or services through alternative channels at the same or a different price, and may not restrict the seller from advertising. It may not compel the seller to obtain goods or services from any particular person, and may not include any provision enabling such restrictions in the intermediary agreement.

For a brand selling on a Turkish marketplace while also running its own site, this matters directly. Pricing differently on your own store, advertising your own channel, and maintaining other sales routes are protected activities rather than concessions to negotiate.

The commercial context of selling through Turkish marketplaces is covered in our guide to Hepsiburada and Amazon Turkey advertising, and the comparison layer that sits alongside them in our guide to Akakçe and Cimri.

Distance selling: the contract behind every order

Every online sale to a Turkish consumer is a distance contract governed by Law No. 6502 and the Distance Contracts Regulation, and the obligations sit largely on the seller.

Pre-contract information is mandatory. The consumer must be informed clearly, comprehensibly and legibly before the contract is concluded, in writing or through a durable medium such as SMS, email or the website. This is the ön bilgilendirme requirement, and it covers the essential terms of the transaction including the withdrawal right.

Delivery has a deadline. The seller must deliver within 30 days of the order reaching it, and the consumer may withdraw from the contract where that is not met.

Proof sits with the seller. The obligation to inform the consumer about the withdrawal right rests with the seller, and so does the burden of proving it was done.

For a foreign brand, the practical consequence is that your Turkish checkout flow needs to be built to produce and retain evidence, not just to display text. A global platform that shows terms without logging what was shown, when, and to whom leaves you unable to discharge a burden of proof that Turkish law places on you.

The fourteen-day-plus-one-year trap

The withdrawal right is the single most commercially significant provision in the distance selling regime, and the sanction for getting the disclosure wrong is unusually severe.

The baseline: a consumer may withdraw from a distance contract within 14 days without giving any reason and without paying a penalty. The period starts, for goods, on the day the consumer or a third party designated by them takes delivery, and for services on the day the contract is concluded. The consumer may also withdraw between contract formation and delivery.

The trap: if the consumer was not properly informed about the withdrawal right as the regulation requires, they are not bound by the 14-day period. The withdrawal period then expires one year after the end of the normal period. If proper information is provided within that year, a fresh 14-day period begins from the date the information was given.

In practical terms, an incomplete or missing withdrawal disclosure converts a two-week return window into one that can run for more than a year — on every order placed while the defect persists. For a foreign seller launching with a translated global checkout, this is the highest-cost compliance failure available.

Not every product carries the right. The Regulation lists exceptions, which include goods whose price varies with financial market fluctuations, goods prepared to the consumer’s specifications or personalised, goods liable to deteriorate or expire quickly, and cosmetics, personal care products, audio or video recordings and software whose packaging has been opened. Confirm how the exceptions apply to your specific catalogue rather than assuming.

Refunds and marketplace joint liability

The refund rules are prescriptive, and one of them changes who bears the risk.

The refund deadline. Where the consumer exercises the withdrawal right, the seller must refund all payments collected, including delivery costs where applicable, within 14 days. Under the Regulation as amended, that period runs from the date the goods are handed to the carrier specified in the pre-contract information; where the consumer returns the goods via a different carrier, it runs from the date the goods reach the seller.

The refund method. All repayments must be made in a manner appropriate to the payment instrument the consumer used, at no cost or obligation to the consumer, and in a single payment even where the purchase was made in instalments. For a market where instalment payment is standard, that is an operational requirement worth checking against your payment setup.

Joint liability for marketplaces. In distance contracts concluded through a platform where the intermediary collects the payment, the intermediary is jointly liable with the seller for refunding those payments — except where the price has already been transferred to the seller after delivery. The Ministry’s consumer guidance describes intermediaries as jointly liable for refunds for as long as they collect and hold funds on the seller’s behalf.

One timing note: transitional provisions have deferred the application of parts of the amended Regulation, with the Ministry’s amendment published in August 2024 deferring the application of Article 12 until 1 January 2026 and preserving the previously applicable version until then. Confirm which version applies to your situation at the time you launch.

What your Turkish site has to show

Pulling the obligations together, a compliant Turkish storefront is a build specification rather than a content task:

  • Seller identification — full legal name, address and contact details, consistent with your ETBİS registration.
  • A distance sales contract presented and accepted before the order is completed.
  • A pre-contract information form covering the required elements, delivered in writing or through a durable medium.
  • Withdrawal right information, including how to exercise it and the model withdrawal form from the Regulation’s annex.
  • Clear pricing including taxes and delivery costs, with any instalment presentation consistent with what your payment setup actually offers.
  • Delivery terms reflecting the 30-day obligation.
  • Category-specific withdrawal exceptions stated accurately for the products they apply to.
  • Evidence logging of what was shown and accepted, and when.

This is web and software work sitting alongside legal review — the contract texts come from Turkish counsel, but producing a checkout that displays, captures and retains them correctly is a build. That combination of web development and marketing capability is the kind of work agencies such as Medyae handle, though the legal texts themselves should always come from a qualified Turkish lawyer. The wider conversion side is covered in our guide to conversion rate optimization for e-commerce in Turkey.

Enforcement and penalties

Enforcement sits with the Ministry of Trade, and the sanctions escalate.

Administrative fines apply across the range of obligations under Law No. 6563, with amounts revised over time. For intermediary service providers required to hold an e-commerce licence, legal commentary describes failure to obtain one as leading first to administrative fines and, on repetition, to suspension of activity.

Distance selling breaches are enforced separately under the consumer protection framework, and the Advertising Board supervises advertising content under that same framework — a separate exposure covered in the advertising regulation context.

Because penalty amounts are revalued and the regime has been amended repeatedly since 2022, treat any figure quoted online, including in this article’s sources, as needing confirmation against the current legislation.

Common mistakes

Running competitor brand search ads by default. Turkish e-commerce law addresses search advertising on another party’s ETBİS-registered domain brand directly, for all sellers.

Treating ETBİS as your partner’s paperwork. The registered domain is a protected asset; decide deliberately whose name it sits in.

Translating a global checkout. Pre-contract information, withdrawal disclosure and evidence logging are structural requirements, not text.

Getting the withdrawal disclosure wrong. It converts a 14-day window into one that can exceed a year, on every affected order.

Refunding instalment purchases in instalments. Repayment must be in a single payment.

Assuming one threshold tells you your obligations. Thresholds differ by role, by obligation and by transaction count, and are inflation-indexed.

Accepting marketplace restrictions on your own channels. Restrictions on alternative channel pricing and advertising are addressed by law.

Assuming KVKK compliance covers e-commerce law. Four regimes, four sets of obligations.

Frequently asked questions

What is ETBİS and do foreign sellers need to register?

ETBİS is the Electronic Commerce Information System maintained by Turkey’s Ministry of Trade, where service providers register details including their domain name, contact information, registered electronic mail address and trade registry data. Whether and how registration applies depends on your structure — whether you sell through a Turkish entity, a distributor or a marketplace seller of record — so confirm the position for your specific arrangement with Turkish counsel.

Can I bid on competitor brand keywords in Turkey?

Not without care. Law No. 6563 addresses search engine advertising using the brand of a domain name registered in ETBİS by an unconnected party without that party’s consent, and legal analysis notes the obligation applies to all e-commerce service providers with no threshold. Get a legal read on your specific campaign before running brand-competitive paid search in Turkey.

How long is the return period for online purchases in Turkey?

Fourteen days, without the consumer giving any reason or paying a penalty, starting on delivery for goods and on contract formation for services. If the consumer was not properly informed about the withdrawal right, they are not bound by that period and it expires one year after the normal period ends — with a fresh 14-day period beginning if proper information is given within that year.

When must I refund a Turkish customer?

Within 14 days, including delivery costs where applicable. Under the amended Regulation the period runs from when the goods are handed to the carrier specified in the pre-contract information, or from when the goods reach you if the consumer used a different carrier. Refunds must match the original payment instrument and be made in a single payment even where the purchase was in instalments.

Is the marketplace liable if I fail to refund?

Where the contract is concluded through a platform that collects the payment, the intermediary is jointly liable with the seller for refunding, except where the price has already been transferred to the seller after delivery. In practice, intermediaries are jointly liable while they hold funds on the seller’s behalf.

Do the e-commerce thresholds apply to my business?

Most likely not at entry scale, but you cannot determine it from a single figure. Thresholds differ between marketplaces and direct sellers, differ again for advertising budgets and licence calculations, carry separate transaction-count conditions for some obligations, and are indexed to inflation — the Ministry announced a 48.07 percent increase applicable to 2025 net transaction volumes. Assess your position with Turkish counsel rather than from a published number.

Conclusion

Turkish e-commerce compliance is more prescriptive than most foreign sellers expect, and the costly failures are concentrated in two places. One is the withdrawal disclosure, where an incomplete implementation extends every affected customer’s return window from two weeks to potentially more than a year. The other is paid search, where a tactic treated as routine elsewhere runs into a specific statutory prohibition tied to ETBİS-registered domain brands.

The sequence that works is to settle the registration position before launch, have Turkish counsel produce the contract and pre-contract texts, build the checkout to display and log them rather than merely to show them, and brief your paid search team on the brand bidding rule before the first campaign goes live. None of it is difficult. All of it is expensive to retrofit.

This article is general information based on published legislation as at the date shown. It is not legal advice. E-commerce thresholds, penalty amounts and distance selling provisions change, and transitional arrangements affect which version of a rule applies. Confirm your position with qualified Turkish legal advisors before acting.