Türkiye is preparing to extend its internet regulation regime to the online gaming sector.

A draft law currently before the Turkish Grand National Assembly would bring game developers and gaming platforms within the scope of Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed by Means of Such Publications (“Law No. 5651”), potentially introducing new compliance obligations for companies operating in or targeting the Turkish market.

While the proposed amendments primarily aim to strengthen child protection in digital environments, they may also introduce new regulatory oversight and operational requirements for the online gaming ecosystem.

Below is an overview of the key aspects of the proposed framework.

➢ Online gaming platforms brought within the scope of Law No. 5651

One of the most notable aspects of the draft law is the introduction of legal definitions for key actors in the online gaming ecosystem.

The proposal defines:

• Game - digital games distributed, played or updated via the internet
• Game provider - individuals or companies that develop games or in-game components
• Game distributor - entities that enable the distribution or playing of online games

As a result, online gaming platforms may soon become subject to direct regulatory oversight and new compliance obligations under Law No. 5651.

Ø  Age classification system for online games

The draft law introduces a mandatory age classification requirement for online games.

Under this system, games would be categorized according to their suitability for different age groups. The classification process may consider factors such as:

• violent content
• gambling-like mechanisms within games
• addictive game design features• user interaction dynamics

Ø  Parental control obligations for gaming platforms

Similar to the requirements proposed for social media platforms, the draft law would also require online gaming services to introduce parental control mechanisms.

These tools are expected to allow parents or guardians to:

• manage children’s gaming accounts
• monitor and restrict in-game purchases
• control the amount of time spent playing games.

Ø  Information disclosure obligations to the regulator

The proposal also introduces information disclosure obligations for game providers and distributors.

Upon request, companies may be required to provide the Information and Communication Technologies Authority (BTK) with information regarding:

• their corporate structure
• technological infrastructure
• data processing practices
• algorithmic systems used within their services.

Ø  Local representative requirement for certain platforms

The draft law also introduces a local representative requirement for foreign-based game distributors with more than 100,000 daily accesses from Türkiye.

Such platforms may be required to appoint a local representative responsible for communicating with Turkish authorities and ensuring compliance with regulatory obligations.

Ø  Risk assessment obligations for certain game distributors

The draft law also introduces a risk assessment obligation for game distributors exceeding 100,000 daily accesses in Türkiye.

Under the proposed provision, such distributors will be required to assess whether their services offered in Türkiye may pose risks, particularly in relation to:

• fundamental rights protected under the Constitution
• the protection of children and the family
• public order and public health
• the dissemination of unlawful content.

BTK may review the submitted assessments and request explanations from the relevant game distributor regarding the identified risks and the measures taken to mitigate them. If the authority concludes that the risks have not been sufficiently addressed, it may require the implementation of additional measures or changes to the way the service is provided.

Ø  Potential sanctions for non-compliance

Failure to comply with the proposed obligations may lead to several administrative sanctions, including:

• administrative fines
• bandwidth throttling measures
• restrictions on platform operations.

Ø  Key takeaways for gaming companies

If enacted, the proposed amendments would bring the online gaming sector within Türkiye’s internet regulation framework under Law No. 5651.

Gaming companies operating in or targeting the Turkish market should therefore begin assessing potential compliance implications, particularly in relation to:

• age classification systems for online games
• parental control features
• potential regulatory information requests
• possible local representation requirements.

Companies active in the gaming ecosystem should also closely monitor the legislative process, as the proposal may introduce new operational and compliance considerations for online gaming services in Türkiye.