The Law does not devote a heading to this question; the answer follows from the definition in Article 1: those working for a wage in the intellectual and artistic work within the scope of this Law are called journalists.
The Decisive Phrase: "Working for a Wage"
The definition presupposes an employment relationship, and that assumption runs through the whole Law:
| Article | What it presupposes |
|---|---|
| Art. 4 | A written contract stating the nature of the work, the wage and seniority |
| Arts. 5–7 | Termination and notice periods — a continuing relationship |
| Art. 14 | Payment of the wage monthly in advance |
| Art. 21 | Annual leave — work for an employer |
But the Method of Payment Is Not Decisive on Its Own
The Law shows this expressly in one place. Additional Article 1 provides that where a journalist whose pay is set per piece or by volume of work is required to work overtime, payment is again made on the basis of that article.
So payment by fee or by the piece does not take a person outside the Law. The Law recognises this method of payment and brings it within scope.
Work Outside the Contract Is a Separate Institution
Article 15 provides that a staff journalist receives separate pay for work outside their contract and for pieces commissioned or accepted for publication, and requires the social security premiums of those additional payments to be paid.
That article governs the extra work of a member of staff — not a relationship formed with someone outside the staff. It is covered in the extra pay article.
Outside Work Is Free
Under Article 13, unless the contract says otherwise the journalist is free to take other work outside, whether or not it is press-related. A staff journalist may therefore produce freelance work for other outlets unless restricted by contract.
The Press Card Side Recognises Freelance Work
The Press Card Regulation recognises freelance work through a separate card type. Under Article 13, the free press card is issued to Turkish citizen media members who are temporarily not working, or who work as freelance journalists abroad.
| Situation | Card |
|---|---|
| Employed by an organisation | Duty-based press card |
| Temporarily not working | Free press card — 12/18/24 months |
| Turkish citizen freelancing abroad | Free press card — with confirmation from the embassy or consulate |
The Nature of the Actual Relationship Governs
For the Official Announcement Staff
At publications carrying official announcements, the contracts of intellectual workers shown on the minimum staff must be made in writing and full-time in compliance with Law 5953 (Official Announcement and Advertisement Regulation, Art. 18). A freelance worker therefore cannot be shown on the minimum staff.
Bottom Line
The Law's test is working for a wage, and its provisions presuppose a continuing employment relationship. Payment by fee or by the piece does not by itself remove a person from scope — Additional Article 1 expressly recognises that method of payment. A wholly independent worker falls outside the definition; on the press card side, the free press card is regulated separately.