KVKK standard contracts: what the first full year's 2,497 notifications say

Law No. 7499 rewrote Article 9 of the Turkish data protection law in 2024. Where no adequacy decision exists, Article 9(4)(c) opens the route the numbers say teams actually take: the Board's standard contracts, signed with the text unchanged and notified within five business days of the last signature; since October 2024 the filing can be made through the Authority's online module. Missing the filing carries an administrative fine of 50,000 to 1,000,000 lira in the 2024 text, and the fine can be imposed on the data processor as well as the controller. The transfer analysis itself stays where it always was; what changed is that the safeguard now leaves a record.

The Authority counted 1,345 notifications in 2024, when the new regime ran for seven months, against three approved undertakings. The 2025 activity report, summarized by GRC Legal, 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. I read them differently: 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-day clock runs from the last signature, not from yours. The notification receipt. And a change note whenever parties or data scope move, so the team sees that the contract on file no longer describes the transfer that actually runs, before anyone else does.

Two years in, the pattern is familiar from other filing regimes: the duty looks clerical until the Authority starts reading its own register. Better to ask in a quiet week whether your notifications would survive that reading than to learn the answer during an examination.

Published 29 July 2026

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