Turkey amended its commercial advertising regulation to require disclosure of AI use in ads and to prohibit AI digital copies of real people endorsing products

The AI disclosure duty

Article 6 of the amendment adds a new paragraph 8 to article 18 of the 2015 regulation. On the Ministry's drafting, where AI or other software is used in advertising in a way that materially affects consumers' economic behaviour toward a good or service, or where digital characters indistinguishable from a human and created using AI technologies are featured, that fact must be stated clearly, understandably and distinguishably.

Read the trigger carefully. It is not every use of AI in production. It is use that materially affects economic behaviour, plus a separate limb for human-indistinguishable digital characters that has no materiality qualifier attached to it in the text.

The standard borrowed for the disclosure itself, clear, understandable and distinguishable, is the same phrase the amendment uses for influencer advertising in the new article 23/A. That is convenient, because the detailed formatting rules written for influencer labels give you a concrete picture of what the Ministry means by distinguishable.

The digital replica prohibition

Article 11 adds a new paragraph 12 to article 27, the article listing advertising that cannot be done at all. It provides that advertisements cannot be made in which a digital copy of a real person, created using AI technologies, gives the impression, contrary to the truth, that the person personally experienced or used a good or service, or made a recommendation about it.

This is drafted as a prohibition, and it sits alongside the other flat bans added by the same article, including new paragraph 11 barring advertising of medicinal products, electronic cigarettes, tobacco products and alcoholic drinks.

Two elements limit it. It applies to a digital copy of a real person, not to an invented character, and the impression given has to be contrary to the truth. A synthetic presenter who never claims personal use is a different question, and one the disclosure duty in article 18 rather than the ban in article 27 would reach.

Targeted advertising and children

Article 9 inserts a new article 25/A defining targeted advertising as the presentation of ad content to specific persons or groups by analysing consumers' online behaviour, past records of preferences, location data, demographic data or similar personal data, carried out by sellers and providers or by the intermediary service providers acting for them in distance contracts.

Targeted advertising may be carried out on condition that consumers are given direct and easily accessible information on the criteria used to show them the ad and on how those criteria can be changed.

Paragraph 3 is the harder one. Where the consumer is known, or reasonably expected to be known, to be a child, targeted advertising using profiling methods based on personal data cannot be done. The trigger is constructive knowledge, so a platform that has good reason to believe a segment skews to minors cannot rely on not having asked.

The rest of the amendment, which is not about AI

The same instrument does a lot of unrelated work, and anyone advertising into Turkey should read it whole rather than only for the AI provisions.

New article 23/A codifies influencer disclosure: content must be marked where the influencer links to the advertiser's goods, services or the advertiser itself, receives money or free or discounted goods, shares giveaway or contest content, or posts in return for a benefit from attending the advertiser's event. Either Reklam or Tanitim must appear, together with the advertiser's name or one of the listed acknowledgement formulas. The label must be readable against the background, visible without scrolling, placed before other tags, not overlapping text or icons, and repeated in every post where content spans several posts. Audio-only posts get their own opening formula.

Article 12 rewrites article 28/B on consumer reviews: reviews may only be made by people who bought the good or service, reviews from channels where purchase verification is impossible cannot be published, published reviews must stay up at least a year ordered by an objective criterion, and no agreement may be made or service bought to procure untrue reviews. Article 13 shortens a response window in article 28/C from at least seventy-two hours to forty-eight, and adds that if no reply comes within the period the review is published directly.

Article 4 changes the reference price for discount claims to the lowest price applied in the ten days before the discount began, with a different rule for perishables and services. Article 5 tightens environmental claims, requiring certificates and approvals to be substantiated by documents from competent bodies, relevant university departments, or accredited or independent research, test and evaluation organisations. Article 10 repeals article 26, and article 14 repeals item 13 of the deceptive practices annex.

What to do before 1 August

The compliance question is not whether you use AI. It is whether any live creative falls into the two AI categories, and that is an inventory exercise.

Pull every asset running to Turkish consumers and sort it. Assets where AI materially shapes the consumer's economic decision, or which feature a human-indistinguishable synthetic character, need a label meeting the clear, understandable and distinguishable standard. Assets featuring an AI likeness of a real person that implies personal use or a recommendation need to come down, because a label does not fix an article 27 prohibition.

Influencer contracts are the other exposure. The formatting rules in article 23/A are specific enough that a generic contractual duty to disclose will not produce compliant posts on its own.

What we did not verify

We opened the full Turkish text of the amending regulation as published in Resmi Gazete of 1 July 2026, No. 33297, and every fact and the quotation here comes from that text.

We did not open the consolidated 2015 regulation it amends, so we describe only the changes as drafted, not how each amended article now reads end to end. We did not find or open an official English translation, and the translations here are ours. We did not review any Ministry guidance, Advertisement Board decision, or enforcement practice under these provisions.

We do not claim any penalty amount, because the amendment does not set one out, and we do not claim how the Advertisement Board will read materially affects consumers' economic behaviour in a contested case.

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