The clear answer: yes, it does. The question is sometimes presented as contested; in fact Consumer Protection Law No. 6502 and the relevant regulations contain three separate and mutually reinforcing bases bringing the internet within scope. More than that, the internet is listed as a separate subparagraph in the penalty scale, and an access-blocking procedure specific to the internet alone has been established. This article covers those three bases, the structure of the Board, the complaints procedure, and where the relationship with the broadcasting regulator RTÜK stands in the legislation.

Three bases

  • Law No. 6502, Article 61(1) — the definition of advertising says “in any medium”; there is no limitation as to medium. Article 4(1)(ı) of the Regulation names the internet expressly in its definition of a medium.
  • Law No. 6502, Article 77(12)(e) — in the administrative fine scale, the internet is regulated as a separate subparagraph, together with satellite television.
  • The closing sentences of Law No. 6502, Article 77(12) — a special procedure applying only to the internet environment has been established, with a 24-hour notice period and an access-blocking mechanism.

Read together, these three leave no room for debate: the legislature has not left the internet outside the scope but has, on the contrary, built a sanctions regime specific to it.

Basis 1: “in any medium”

Law No. 6502, Article 61(1): “Commercial advertising means announcements in the nature of marketing communication made by advertisers in any medium in written, visual, aural and similar ways, in connection with a trade, business, craft or profession, for the purpose of securing the sale or rental of a good or service, or of informing or persuading the members of a target audience.”

Article 4(1)(ı) of the Regulation on Commercial Advertising and Unfair Commercial Practices leaves no room for doubt when defining a medium: “Medium: … communication channels such as television, print media of all kinds, the internet, telephone, radio and cinema, together with communication tools such as outdoor and printed material,”. Subparagraph (i) of the same article then defines a media outlet as “the natural or legal person who owns or operates, or leases out, any medium in which advertising is published and through which it reaches the target audience”. An online news site sits directly at the intersection of those two definitions.

The addressee of the obligation is determined by Article 61(7): “Advertisers, advertising agencies and media outlets are obliged to comply with the provisions of this Article.” The purpose article of the Regulation (Article 1) also names media outlets expressly.

Basis 2: a separate penalty subparagraph for the internet

Article 77(12) of Law No. 6502 splits the penalty into subparagraphs by medium. The internet is in subparagraph (e): “e) where it has been carried out through a television channel broadcasting by satellite or through the internet …” If the internet were outside the scope, that subparagraph would be unnecessary.

The placing of the subparagraph is also significant. Printed periodicals are dealt with in subparagraph (c), at half the fines in subparagraphs (a) and (b); the internet is placed in the same band as national radio, that is, markedly above the periodicals band. The same piece of surreptitious advertising is subject to a lower band in a printed newspaper and a higher one on a website. For the detail of the bands and defence strategy, see the article on penalties for surreptitious advertising.

Basis 3: the 24 hours and access blocking specific to the internet

The sentences of Article 77(12) as amended by Law No. 7511 of 23/5/2024 establish a procedure operating for the internet alone: “Where the infringement occurs in the internet environment, the Advertising Board may decide that notice be given, by means allowing electronic communication, on the basis of information obtained from sources such as the means of contact on the relevant internet page, the domain name, the IP address and similar, requesting removal of the content, and, if the content is not removed within twenty-four hours despite that notice, that access be blocked.”

  • An access-blocking decision may be given directly, but only where notice cannot be given to the addressee.
  • The decision is sent to the Access Providers Union for implementation.
  • The block is given “in principle limited to the content in which the infringement occurred”.
  • Where access to the content cannot technically be blocked, or where the infringement cannot be prevented that way, a decision may be given to block the whole of the website.

This mechanism does not depend on a court decision; it operates administratively. In practice the most critical point is that the email address given in the imprint is actually monitored — because the 24-hour period starts with the notice.

How a complaint is made to the Board

The procedure is set out in the Advertising Board Regulation. Article 8(1): “Applications to the Board are made in writing or by electronic means. Applications that do not contain the name, surname, Turkish identity number and address of an applicant who is a natural person, or the title and address of an applicant that is a legal person, shall not be taken into consideration by the Board.” In other words, no file is opened on an anonymous tip-off.

Article 8(2) provides that complaints about commercial advertising must include “determinative matters such as the medium, the date and the subject of the complaint in which the advertisement complained of was published”. The sentence added to Article 8(3) by the amendment of 28/7/2022 targets the internet directly: “For advertising carried out in the internet environment, samples of the advertisement containing the internet address extension complained of (in the form of a URL or similar) and the date information shall be annexed to the petition.”

The existence of that sentence is itself proof: the Regulation separately governs how a complaint about internet advertising is to be documented. The same list also shows what will be in the file when a complaint is made against you; there is therefore value in keeping your own archive to the same standards.

text
COMPLAINT TO THE ADVERTISING BOARD — WHAT ARTICLE 8 REQUIRES
(Advertising Board Regulation, Art. 8(1), 8(2), 8(3))

MANDATORY — without these the application is NOT CONSIDERED (Art. 8(1)):
  [ ] Natural person : name, surname, Turkish identity number, address
  [ ] Legal person   : title, address
  [ ] Form of application: in writing OR by electronic means

FOR A COMMERCIAL ADVERTISING COMPLAINT (Art. 8(2)):
  [ ] The MEDIUM in which the advertisement was published
  [ ] The DATE of publication
  [ ] The SUBJECT of the complaint

SAMPLE OF THE ADVERTISEMENT (Art. 8(3)):
  [ ] ORIGINALS of written/printed advertisements
  [ ] IMAGES of those not capable of being annexed
  [ ] For INTERNET advertising, samples containing:
        - the internet address extension complained of (URL or similar)
        - the date information

FOR AN UNFAIR COMMERCIAL PRACTICE COMPLAINT (Art. 8(2)):
  [ ] Information and documents relating to the complaint

NOTE FOR THE PUBLISHER:
  The same items are the contents of any file opened against you.
  Keep URL + date-stamped screenshots of your advertising content in
  your own archive too (Law 6502 Art. 63(8): the examination is
  conducted on the file).

The structure of the Board and how it works

Under Article 63(2) of Law No. 6502, the Board is chaired by the relevant Director General designated by the Minister, and consists of nineteen members including the chair. The memberships of note from a media standpoint are:

  • “one member to be designated by the Radio and Television Supreme Council,” (subpara. (e))
  • “one member to be designated by the Council of Higher Education from among academics specialising in advertising, communication or commercial law,” (subpara. (ğ))
  • “one member to be designated by the Union of Chambers and Commodity Exchanges of Türkiye from among the members of the Türkiye Media and Communication Assembly,” (subpara. (h))
  • “one member to be elected by the associations of advertisers or, where they exist, their umbrella organisations,” (subpara. (j)) and “one member to be elected by the associations of advertising practitioners or, where they exist, their umbrella organisations,” (subpara. (k))
  • In addition, representatives of the Ministries of Justice, Health, Culture and Tourism and Agriculture; the Turkish Standards Institution; metropolitan municipalities; the Confederation of Turkish Tradesmen and Craftsmen; the Consumer Council; the Pharmacists’, Dentists’ and Medical Associations; and the Union of Turkish Bar Associations.

Procedural provisions: members serve three-year terms (Article 63(3)); the Board meets at least once a month (Article 63(4)); it convenes with at least eleven members including the chair present and decides by an absolute majority of those attending (Article 63(5)). The most critical provision is Article 63(8): “The Board conducts its examination on the file containing the relevant documents.” There is no hearing; the defence is in writing. Under Article 63(10), Board decisions are announced by the Ministry for the purpose of informing consumers — that is, the decision is made public.

The sanctions it may impose

Article 63(1) lists the Board’s repertoire of sanctions. Access blocking was added to the list by Article 18 of Law No. 7511 of 23/5/2024:

  • Suspension
  • Correction by the same method — publishing a correction in the medium in which the infringement occurred
  • An administrative fine
  • Suspension as a precautionary measure for up to three months — this power may be delegated to the Chair of the Board
  • Removal of the content and/or blocking of access

The allocation of powers is in Article 78(1) of Law No. 6502: “The administrative sanction decisions provided for in the twelfth and thirteenth paragraphs of Article 77 are given by the Advertising Board, and those provided for in the other paragraphs by the Ministry.” Since advertising infringements fall under Article 77(12), the deciding authority is the Board itself. Board decisions may be challenged before the administrative courts; proceedings are brought within thirty days of the day following notification, and the bringing of proceedings does not suspend implementation of the decision (Article 78(2)).

The division of powers with RTÜK is not regulated in the legislation

This has to be said honestly: in the three documents examined — Law No. 6502, the Regulation on Commercial Advertising and Unfair Commercial Practices, and the Advertising Board Regulation — there is no reference at all to Broadcasting Law No. 6112; the expression “6112” does not appear once. A medium-based division of powers between the Advertising Board and RTÜK, an order of priority, or a “no two penalties for the same act” rule is not regulated in these texts.

The only concrete bridge that can be found is in Article 7(2) of the Advertising Board Regulation: in applying administrative fines, the type of licence granted by RTÜK determines which penalty band applies. In terms: “a) infringements in broadcasts carried out through organisations granted a national broadcasting licence or broadcasting permit by the Radio and Television Supreme Council shall be deemed to have been committed nationwide.” … “c) infringements in broadcasts carried out through organisations that, without holding a national broadcasting licence from the Radio and Television Supreme Council, have been granted a satellite TV, cable TV (other than a single-province broadcasting licence), internet TV or on-demand service broadcasting licence or permit shall be deemed to have been committed via the satellite environment.”

Subparagraph (ç) of the same paragraph sets a criterion for print publications: “Periodicals whose distribution provinces have a combined population amounting to at least seventy per cent of the national population shall be deemed to be distributed nationwide.”

The practical result: RTÜK is not the deciding authority in advertising supervision; but the type of licence your publishing organisation holds from RTÜK directly affects which band the Advertising Board will apply. A news site that has obtained an internet TV or on-demand media service licence for video output is treated as “the satellite environment” under subparagraph (c). For obligations on the RTÜK side, see the RTÜK broadcasting principles checklist.

The general rule applying where the regimes overlap is in Article 77(20) of Law No. 6502: “The application of an administrative sanction under this Law does not prevent proceedings to be taken under other laws.” An Advertising Board fine therefore does not extinguish liability arising for the same content under the Press Law, before RTÜK, or through general legal remedies.

The practical upshot for a news site

  • Even without an RTÜK licence, you are under the supervision of the Advertising Board; the basis is the medium-neutral definition in Article 61(1).
  • Liability cannot be transferred by contract: Article 61(7) places the obligation on the media outlet expressly and directly.
  • The examination is conducted on the file (Article 63(8)); a URL and date-stamped screenshot from the moment of publication is your strongest evidence.
  • The decision is made public (Article 63(10)); the reputational risk may be greater than the fine itself.
  • The 24-hour notice period runs from the contact channel in your imprint; monitor that inbox.
  • An Advertising Board fine does not remove liability arising under other laws (Article 77(20)).

If you want to build the compliance side as a whole, start with the legal compliance checklist for online news sites; then move to the advertorial labelling guide for labelling practice, and to the article on influencer partnerships for brand collaborations.