The short answer is yes, it is mandatory. Article 22 of Law No. 6112 is imperative — media service providers “shall appoint” a viewer representative. The article contains no exemption, no exception and no size threshold: a national television channel and a small local radio station are under the same duty.
What the article says
Article 22/1: “Media service providers shall appoint a viewer representative with at least ten years’ professional experience for the purposes of establishing joint supervision and self-regulatory mechanisms, evaluating complaints received from viewers and listeners and submitting them to the broadcasting board of the undertaking, and following up their outcomes. The viewer representative so designated shall be announced to the public by appropriate means and notified to the Supreme Council.”
The four elements
| Element | What the Law requires | Practical meaning |
|---|---|---|
| Qualification | At least ten years’ professional experience | A recent graduate or junior member of staff cannot be appointed |
| Number | One viewer representative | One person suffices; no board is required |
| Publicity | Announced to the public by appropriate means | Viewers must be able to find out whom to approach |
| Notification | Notified to RTUK | Appointments and changes must be reported |
The role: carrying complaints to the broadcasting board
The article gives the representative three functions, each following from the last:
- Establishing joint supervision and self-regulatory mechanisms. The representative is not a complaints inbox but the architect of the internal review system.
- Evaluating complaints and submitting them to the broadcasting board. The Law names the addressee: complaints go to the broadcasting board, not to a public relations desk.
- Following up outcomes. The duty does not end with passing the complaint on; whether the decision taken is implemented must be monitored.
Consequences of breach
Article 22 is not among the grave sub-paragraphs listed in Article 32/1, so a breach falls under Article 32/2, which covers 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”. The fine is one to three per cent of the gross commercial communication revenue for the month preceding detection, subject to the floor of TRY 1,000 for radio and TRY 10,000 for television and on-demand services.
How to announce the appointment
The Law says “by appropriate means” and does not prescribe a method. What is expected in practice is that the name and a route to contact are somewhere the viewer can easily reach.
- A separate page on the undertaking’s website, reachable from the home page
- The representative’s name and a direct contact channel (e-mail or form)
- A short explanation of how to complain
- Periodic on-air announcement
Can the representative also be the responsible editor?
The Law does not expressly forbid it, but the logic of the two roles is opposed. The responsible editor under Article 46/1 bears liability arising from the broadcast; the viewer representative evaluates complaints about that broadcast and submits them to the board. Combined in one person, the self-regulatory function loses its meaning. The purpose in Article 22 — “establishing self-regulatory mechanisms” — calls for a functional separation.
The broadcasting equivalent of a press ombudsman
Viewer representation is the radio and television counterpart of what the print sector calls a readers’ editor or ombudsman. Law No. 6112 turns it from a choice into a duty, and there is a practical benefit for the undertaking: a complaint resolved internally closes without becoming a right of reply request under Article 18 or an RTUK supervision file.
The complaint routes are set out in the complaints guide and the responsible editor’s conditions in the responsible editor guide.