Türkiye's evolving digital legal framework: regulatory developments in innovation and data protection

One of the earliest and most consequential legislative developments in this context is the Regulation on the Identification and Certification of Technology and Innovation-Oriented Startups, promulgated by the Ministry of Industry and Technology. Enacted pursuant to Presidential Decree No. 1 on the Presidential Organisation, the Regulation establishes a structured legal framework for the formal recognition and certification of startups contributing to Türkiye's innovation ecosystem.

One of the Regulation's key features is the Techno-Startup Badge, a formal designation granted to small and medium-sized enterprises that are not older than 15 years and operate on scalable, technology- and innovation-driven business models. Eligibility for the Badge is contingent upon active participation in designated innovation and entrepreneurship support mechanisms, including:

• Technology Development Zones, regulated under Law No. 4691;
• Technology Development Centres, supported by KOSGEB;
• Entrepreneurship support programmes administered by TÜBİTAK (the Scientific and Technological Research Council of Türkiye), such as BİGG (Individual Young Entrepreneur) and BiGG Yatırım, which provide funding and resources to early-stage technology startups.

The Regulation defines who qualifies, how applications are reviewed, how long certifications last and how they can be renewed or revoked. In doing so, it offers legal certainty and institutional support to a critical segment of the digital economy, while promoting targeted state incentives and enhancing accountability.

In addition to its regulatory function, the Techno-Startup Badge is expected to gain increasing strategic value for eligible enterprises. The Badge can help startups access public funding, gain investor trust and stand out in public tenders. As such, the Regulation contributes not only to legal certainty but also to the broader objective of integrating promising startups into the national innovation strategy.

In parallel with efforts to foster innovation, Türkiye has also taken important steps to address the ethical and legal implications of emerging technologies, particularly in the field of artificial intelligence. On 11 July 2025, the Personal Data Protection Authority published a policy document titled "Recommendations on the Protection of Personal Data in the Field of Artificial Intelligence", outlining the Authority's key expectations concerning the responsible design, development and deployment of AI systems in accordance with data protection principles.

The Authority highlights the importance of building privacy into AI systems, keeping humans in the loop and taking a cautious approach to prevent harm. The recommendations specifically address potential harms associated with algorithmic bias, overreliance on automated decision-making, and the lack of contextual nuance in AI applications.

In this context, AI developers and data controllers are called upon to implement safeguards that promote:

• data minimisation and proportionality;
• transparency and interpretability of automated decisions;
• accountability across all stages of the AI life cycle;
• informed user choice, including meaningful consent and robust mechanisms for redress in the event of adverse automated outcomes.

Importantly, these recommendations serve as a normative counterweight to Türkiye's innovation agenda, emphasising that technological progress must not come at the expense of individual rights or public trust.

Taken together, these regulatory initiatives reflect a maturing digital governance strategy. As Türkiye continues to position itself as a regional leader in digital innovation, effectively balancing economic competitiveness with ethical and legal oversight will be essential to building a sustainable, inclusive and rights-respecting digital ecosystem.

authors: Didem Kara, Damla Aydogan