KVKK standard contracts: what the first full year’s 2,497 notifications say
The rebuilt transfer regime has its first full-year numbers, thousands of contracts on file and the Authority now examining them. Filing inside five business days was never the hard part of this; the register those filings build is where the exposure sits.
Law No. 7499 rewrote Article 9 of the Turkish data protection law in 2024. Where no adequacy decision exists, the route the numbers say teams actually take is Article 9(4)(c): the Board’s standard contracts, signed with the text unchanged and notified within five business days of the last signature, and since October 2024 the filing can be made through the Authority’s online module. Missing that filing carries an administrative fine of 50,000 to 1,000,000 lira in the 2024 text, and it can land on the data processor as well as on the controller. The transfer analysis itself stays where it always was. What changed is that the safeguard now leaves a record behind it.
The Authority counted 1,345 notifications in 2024, a year in which the new regime only ran for seven months, against three approved undertakings. The Authority’s 2025 activity report counts 2,497 for the first full calendar year, and records the Authority opening ex officio examinations on 70 notifications, concluding 21 and fining three of them 150,000 lira in total. The fines are small enough to shrug at, and I wouldn’t. Every notified contract is now a data point the Board can query, and it has started querying.
The file I ask a legal team to show me is short. A transfer inventory listing each vendor and the mechanism it relies on. A signature log, because the five-business-day clock runs from the last signature and not from yours. The notification receipt. And a change note every time the parties or the data scope move, so that the team is the first to notice when the contract on file no longer describes the transfer that actually runs.
Two years in, the pattern is familiar from other filing regimes. The duty looks clerical for exactly as long as the Authority is not reading its own register. A quiet week is a better time to ask whether your notifications would survive that reading than the middle of an examination.
Published · Last updated · 2 min read
Sources
- Law No. 7499, Official Gazette 12 March 2024, No. 32487, Articles 34 and 35
- Regulation on the Transfer of Personal Data Abroad, Official Gazette 10 July 2024, No. 32598, Article 14
- KVKK, Standard Contract Notification Module announcement, Board decision 2024/1793 of 17 October 2024
- KVKK, 2024 Yılı Faaliyet Bilgi Notu
- KVKK, 2025 Activity Report, pp. 34 and 43
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