Age Verification and Child-Specific Service Requirements Introduced for Social Network Providers
Selin Çetin Kumkumoğlu
Of Counsel
Yaren Alparslan
Associate
Buse Sığın
Trainee
The Regulation on the Provision of Separate Services Specifically Tailored to Children by Social Network Providers and Age Verification (the “Regulation”), published in the Official Gazette dated 10 October 2026 and numbered 33396, sets out the obligations of domestic and foreign social network providers accessible from Türkiye regarding age verification, the provision of separate services specifically tailored to children, and parental control tools. Under the Regulation, persons under the age of 18 are considered children, even if they have attained legal majority at an earlier age. While the provision of services to children under the age of 15 is prohibited, specific service requirements are introduced for children aged 15 and over.
Age Verification and Prohibition on Providing Services to Children Under 15
The Regulation prohibits social network providers from providing services to children under the age of 15 and requires age verification at the account creation stage. For this purpose, age verification is to be carried out through an age verification token generated via the e-Government Gateway, which indicates only whether the user has reached the age of 15 and, where applicable, the age of 18, without containing any other information.
The Regulation also provides for social network providers to apply their own age verification methods throughout the provision of their services. Where there are reasonable grounds to suspect that an account is being used inconsistently with the verified age group, the account may be suspended and verification through an age verification token may be required before the account can be used again. The principles of personal data protection, technical reliability, transparency, accessibility and non-discrimination are to be observed throughout age verification processes.
Separate Services Specifically Tailored to Children
The Regulation requires social network providers to tailor services offered to children aged 15 and over in a manner that safeguards the child’s best interests and physical, mental, psychological, social and emotional development. Accordingly, high-level privacy settings are to be applied by default, personal data processing is to be limited to what is necessary, and content filtering and recommendation system settings are to be implemented to reduce children’s exposure to harmful content.
Children’s accounts are to be private by default, with no option to create public accounts. Information regarding followers and followed accounts is to be concealed from other users, messaging is to be limited to accounts followed by the child, and read receipts are not to be displayed. The Regulation also provides for live-streaming to be unavailable on children’s accounts and for technical measures to be implemented to prevent screenshots of profiles, accounts, posts and images.
In addition, the Regulation introduces restrictions on features that may encourage addictive behaviour, interfaces that automatically or consecutively display content, and the synchronisation of third parties’ contact information. Measures are also envisaged to prevent children’s accounts from being recommended to other users or made searchable through third-party contact information. Behaviour-based personalisation and the use of children’s personal data for profiling or personalised commercial advertising are likewise restricted.
Parental Control Tools
The Regulation requires social network providers to offer parental control tools enabling parents to manage account and feature settings, subject purchases, rentals and paid memberships to parental permission or approval, set spending limits, monitor and restrict usage time, and manage location sharing.
These tools are expected to be available in Turkish, easily accessible and activatable, and compatible with different devices and operating systems. Children are also to be clearly informed when parental control tools are activated. Appropriate safeguards are to be implemented to prevent children from disabling parental control without the necessary security verification and without the parent’s knowledge. The provision of parental control tools does not relieve social network providers of their separate obligation to offer services specifically tailored to children.
Application and Appeal Mechanism
The Regulation requires a free and accessible application and appeal mechanism, available in Turkish, for reviewing matters concerning age verification results, account suspensions or closures, and measures applied under services specifically tailored to children. Applications and appeals may not be reviewed solely through automated systems and are subject to meaningful human review.
Social network providers are also required to report annually to the Cybersecurity Presidency on the number of applications and appeals, acceptance rates and average resolution times, and to publish the same information on their websites. Notifications communicating the outcome of an application or appeal must also inform users of their right to lodge a complaint with the Cybersecurity Presidency and to seek judicial recourse.
Conclusion
The Regulation will enter into force on 1 November 2026. Existing accounts created before that date which have not been verified through an age verification token must be verified at least once by 31 March 2027. Accounts identified as belonging to children under the age of 15 are to be closed, while accounts belonging to children aged 15 and over are to be brought into compliance with the requirements applicable to services specifically tailored to children.
Non-compliance with the Regulation may result in sanctions under Article Additional 4 of Law No. 5651. Social network providers should therefore review their existing practices in light of the Regulation and plan and complete the necessary compliance measures within the applicable timeframes.
