New Rules on Environmental Claims AI and the Digital Advertising Ecosystem
The Regulation Amending the Regulation on Commercial Advertising and Unfair Commercial Practices was published in the Official Gazette dated 1 July 2026 and numbered 33297. The amendment package, one of the most comprehensive revisions to date of the Regulation on Commercial Advertising and Unfair Commercial Practices (the “Regulation”), in force since 2015, will enter into force on 1 August 2026.
The package touches on nearly every topical debate in advertising law, from environmental claims and the use of artificial intelligence to influencer marketing, targeted advertising and online consumer reviews. Many of the changes run parallel to the European Union’s green claims and digital services legislation. The package is also significant in that it elevates areas hitherto governed largely through Advertising Board guidelines to the level of binding regulation.
1. A Stricter Substantiation Regime for Environmental Claims
Under the definition added to the Regulation, an environmental claim covers any statement or visual suggesting that a good or service delivers an environmental benefit, or that its adverse environmental impact has been reduced or eliminated, in relation to its components, production, placement on the market, presentation, use or disposal.
With the amendments to Article 17, which governs advertisements containing environmental claims, certificates and endorsements referred to in such claims must now be substantiated with documents obtained from competent authorities and institutions, the relevant departments of universities, or accredited or independent research, testing and evaluation bodies.
Generic concepts and expressions such as “environmentally friendly”, “sustainable” or “green” may no longer be used without explanation, or in a manner that leaves consumers uncertain as to the environmental impact of the product or its production processes.
Advertisements must also state clearly which part of the good or service, or which stage of its life cycle, the environmental claim relates to. Explanatory information on measurement and assessment methods must be provided within the advertisement itself or on a website or pop-up screen to which the consumer is directed.
The process that began with the Advertising Board’s 2022 Guideline on Advertisements Containing Environmental Claims, running parallel to the EU’s regulatory agenda on green claims, thus evolves into a binding and detailed regulatory regime. Greenwashing risk is no longer a matter of abstract principle: it is now tied to a concrete documentation obligation.
2. AI in Advertising: A Transparency Obligation and a Ban on “Digital Replicas” (Deepfakes)
One of the most striking novelties of the amendment is the introduction of the first explicit rules on the use of artificial intelligence in advertising.
Under the paragraph added to Article 18 of the Regulation, where artificial intelligence or other software is used in a manner liable to materially affect consumers’ economic behavior in relation to a good or service, or where digital characters created through AI technologies and indistinguishable from humans are featured, this must be disclosed in a clear, comprehensible and distinguishable manner.
In addition, under the provision added to Article 27, advertisements in which an AI-generated digital replica of a real person is falsely portrayed as having personally experienced or used a good or service, or as endorsing it, are prohibited outright.
Turkish advertising law thereby acquires a framework that directly addresses both AI transparency and deepfake content.
3. The Digital Advertising Ecosystem: Influencers, Targeted Advertising and Consumer Reviews
Advertising through social media influencers, an area governed until now through an Advertising Board guideline, is elevated to regulatory level with the new Article 23/A.
Influencer posts must carry one of the labels “Reklam” (Advertisement) or “Tanıtım” (Promotion) and identify the advertiser. The label must be distinguishable from the background, easily legible and visible without scrolling. It must appear before any other tags or explanations, and it must be repeated in each post where content spans multiple posts. In audio-only content, a verbal disclosure must be made at the beginning of the broadcast and before the advertisement.
The new Article 25/A defines targeted advertising for the first time: the delivery of advertisements tailored to specific persons or groups through the analysis of personal data such as consumers’ online behavior, preference history, location data and demographic information.
Such advertising may only be carried out on condition that information on the criteria by which the advertisement is displayed, and on how those criteria can be changed, is presented to consumers in a direct and easily accessible manner.
Where it is known, or can reasonably be expected to be known, that the consumer is a child, targeted advertising based on the profiling of personal data is prohibited altogether. This rule is reminiscent of the similar ban under the EU Digital Services Act (DSA).
Article 28/B on consumer reviews is, in turn, rewritten in its entirety. Only consumers who have actually purchased the good or service concerned will be permitted to post reviews online, and reviews sourced from channels where the purchase cannot be verified may not be published.
Reviews must remain published for at least one year, without any steering and on the basis of objective criteria, regardless of whether they are positive or negative. Entering into arrangements, or purchasing services, to procure fake reviews with a view to boosting sales is expressly prohibited.
The 72-hour period allowed in the review publication process is reduced to 48 hours, and reviews not responded to within that period will be published directly.
Other Changes
Other changes in the package include the following:
Discount advertising: The reference period for determining the pre-discount price is reduced from thirty days to ten days. That price will now be determined solely by reference to the sales channel in which the discount is offered. This represents a notable relaxation, operating in favor of sellers and suppliers, within an otherwise largely tightening package.
Loyalty programmes and conditional campaigns: The discount advertising rules are extended to advertisements for easily accessible loyalty programmes and conditional sales campaigns.
Academic titles: Academic titles are added to the list of matters that may not be used in a manner misleading to consumers.
Food supplements: The absolute ban on comparative advertising of food supplements is removed. Such products are instead brought within the prohibition on comparisons involving health claims, coupled with a ban on advertisements creating the impression that they can replace a normal diet.
Illegal games of chance: Illegal games of chance are expressly included within the scope of the advertising ban.
Regulated products: The advertising ban on medicinal products for human use, electronic cigarettes, tobacco products and alcoholic beverages is expressly regulated in the text of the Regulation itself, with Article 26 repealed in parallel.
Awards used in advertising: Advertisements may not feature awards that are not based on pre-announced objective criteria or that are granted in return for a benefit.
Assessment
Taken as a whole, the amendment package brings Turkish advertising law largely into line with current trends in the EU acquis, including the substantiation of green claims, AI transparency, the ban on targeted advertising to children and verified consumer reviews.
The compliance window running until 1 August 2026 is, however, remarkably short.
Advertisers, e-commerce platforms, intermediary service providers and brands working with social media influencers would be well advised to review their sustainability communications, discount and campaign mechanics, influencer agreements and consumer review processes against the new rules without delay.