Turkiye: Decision on preparation of explicit consent and disclosure texts enters into force

On 24 March 2026, Decision No. 2026/347 of the Turkish Personal Data Protection Board on the separate preparation of explicit consent and disclosure texts enters into force upon its publication in the Official Gazette No. 33203. The Decision requires data controllers to fulfil disclosure obligations prior to any data processing activity, independently of whether processing is based on consent or another legal ground. Where processing is based on explicit consent, the Decision requires disclosure and consent texts to be prepared as separate documents under distinct headings, with separate declarations for each, even where both texts appear on the same page and must be placed one above the other. Where processing is based on legal grounds other than consent, the Decision prohibits presenting a consent text to data subjects alongside the disclosure text. Non-compliance constitutes a breach of data security obligations under Article 12 of Law No. 6698 and results in enforcement action under Article 18 of Law No. 6698.