The short answer is that Law No. 6112 sets no fixed monetary ceiling. The ceiling is a rate: five per cent of gross commercial communication revenue. As revenue grows, so does the fine. What the Law does fix is the floor: TRY 1,000 for radio and TRY 10,000 for television and on-demand media service providers.
The monetary ceiling: five per cent
For the grave breaches in Article 32/1 the band runs from two to five per cent. For other breaches under Article 32/2 it runs from one to three per cent. The highest fine available for a single breach is therefore five per cent of the gross commercial communication revenue for the month preceding detection.
| Previous month’s gross commercial communication revenue | Art. 32/1 ceiling (5%) | Art. 32/2 ceiling (3%) |
|---|---|---|
| TRY 500,000 | TRY 25,000 | TRY 15,000 |
| TRY 5,000,000 | TRY 250,000 | TRY 150,000 |
| TRY 50,000,000 | TRY 2,500,000 | TRY 1,500,000 |
The real ceiling is not money
What actually threatens a broadcaster is the repeat-breach ladder in Article 32/5. It runs on two tracks and both end in licence revocation.
Grave breaches track. Where broadcasting contravenes Article 8/1 sub-paragraphs (a), (b) or (d), or Article 8/4, a repetition of the same breach within one year of notification of the sanction decision leads to suspension of broadcasting for up to ten days; on a second repetition the licence is revoked. Two repetitions are enough to end the licence.
Other breaches track. Where the other sub-paragraphs of Article 8/1, Article 8/2 or any provision governing commercial communication are breached more than twenty times within one year of notification, broadcasting is suspended for up to five days; a repetition of the same breach within one year brings suspension of five to ten days; a second repetition brings licence revocation.
| Step | Grave track (a, b, d and Art. 8/4) | Other track |
|---|---|---|
| First decision | Fine + programme suspension | Fine |
| Repetition within 1 year | Broadcasting suspended up to 10 days | 20+ breaches → suspension up to 5 days |
| Next repetition | Licence revocation | Suspension of 5–10 days |
| Second repetition | — | Licence revocation |
Ignoring a decision is itself a revocation ground
The last sentence of Article 32/5 is categorical: an undertaking whose programmes or broadcasts have been suspended and which continues broadcasting contrary to the requirements of the decision, despite notification, has its licence revoked. No ladder applies; a single act leads straight to revocation.
The warning: a rung below the fine
Not every breach has to end in a fine. The sentence added to Article 32/8 gives RTUK power to issue a warning instead of a fine — once for each breach falling under Article 32/2 — weighing the gravity of the breach, the presence of unjust economic gain and of repetition, and the sanctions applied in the last five years. The power was added in 2017 by Decree Law 690 and enacted in 2018 by Law 7077.
Judicial sanctions sit on a different scale
Administrative ceilings should not be confused with criminal ones. Under Article 33/1, natural persons and, for legal persons, board members and the general manager who broadcast without a licence — or despite suspension or revocation — face one to two years’ imprisonment and a judicial fine of one thousand to five thousand days. Failing to keep or deliver broadcast recordings exposes the responsible editor to one thousand to five thousand days (Art. 33/3), rising to five thousand to ten thousand days where recordings are altered, cut or deleted (Art. 33/4).
How the fine itself is worked out is in the calculation guide; the grounds for losing a licence are in the revocation guide.