Regulation on Geospatial Data Permits (“Regulation”), prepared by the Ministry of Environment, Urbanization, and Climate Change (“Ministry”), was published in the Official Gazette dated October 14, 2026, and entered into force on the same date.
The basic framework for geospatial data (any type of data containing location information) was established by Presidential Decree No. 49 on Geographic Information Systems, which also provides for the National Geospatial Data Responsibility Matrix (“Matrix“), indicating which public institution is responsible for which geospatial data theme.
Although the procedures and principles of the permit regime for geospatial data covered by the Matrix were previously established by the Regulation on Geospatial Data Permits, published in the Official Gazette on February 10, 2021, that regulation was repealed upon the entry into force of the new Regulation. The new Regulation, in turn, reorganizes this permit regime.
Permit Requirement: Pursuant to the Regulation, natural persons, private-law legal entities, and foreign natural or legal persons are required to obtain a permit from the Ministry for commercial activities involving the collection, production, sharing, or sale of geospatial data covered by the Matrix.
However, the following cases are exempt from the permit requirement: (i) address information requested for the purpose of issuing an invoice, and (ii) the sharing of address and location data pertaining to the headquarters, branches, and agencies where activities are conducted, on a website or social media accounts.
Legal entities granted a distribution license by the Energy Market Regulatory Authority are also exempt from the obligation to obtain a permit and pay the permit fee, limited to their activities under the distribution license and provided that they register with the Ministry’s electronic infrastructure (the electronic environment in which the geospatial data permit process is tracked).
Application: In accordance with the Regulation, permit applications must be submitted through the Ministry’s electronic infrastructure prior to commencing operations. When applying, the data themes to be covered, the operational area, the activities to be carried out, and the requested permit duration must be specified. Foreign applicants are required to submit notarized copies of documents related to their commercial activities and letters of commitment entered into with the individuals or companies that will carry out their activities in Türkiye.
It is stipulated that the outcome of the application will be communicated to the applicant within 30 days, and that natural persons and private-law legal entities whose applications are approved must pay the permit fee within 15 days; otherwise, the application will be deemed invalid.
Permit Certificate: The validity period of the permit certificate will be determined between 1 and 5 years, subject to the permit holder’s request and the Ministry’s approval and will begin on the date the application is approved. If there are changes to the scope of activities, the area of operation, or the permit period, a new application must be submitted.
The permit fee will be calculated for Turkish citizen natural persons and private-law legal entities on the basis of the number of data themes, the business area, the permit duration and the net sales or sales revenue in the last accounting period, and for foreign natural persons and legal entities on the basis of the permit coefficient fee and the permit duration. It is stipulated that the permit fees will be announced each year on the Ministry’s unit price list.
In addition, Turkish citizen natural persons and private-law legal entities commencing commercial activity for the first time have been exempted from the permit fee for the year in which they commence activity.
Obligations of Permit Holders: Permit holders are required to submit their activity reports and geospatial data to the Ministry’s electronic infrastructure every twelve months and to share, free of charge, any geospatial data requested by the Ministry for use in disaster and emergency management.
Additionally, the Regulation requires that the Ministry be notified within 15 days of the termination of operations, changes in the business name or partners, changes in contact, personnel, and vehicle information, and, for foreign natural and legal persons, the termination of agreements with the individuals or companies conducting their activities in Türkiye. Furthermore, permit certificates of natural persons and private-law legal entities may not be transferred to third parties.
Penalties: Pursuant to the Regulation, if it is determined that operations are being conducted without a permit, the operator will be given 15 days to apply for a permit. If a Turkish citizen or a private-law legal entity fails to apply within this period, an administrative fine equal to the maximum annual permit fee will be imposed, while foreign individuals and legal entities will be subject to an administrative fine equal to twice the annual permit fee. An appeal against the administrative fine may be filed with the Ministry within one month; and if the appeal is rejected, an appeal may be filed with the administrative court within 30 days. A discount will be applied if the fine is paid within one month.
If a permit application is not submitted within 60 days of the notification of the administrative fine, the permit fee will be doubled.
Furthermore, the Regulation stipulates that a permit will be suspended in cases of failure to comply with the obligations in the permit agreement, if inspections reveal that the application requirements have been lost, or if incomplete or incorrect information is provided in the application. The permit will be revoked in cases such as failure to rectify deficiencies within 60 days, if it is determined that the permit holder no longer meets the application requirements, or if a situation contrary to national security is identified.
Status of Existing Permit Documents: Permits and licenses issued priorly under the Regulation on Geospatial Data Permits and the Regulation on Geospatial Data Licensing, which were both repealed by the Regulation, will remain valid until the end of the period stated in the documents.
Authors: Sümeyye Uçar, Maral Baymak