Significant Amendments to the Regulation on Private Health Insurance

With the amendment published in the Official Gazette dated 20 October 2025 and entering into force on 1 January 2026, important changes have been introduced into the Regulation on Private Health Insurance:

Waiting Period

Insurance companies holding an operating license in the branch of health and sickness insurance are entitled to stipulate waiting periods for insurance contracts, provided that such periods comply with the requirements of insurance practice and the principle of good faith.

A waiting period may be applied only during the first insurance period for each coverage offered under the policy.

The waiting periods and the specific illnesses or special conditions subject to such waiting periods must be explicitly stated in the contract.

Since the procedures and principles regarding waiting periods are to be determined by the Insurance and Private Pension Regulation and Supervision Agency (SEDDK), the implementation details will be provided in the secondary legislation.

Lifetime Renewal Guarantee

Insurance companies licensed in the branch of health and sickness insurance are now obliged to offer contracts including a lifetime renewal guarantee, to individuals purchasing private health insurance or supplementary/supportive health insurance, who have not yet reached the age of 60.

Depending on the policyholder’s preference, contracts with or without a lifetime renewal guarantee may be concluded.

For the lifetime renewal guarantee to be valid, the insured must remain continuously insured under the same plan for three consecutive years, and the total amount of claims paid during this period must not exceed 80% of the total premiums paid.

The guarantee may not be denied to insured persons who meet these conditions. Furthermore, with respect to the policies that include a renewal guarantee, the scope of coverage may not be narrowed, co-payment rates may not be increased, and no additional premium may be charged. Undertakings different than the lifetime renewal guarantee referred to in the Regulation cannot be offered under the name of a renewal guarantee or in a manner that creates the impression of a lifetime renewal guarantee.

Insurance companies may grant a lifetime renewal guarantee to policyholders meeting the assessment conditions specified in the contract; however, they cannot impose stricter conditions than those set forth in the Regulation for obtaining such a guarantee.

It is explicitly regulated that where an insured person benefiting from a lifetime renewal guarantee transfers to another company, the lifetime renewal guarantee shall continue with the new company.

Unless the insured or policyholder requests to be insured under a lower or narrower plan, the new company may not narrow the scope of coverage, reduce coverage limits, or increase co-payment amounts.

However, if an insured person wishes to transfer to another company under a higher or broader coverage plan, the entitlement to a lifetime renewal guarantee may be reassessed by the new company.

It is further clarified that insured persons who leave a group policy with a lifetime renewal guarantee may, by applying within the period specified in the special terms, continue their insurance coverage under one of the individual tariffs of the same company that includes the same plan, or if such plan no longer exists, under the most similar plan available.

Provisions on Personal Data

Insurance companies are now authorized to access, through the Insurance Information and Monitoring Center (SBGM), information on the health condition and medical history of the insured for the purposes of:

• conducting risk assessments for offers, active policies, and renewal transitions,
• determining the boundaries of lifetime renewal guarantees and applicable waiting periods, and
• calculating payable amounts under supplementary and supportive health insurance products.

It is also regulated that the insurance and health records kept by the Center shall be retained for 10 years following the termination of the individual’s insurance coverage. Upon expiry of this period, the Center shall automatically delete, destroy, or anonymize such data in accordance with the Law No. 6698 on the Protection of Personal Data (KVKK).