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.

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