1. Notarization Requirement Annulled for Corporate Books Kept in Electronic Form

It was previously regulated that companies which will be registered with the trade registry as of 01.01.2026 and joint stock companies whose incorporation or articles of association amendments are subject to the approval of the Ministry of Commerce will be required to keep the corporate books in electronic form. Other companies were granted the option to voluntarily transition to the electronic corporate books system. Further details regarding the relevant regulation can be found here.

Pursuant to the notifications sent by the Ministry of Commerce to the trade registry directorates, it has been stated that the resolutions in commercial books kept in electronic form can be reviewed directly through the Ministry’s system. Accordingly, there is no longer a need to submit notarized copies of such records.

The requirement for companies to obtain notarized copies of company resolutions to be submitted to third parties, especially trade registries, in order to confirm their consistency with the records kept in the corporate books, as well as the obligation to have such books certified by notaries upon opening and closing, imposed a significant financial burden on companies. The electronic corporate books system is considered a positive step in terms of the transformative impact of digitalization in minimizing certain procedures and costs, and is expected to encourage companies not subject to the obligation to adopt the system voluntarily as well.

2. Implementation of the Second Phase of the AI Act

On 13.03.2024, the European Parliament adopted the EU Artificial Intelligence Act and introduced the first legal framework to regulate artificial intelligence. As of 02.02.2025, the provision prohibiting unacceptable-risk AI systems has entered into force.

As of 02.08.2025, the specific obligations concerning general-purpose AI models (“GPAI”), as well as the provisions on governance, supervision, oversight and enforcement, have become applicable. The European Commission and the EU AI Office have published guidelines and code of practice for GPAI providers. From this date onwards, member states shall commence the process of designating their national market surveillance authorities, establishing a unified supervisory structure at EU level. As of 2 August, these rules will apply directly to all GPAI models placed on the market after this date, while models placed on the market before that date are expected to achieve full compliance by 02.08.2027.

A provider that retrains an existing GPAI model will be classified as a new GPAI provider if, during the retraining, it expends at least one-third of the computational power used to train the original model, and if the modification leads to a significant change in the model’s overall capabilities, risk profile, or intended purpose. Similarly, revisions that materially alter a model’s functionality or its systemic risk level may also lead to GPAI provider status.

GPAI model providers are subject to comply with certain fundamental obligations under the AI Act. They are required to document in detail all technical aspects of the model’s development, training, testing, and evaluation processes, and to keep such documentation up to date, making it available upon request to both downstream providers and supervisory authorities. In addition, the data used for training must be selected in compliance with intellectual property legislation, and providers are expected to adopt a copyright compliance strategy to prevent potential infringements. Each provider is also expected to establish a copyright policy ensuring that the use of training data complies with intellectual property rights. Furthermore, providers must publish a public summary of the training data sources and methods used and must cooperate with national and EU-level supervisory authorities by providing any information or documentation they may request.

Further details regarding the AI Act can be found here, and detailed information on the prohibition of AI systems posing an unacceptable level of risk can be found here.

3. A New Exemption Criterion Introduced for VERBIS Registration Obligation

Previously, natural or legal person data controllers with fewer than 50 employees and an annual financial balance sheet total below TRY 100 million, whose main activity does not involve processing special categories of personal data, were exempt from the obligation to register with VERBIS. Accordingly, data controllers whose primary activity involves the processing special categories of personal data were subject to the VERBIS registration requirement, regardless of their employee count or annual financial balance sheet.

However, pursuant to the Personal Data Protection Board’s Decision dated 04.09.2025 and numbered 2025/1572, it has been decided that natural and legal person data controllers whose main activity is the processing of special categories of personal data but who have fewer than 10 employees and an annual financial balance sheet total below TRY 10 million are now also exempt from the VERBIS registration obligation.

4. Amendment to Notifications under the Labor Law

Law No. 7555, published in the Official Gazette dated 24.07.2025, amended the provision of Article 109 of Labor Law No. 4857 concerning notifications to be made within the scope of the Labor Law.

The relevant article previously stipulated that notifications between the employer and the employee must be made in writing and signed by the relevant party. In cases where the receiving party refused to sign, this situation must be recorded by means of an official report.

The procedure requiring parties to issue written notifications and obtain the relevant party’s signature—particularly in relation to matters such as monthly wages and disciplinary warnings—was especially difficult to implement in workplaces where remote work is practiced. Alternatively, serving such notifications through a notary was not preferred due to cost considerations. Although it was not clear whether such notifications were legally valid, it had become common practice to serve such notifications to employees via registered electronic mail (“REM”).

The aforementioned amendment explicitly regulated that notifications between employer and employee may also be made through the REM, provided that the employee gives written consent. Therefore, it is recommended that employers revise their employment agreements regarding notifications to be made through REM or sign an additional protocol in this regard. The same amendment also stipulates that the costs associated with the use of the REM system shall be borne by the employer, and that termination notices may not be made through the REM.

The amendment, which entered into force on the date of its publication, is considered a positive step in terms of the transformative impact of digitalization in minimizing certain procedures and costs, as it now allows for notifications, excluding termination notices, to be validly made through the REM.

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