Update on Exception Criteria for Registration Obligation to the Personal Data Controllers Registry

Pursuant to the decision of the Personal Data Protection Board dated 06.07.2023 and numbered 2023/1154 published in the Official Gazette dated 25.07.2023 and numbered 32259,  the exemption to the obligation to register with the Data Controllers Registry Information System ("VERBIS") has been updated ("Update”).

Accordingly, the total amount of the annual financial balance sheet has been updated by way of changing the exemption criterion of  "real or legal person data controllers (i) whose annual number of employees is less than 50 and (ii) whose total amount of annual financial balance sheet is less than 25 million Turkish Liras and (iii) whose main activity is not processing special categories of personal data" to "real or legal person data controllers (i) whose annual number of employees is less than 50 and (ii) whose total amount of annual financial balance sheet total is less than 100 million Turkish Liras and (iii) whose main activity is not processing special categories of personal data".

Update has been entered into force on 25.07.2023 and the data controllers, who are subject to the exemption based on their total amount of annual financial balance sheet  after the date of Update’s entry into force, will not be required to register with VERBIS, even if they had not been subject to the exemption before the Update’s entry into force.

Aslı Tezcan LL.M., Partner
Gamze Güngör Bulut, Associate
Sıla Eyvaz, Legal Intern