Bill on Foreign Digital Accommodation Platforms Submitted to the Turkish Grand National Assembly

On 10 August 2026, the “Bill on Foreign Digital Accommodation Platforms” (the “Bill”) was submitted to the Speakership of the Turkish Grand National Assembly (“TBMM”). The Bill aims to establish the procedures and principles governing the activities carried out in Türkiye by foreign digital accommodation platforms through electronic commerce, and to regulate the conditions, obligations and sanctions applicable to such activities.

The general rationale notes that the absence of specific legislation on foreign digital accommodation platforms currently gives rise to various legal and administrative difficulties in practice, particularly with respect to the supervision of such activities, consumer protection, compliance with tax and financial obligations, ensuring fair competition in the sector, and the conduct of relations with public authorities.

Mandatory Permit Requirement

Under the Bill, foreign digital accommodation platforms will be required to obtain a permit from the Ministry of Culture and Tourism (the “Ministry”) in order to operate in Türkiye. The permit fee is set at TRY 5 million, to be increased annually in line with the revaluation rate, with the President of the Republic authorised to increase this amount by up to two times or reduce it by up to half. The permit will be valid for two years and may not be transferred.

To obtain a permit, platforms must be digital service tax payers, have no outstanding tax debts, designate a domestic contact address together with a responsible Turkish citizen or legal entity, and notify their National Electronic Notification System address. Platforms must also designate at least one representative in Türkiye; where the representative is a legal entity, it must be incorporated as a capital company and at least one of its authorised representatives must be a Turkish citizen resident in Türkiye, while an individual representative must likewise be a Turkish citizen resident in Türkiye.

Scope of Activities and Applicable Law

Foreign digital accommodation platforms will be permitted to directly conduct electronic commerce for tourism-certified accommodation establishments and permit-holding tourism rental residences, as well as electronic air ticket sales. Beyond this, the trade of services exclusively offered by travel agencies may only be carried out through licensed travel agencies, and vehicle rental services only through undertakings authorised by the Ministry of Trade. Disputes arising from activities within the scope of the permit will be governed exclusively by Turkish law, with Turkish courts having exclusive jurisdiction.

Obligations of Platforms

The Bill imposes a number of obligations on platforms, including: not operating beyond the scope of the permit; notifying the Ministry of changes to permit-related information within 15 days; providing information and documents requested by the Ministry within 15 days; displaying permit numbers when marketing accommodation establishments and rental residences; not charging fees where no service is rendered or where the type or amount of the fee is not specified in the intermediation agreement; not demoting, restricting, suspending or terminating a service provider in ranking or recommendation systems without objective criteria or on account of an application to public authorities or judicial bodies; and not restricting service providers from selling through alternative channels or advertising at different prices. In addition, the amount platforms may charge on the sale price of the service, however designated, may not exceed 17% of the price excluding VAT.

Administrative Sanctions

The Bill provides for graduated administrative sanctions for breaches of these obligations. Administrative fines ranging from TRY 200,000 to TRY 500,000 will apply to matters such as using unauthorised intermediaries, breaching notification obligations, and failing to use the hardware/software required by the Ministry; fines will increase by 50% upon a second breach within the same calendar year, and the permit will be revoked upon a third breach. For unlawfully collected fees, an administrative fine of ten times the amount collected is envisaged. Where a committed service is only partially rendered or not rendered at all, a fine of between TRY 50,000 and TRY 100,000 will apply per contract. Platforms operating without a permit, or whose permit has been revoked or has expired, will be subject to an access-blocking decision, to be submitted for approval to a criminal judgeship of peace within 24 hours, with the judge required to decide within 48 hours.

Tourism Share Obligation

The Bill also amends Law No. 7183 on the Türkiye Tourism Promotion and Development Agency to include foreign digital accommodation platforms among the parties liable for the tourism share. Platforms will pay a tourism share at a rate of 0.075% (7.5 per ten thousand), calculated on the tax base for digital service tax purposes.

Transitional Provision and Entry into Force

Platforms already operating in Türkiye through electronic commerce as of the effective date of the Bill will be required to apply to the Ministry for a permit within three months of that date. Platforms that fail to comply with this obligation, or whose applications are not accepted, will be subject to the access-blocking provisions. If enacted, the Bill will enter into force on the date of its publication.

The Bill envisages a significant compliance process for foreign digital accommodation platforms by bringing them under a formal registration, permit and supervision regime in Türkiye and including them within the scope of the tourism share obligation. We will continue to monitor the Bill’s progress through the TBMM and its final enacted text.