Turkey Now Requires AI Disclosure in Advertising

What Happened

The amendment targets four areas simultaneously.

AI characters must be labelled

Digital characters indistinguishable from humans must now carry an indication that they were produced with artificial intelligence. The stated rationale is that synthetic content manipulates consumer decision-making.

Digital replicas cannot appear to test products

Presenting a digital copy of a real person as though they had personally tried a product is prohibited outright. Synthetic footage of well-known figures being used to market goods was the field evidence behind this provision.

Undisclosed promotion becomes a general rule

Every form of benefit relationship — gifted product, invitation, discount — must be identified with an advertising or promotion notice. What was previously handled case by case has become a general obligation.

Dark patterns are under enforcement

Flows that make cancellation difficult, designs that steer consumers toward unintended transactions and false urgency devices such as last-item-in-stock notices fall within the Board’s focus.

Who Is Covered?

The most misunderstood aspect is scope. This is not confined to the influencer economy.

Any site that sells

The dark-pattern provision speaks directly to e-commerce interfaces: countdown timers, stock warnings, pre-ticked add-on services and obstructed cancellation flows. Most of these arrive by default with themes and plugins, and many businesses do not know they are running.

Any brand using AI in creative work

A brand generating imagery with AI carries a labelling obligation once it produces characters indistinguishable from people. The use itself is not prohibited; concealing it is.

Both sides of a collaboration

Liability does not rest solely with the person publishing the content. The brand providing the benefit is party to the process, and working through an agency does not transfer responsibility.

Anything targeting children

Profiling children through their gaming and internet habits in order to serve them tailored advertising has been blocked. Any brand whose audience includes children should assess this provision separately.

Who This Affects, and How

The same regulation creates cost for some businesses and advantage for others.

Those who gain

Brands already operating transparently. For companies that label collaborations, show real stock and keep cancellation simple, nothing changes — what changes is that competitors can no longer use those devices. A rule always favours whoever was already following it.

Those who lose

Sites whose conversion rests on manufactured urgency. When timers and stock warnings come down, conversion will fall — and that fall is the true performance figure. Brands running unlabelled collaborations also carry penalty exposure.

Those largely unaffected

Businesses selling only to corporate buyers, with no consumer advertising, sit outside direct scope. Where a distributor sells to consumers, however, the distributor’s practice reflects on the brand.

The indirect chain

False urgency is removed, conversion drops, advertising cost per sale rises, pressure moves to price. The only way to stay out of that chain is to have built conversion on genuine reasons in the first place.

What to Do About It

All four items can be completed within a week and each directly reduces exposure.

Audit the interface

List every timer, stock warning and pre-ticked box on your Turkish storefront. For each, one question: is this information true? If yes it stays; if not it goes. Leaving grey areas is risky under this regulation, and the audit typically takes an afternoon and produces a longer list than expected.

Test your own cancellation flow

Try cancelling a subscription or membership on your own site and count the steps. Any exit that is harder than the entry is moving toward the dark-pattern definition.

Add disclosure clauses to collaboration contracts

Require the advertising or promotion notice contractually and review posts before publication. Corrections after the fact arrive late and the record remains.

Document your AI usage

Keep a record of which creative assets were AI-generated. When a labelling question arises, knowing which content is in scope is far easier than auditing an entire archive.

The Digital Side

This reads as a marketing loss. In practice it makes measurement honest.

False urgency conceals real performance

Conversion achieved through a countdown measures the success of pressure, not of the product or the price. Once the device is removed you see your actual conversion rate for the first time — uncomfortable, but useful, because every subsequent improvement is now measured from a real baseline.

Genuine urgency remains available

Genuinely limited stock, a real campaign end date and an actual delivery cut-off are not prohibited. What is prohibited is the invented version. A properly constructed campaign calendar does the same work and can be repeated without risk.

Disclosure does not always cost conversion

The assumption that labelled collaborations lose credibility is not borne out in practice; content openly identified as advertising performs better than content whose commercial nature is inferred. A collaboration discovered to be concealed, meanwhile, costs permanently.

Proof is again the common thread

The shared logic of this regulation is simple: mark your claim, show your source. On the e-commerce side this has become the most discussed heading of the period.

A Solid Digital Foundation

The obligation to disclose commercial relationships is not confined to what is visible; it has a technical counterpart in how links are marked.

Paid links must be identified

Links obtained in exchange for payment or other benefit need to be marked as such; unmarked paid links also affect how a site is assessed on the search side. Link attribution criteria are set out in the Google Search Central documentation. The disclosure obligation runs in two places at once.

Agency work is still your responsibility

Historic paid links or unlabelled collaborations sitting on your site are carried by whoever operates the site, not whoever created them. Archive review therefore does not tolerate deferral.

Expired campaign pages should be closed

A finished campaign whose page remains live keeps an invalid promise in publication. Every page past its end date should be updated or retired.

Tightening rules favour the prepared

This amendment belongs to a direction of travel and is expected to become more detailed. A business keeping its interface, contracts and content archive in order enters each new provision ready. How that discipline is built is set out in our approach to digital consulting.

Frequently Asked Questions