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The Regulation on Embedded Insurance, published in the Official Gazette on 12 November 2026 and entering into force on the same date, establishes a framework for insurance offered as an integrated part of the sale of goods or services. It is directly relevant not only to insurance providers but also to e-commerce platforms, retailers and service providers. The new Regulation restricts the products that may be offered while emphasising the optional nature of insurance, the separate identification of premiums, straightforward termination and secure technical infrastructure.
Who is affected?
The Regulation applies to insurance and reinsurance companies, pension companies providing insurance cover, insurance intermediaries, banks, institutions authorised under special legislation to act as insurance agents, and individuals and entities providing a trading environment for embedded insurance.
Embedded insurance refers to cover offered in the physical or electronic environment in which goods are sold or hired, or services are sold, limited to risks directly connected with those goods, services or their financing. Accordingly, not every insurance product added to a sales process automatically falls within this scope.
Which products may be offered?
The Regulation covers risks such as breakage, loss, theft, fire or malfunction of goods. It also covers risks relating to services such as travel, transport, accommodation, events, subscriptions, bill payments, cybersecurity and shared or short-term vehicle hire, including the inability to use a service for reasons not attributable to the service provider, cancellation, interruption or unauthorised use. Other risks connected with travel services are also specifically addressed.
Insurance required for residence permit and visa applications may also be offered, subject to the specified conditions, as may life, debt repayment and personal accident insurance linked to personal loans provided by banks through e-commerce platforms not owned by those banks.
By contrast, compulsory insurance, home and business premises insurance, construction and erection insurance, savings and investment-linked insurance, agricultural insurance, financial loss insurance, cargo insurance and legal expenses insurance are excluded. For vehicle, health and sickness, personal accident, life, liability and credit insurance, the specific exceptions in the Regulation require separate consideration. Surety insurance is also listed among the products that may not be offered.
Limits on premiums, duration and timing of offers
- Premium cap: The annual gross premium must not exceed the monthly gross minimum wage applicable during the first six months of the relevant calendar year, determined by reference to the cover commencement date. The Board may reduce this cap by up to half or increase it to up to twice its amount for particular goods or services.
- Cover period: The maximum period is two years. For products providing extended warranty cover, this period may be extended in line with the warranty period.
- Timing of offers: Insurance may be offered at the time of sale or hire, or within fourteen days of the conclusion of the relevant contract.
Consumer freedom of choice at the point of sale
The purchase of insurance may not be made a condition of purchasing or hiring goods or services. Purchasers who decline insurance may not be subjected to less favourable prices or other sales terms.
Nor may the impression be created that cover is provided by anyone other than the insurance company or pension company providing insurance cover. Information must be disclosed through readily visible displays in physical premises or through a link in an e-commerce environment. This must include details of the cover provider and any intermediary, the premium, the subject matter and scope of the insurance, the entity responsible for paying claims, and how to access further information.
Information, consent and policy delivery
The obligations under the Regulation on the Provision of Information in Insurance Contracts and the obligation to provide an insurance policy under the Turkish Commercial Code remain applicable. Policies may be provided on a durable medium, subject to the statutory requirements.
Before the contract is concluded, the insurance company or pension company providing insurance cover must inform the policyholder about the trading environment in which the transaction takes place. Consent must be obtained through a secure method that enables identity verification and the ascertainment or recording of the policyholder’s declaration. Information, consent and policy delivery processes should therefore be designed to allow subsequent verification.
Straightforward termination and linkage to the underlying contract
A termination request submitted through any means of remote communication to the trading environment provider or an authorised entity will be sufficient. Trading environment providers must establish systems enabling requests to be submitted through the same method used to conclude the insurance contract. Policyholders may not be required to use a termination method that imposes more onerous conditions than the method used to conclude that contract.
Where a right of withdrawal, termination, cancellation or rescission is exercised under the underlying contract for goods or services, the related insurance contract will terminate automatically, without any obligation to pay compensation or a contractual penalty. Integrating return and cancellation processes with insurance systems is therefore critical. The provision does not prescribe a detailed method for calculating premium refunds.
Collection, service fees and system security
Where the premium is collected together with the price of the goods or services, the premium must be shown separately on the payment document. Where it is collected separately, a premium receipt must be provided in printed form or on a durable medium. In all cases, payments made as insurance premiums will be deemed to have been made to the insurance company or pension company providing insurance cover.
Service fees payable by authorised entities to trading environment providers may not be treated as insurance intermediation commissions. This provision calls for service and remuneration models to be assessed alongside the roles actually performed by the parties.
Authorised entities will be responsible for ensuring collection processes comply with payment legislation and that the necessary security measures are in place. They will also be responsible for the security of the information systems and integrations used, the maintenance of transaction records and compliance with applicable legislation.
Pre-launch notification and recommended preparations
Authorised entities must notify the Insurance and Private Pension Regulation and Supervision Authority one month before launching the arrangement. The Authority may require changes to the arrangement, without prejudice to its power to impose administrative sanctions. The provision establishes a prior notification obligation; it does not prescribe a separate authorisation or approval procedure.
The following measures are particularly important:
- Reviewing product and cover inventories against the permitted and prohibited insurance categories;
- Incorporating premium caps, cover duration limits and the fourteen-day offering window into sales systems;
- Reviewing the option to purchase without insurance, information disclosures, secure consent and policy delivery processes;
- Integrating termination channels with the return and cancellation workflows for the underlying contract;
- Clarifying responsibilities for service fees, collection, record-keeping and security in platform agreements; and
- Allowing for the one-month advance notification requirement in the launch timetable.
