Turkiye: Personal Data Protection Board adopted Decision No. 2025/2393 on application of data protection authority (VERBIS) exemption criteria

On 25 December 2025, the Personal Data Protection Board adopted Decision No. 2025/2393 clarifying the application of Decision No. 2018/87 as amended by Decision No. 2025/1572. The Decision determined that, for data controllers keeping books on an accrual basis, both the annual number of employees and the annual financial balance total would be assessed cumulatively when determining exemption from VERBİS registration. For data controllers not keeping books on an accrual basis, only the annual number of employees would be taken into account due to the absence of annual financial balance total information. The clarification addressed differences in bookkeeping obligations under Tax Procedure Law No. 213.