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Changes to the Requirements for Registration to VERBIS

Turkish Personal Data Protection Board’s (“Board”) decision dated 06 July 2023 and numbered 2023/1154, that was published on the Official Gazette today, reevaluated “annual financial balance sheet total” amount, which was accepted as a criterion to be exempt from the obligation to register with the Data Controllers Registry (“VERBIS”), due to economic conditions in the country.

With this decision, the exemption limit is amended to 100.000.000 Turkish Liras for the annual financial balance sheet, which was previously determined as 25.000.000 Turkish Liras with the Board's decision dated 19 July 2018 and numbered 2018/87.

In this context, as of today, “natural person or legal entity data controllers -whose main field of activity is not processing special personal data- with less than 50 employees annually and annual financial balance sheet total less than TRY 100.000.000” are exempted from the obligation to register to VERBIS. Data controllers should consider the declarations to be submitted as of the effective date (25 July 2023) when evaluating whether they are subject to this exception.

This exception has been determined only for local data controllers and does not apply to foreign data controllers.

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