Yes, and the requirement has two layers: number and the body of law that applies. Article 23/1: “The Supreme Council shall determine the minimum number of press-card-holding personnel to be employed in the news units of media service providers. Such personnel shall be subject to Law No. 5953 of 13 June 1952 on the Regulation of Relations between Employees and Employers in the Press Profession.”
First layer: the minimum number
The Law gives no figure; it delegates the power to RTUK. The answer to “how many people must I employ” is therefore not in the statute but in the RTUK determination in force. The number is expected to vary with the type of broadcasting, the coverage area (local, regional, national) and the medium.
Second layer: subject to Law No. 5953
This is the most concrete and most expensive consequence the article produces. Press-card-holding personnel employed in news units are subject not to the general Labour Law but to Law No. 5953. The differences between the two regimes bear directly on staff costs.
| Matter | Feature of the Law No. 5953 regime |
|---|---|
| Employment contract | It must be in writing and contain the elements the Law prescribes |
| Severance pay | The provisions of Law No. 5953 apply |
| Notice period | The periods in Law No. 5953 apply |
| Overtime | Law No. 5953 has its own remuneration regime |
| Late payment of wages | Law No. 5953 provides for default interest |
The press card dimension
Article 23 says “press-card-holding personnel”. The press card is issued by the Directorate of Communications under the Press Card Regulation; Law No. 6112 does not regulate how it is issued, only requiring that personnel holding one be employed in news units. Meeting the duty therefore involves two parallel processes: building the establishment and completing press card applications for it.
News unit versus other departments
The obligation is for personnel “to be employed in news units”. Production, technical, sales and administrative departments fall outside the provision. But the division is expected to be real rather than nominal: showing a member of staff working on news production in another department creates a problem on inspection.
The link with broadcasting principles
The purpose of Article 23 is not only employment but maintaining the professional standard of journalism. Article 8/1(ı) defines that standard on the content side: broadcasting services “shall take as their basis the principles of impartiality, factuality and accuracy …; news capable of investigation within the framework of press professional principles may not be published without investigation or without being sure of its accuracy”. The press card requirement secures the professional staff needed to apply that principle.
Sanctions
A breach of Article 23 falls under Article 32/2. That paragraph covers not only breaches of broadcasting principles but also providers that fail to meet “the principles, obligations or prohibitions laid down in the other articles of this Law and/or the obligations determined by the Supreme Council within the scope of this Law”. Because the minimum number is set by RTUK, falling below it engages that second limb directly.
The fine is one to three per cent of the gross commercial communication revenue for the month preceding detection, not less than TRY 1,000 for radio and TRY 10,000 for television and on-demand services. Under Article 32/8 a warning may be issued once for each breach falling under that paragraph.
Points to watch in establishment planning
- Verify RTUK’s minimum number for your broadcasting type and coverage area.
- Start press card applications alongside recruitment; a card does not follow automatically from employment.
- Draft contracts under Law No. 5953, not on a Labour Law template.
- Keep the news unit establishment identifiable on the payroll.
- On departures, check whether the number has fallen below the threshold.
The responsible editor’s conditions are in the responsible editor guide and the fine calculation in the calculation guide.