Turkey's Web Accessibility Mandate: Presidential Circular 2025/10 Explained for International Companies

Short answer: Presidential Circular 2025/10, published in Turkey's Official Gazette on 21 June 2025 (issue 32933), makes web and mobile accessibility a binding obligation for a wide range of public institutions and private companies. The required standard is WCAG 2.2 Level A combined with the Ministry of Family and Social Services accessibility checklist (31 criteria, 126 questions). The first compliance deadline of 21 June 2026 has already passed for banks, private hospitals, universities, transport companies and other first-wave sectors, so the obligation is in force today; e-commerce providers have until 21 June 2027. There is no published fine schedule for websites yet, but review commissions, TİHEK oversight and procurement requirements make non-compliance a concrete business risk for companies serving the Turkish market.

This article is for general information only and is not legal advice. For decisions about your specific situation, consult qualified counsel in Turkey.

Table of contents

• What Circular 2025/10 requires and why it exists
• Timeline reality: the first deadline has already passed
• Who is in scope and what it means for multinationals
• The technical standard: WCAG 2.2 Level A plus the ministry checklist
• Enforcement stated honestly: what the law does and does not say about fines
• Action plan for international companies
• Where automated scanning and an accessibility statement fit in
• Frequently Asked Questions
• Sources

What Circular 2025/10 requires and why it exists

On 21 June 2025, Turkey published Presidential Circular 2025/10 on the Accessibility of Websites and Mobile Applications in the Official Gazette (issue 32933). The circular converts what used to be soft guidance into a binding obligation: organizations within its scope must make their websites and mobile applications accessible to people with disabilities, against a defined technical standard and within fixed deadlines.

The circular did not appear out of nowhere. Turkey has had a disability rights framework since 2005 under Law No. 5378 on Persons with Disabilities, which established accessibility as a legal principle and created monitoring commissions for the physical environment. On the digital side, public institutions have long had KAİK, the accessibility guide for public information systems published by the Digital Transformation Office and applied within the framework of Circular 2019/12. KAİK, however, was guidance aimed at the public sector. If you want the background on that earlier framework, see our KAİK guide.

Circular 2025/10 changes the picture in three ways:

• It extends digital accessibility obligations beyond government to large parts of the private sector, including banks, hospitals, schools, transport and e-commerce.
• It names a concrete technical standard: WCAG 2.2 Level A, applied together with a national checklist published by the Ministry of Family and Social Services.
• It creates a compliance machinery: each in-scope organization must establish an internal review commission that inspects, reports and tracks remediation, reporting to the ministry. Sites and apps found conformant can receive an official Accessibility Logo, valid for two years before re-evaluation.

For a clause-by-clause walkthrough of the circular itself, our Circular 2025/10 regulation page covers the full text, the commission mechanics and the logo process in detail.

Timeline reality: the first deadline has already passed

This is the point international teams most often get wrong, so it deserves emphasis: for the first-wave group, the compliance deadline was 21 June 2026, and it has passed. As of today, the obligation is not upcoming for those organizations. It is in force.

Two practical consequences follow:

1. First-wave organizations that are not yet conformant are in a remediation posture, not a preparation posture. The sensible response is a documented, dated remediation plan showing active progress, because review commissions and the ministry will look at what an organization can demonstrate, not what it intends.
2. E-commerce providers still have runway, but less than a year of it. Accessibility remediation on a large storefront routinely takes several release cycles: template fixes, third-party widget replacements, checkout flow rework and content retrofits. Starting in 2027 would be starting late.

Who is in scope and what it means for multinationals

The circular's scope is defined by sector and activity, not by where a company's headquarters sits. That matters for international groups in three common configurations:

1. A Turkish subsidiary in a listed sector. If your group operates a bank, private hospital chain, private school, transport company or a telecom operator with 200,000 or more subscribers in Turkey, the Turkish entity is in the first-wave group and the deadline has already passed. The obligation attaches to the entity's Turkish websites and mobile applications.

2. An e-commerce business serving Turkish customers. E-commerce service providers fall in the second wave with a 21 June 2027 deadline. If you run a Turkish storefront (a .com.tr domain, a Turkish-language shop, local fulfilment and Turkish consumer-facing operations), you should treat that property as in scope and plan accordingly. Whether a given cross-border setup is covered can involve fact-specific legal questions, which is exactly the kind of point to confirm with Turkish counsel rather than assume away.

3. A global site with a Turkish market section. Groups often serve Turkey from a global platform with a localized section. Here the pragmatic approach is to evaluate the Turkish-market experience end to end: the localized pages, the checkout or application flows Turkish users actually complete, and any mobile app distributed to Turkish users. Scoping by user journey is both closer to the circular's intent and easier to defend than scoping by domain name.

A useful mental model for EU-based companies: this is structurally similar to the European Accessibility Act, which also pulls private-sector digital services into a binding accessibility regime with fixed dates. If you have already scoped EAA work for your EU properties, the same inventory-and-journey mapping exercise applies to Turkey, with a different standard and different deadlines. Our EAA guide covers the EU side.

The technical standard: WCAG 2.2 Level A plus the ministry checklist

Circular 2025/10 anchors conformance to two instruments used together:

• WCAG 2.2 Level A, the W3C's Web Content Accessibility Guidelines at its baseline conformance level, and
• the Ministry of Family and Social Services "Checklist for the Accessibility of Websites and Mobile Applications", a national evaluation instrument organized as 31 criteria expanded into 126 questions.

The checklist is how the standard is operationalized in Turkey: review commissions and evaluators work through the 126 questions, and the Accessibility Logo is granted on that basis. In practice, teams should treat WCAG 2.2 Level A as the engineering target and the checklist as the audit format their evidence needs to map onto.

How this relates to WCAG work you already do

If your organization already runs WCAG programs for the EU, US or UK, most of that investment transfers directly:

• Level A is a subset of what you probably target. Many international programs aim at WCAG 2.1 or 2.2 Level AA. Everything you have done at Level AA includes the Level A success criteria, so a mature AA program should find the Turkish baseline largely covered, subject to the 2.2-specific criteria and the checklist's question format.
• WCAG 2.2 adds criteria over 2.1. If your audits are still pinned to WCAG 2.1, you will need to pick up the success criteria introduced in 2.2 at the levels relevant to you (at Level A, Consistent Help and Redundant Entry; at higher levels, focus appearance, dragging alternatives and accessible authentication).
• The deliverable format differs. A VPAT or an EN 301 549 conformance report does not automatically read as answers to the ministry's 126 questions. Plan a mapping exercise so your existing evidence can be presented in the national format.

WCAG 2.2 vs EN 301 549: do not mix up the regimes

A frequent misunderstanding in international teams: EN 301 549 is not the standard of Circular 2025/10. EN 301 549 is the harmonized European standard that underpins the European Accessibility Act and EU public-sector rules. It incorporates WCAG for web content, so the technical overlap is large, but the Turkish circular's reference point is WCAG 2.2 Level A plus the national checklist, full stop.

The practical takeaway: one accessibility engineering effort can serve both regimes, but the documentation and audit trails are separate deliverables.

Enforcement stated honestly: what the law does and does not say about fines

Some vendors market Turkish web accessibility with alarming fine numbers. The honest picture is more nuanced, and worth stating precisely.

What exists today:

• Law No. 5378 contains an administrative fine mechanism of 5,000–25,000 TL per finding, applied through monitoring and inspection commissions. In its current form, that fine schedule is directed at physical accessibility: buildings, open spaces and public transport.
• There is no published fine tariff specifically for websites and mobile applications yet. Anyone quoting a per-violation lira amount for web content as settled law is ahead of the actual legislation.

What the real near-term risk looks like:

• Review commissions and ministry reporting. In-scope organizations must stand up internal review commissions that inspect, report and track remediation. A first-wave organization with no commission, no report and no remediation plan is visibly non-compliant with the circular itself, regardless of fines.
• TİHEK oversight. Turkey's Human Rights and Equality Institution has publicly engaged with the circular and handles discrimination complaints. Digital inaccessibility can surface as an equality issue through that channel.
• Procurement and contractual pressure. Public tenders and large corporate customers in Turkey increasingly reference accessibility conformance. Losing eligibility for a tender is a more immediate commercial cost than any hypothetical fine.
• Reputation. The Accessibility Logo creates a visible distinction between organizations that can demonstrate conformance and those that cannot.

It is also reasonable to expect the enforcement framework to develop. A regime that has defined standards, deadlines and audit machinery, but not yet a monetary tariff for the digital layer, is a regime in motion. Building the compliance file now is cheaper than reacting later.

Action plan for international companies

A workable program for a company with Turkish-market properties looks like this:

1. Inventory the Turkish-market estate. List every website, subdomain, web application and mobile app serving Turkish users, and classify each against the circular's sector groups and deadlines. Decide, with counsel where needed, which properties you treat as in scope.
2. Run a baseline audit against WCAG 2.2 Level A. Combine automated scanning with manual testing of key journeys (login, search, checkout, forms, PDFs). Map findings to the ministry checklist's 31 criteria so the output is usable as national-format evidence from day one.
3. Publish an accessibility statement. A public statement describing your conformance status, known limitations and feedback channel is standard practice under the EAA and the natural first artifact of a Turkish program as well. It documents good faith while remediation is ongoing. You can prepare one with our accessibility statement generator.
4. Build a dated remediation roadmap. Prioritize by user impact and legal exposure: blocking defects on core journeys first, then systemic template issues, then content-level fixes. For first-wave organizations past the deadline, a credible dated roadmap is the single most important document to have.
5. Stand up the internal review commission. Assign ownership, meeting cadence and reporting lines as the circular requires, and keep minutes. This is compliance machinery an auditor will ask about.
6. Monitor continuously. Accessibility regresses with every release. Scheduled scans, regression checks in CI where feasible, and periodic manual re-audits keep the conformance level you paid to reach.
7. Align with your EAA program. Share component fixes, design-system improvements and testing capacity across the EU and Turkish workstreams. The engineering is common; only the reporting differs.

Where automated scanning and an accessibility statement fit in

No tool makes an organization compliant, and any vendor telling you otherwise should be treated with suspicion. What tooling can honestly do is help you measure, remediate faster and document your state over time, which is what the compliance file rests on.

Automated WCAG scanning finds the machine-detectable portion of issues (missing alternative text, contrast failures, label and structure defects, keyboard traps that static analysis can catch) and tracks a conformance score across releases. That gives a remediation program its baseline, its trend line and its regression alarm. Manual expert testing remains necessary for the criteria automation cannot judge. It is also worth understanding what accessibility overlays can and cannot do before relying on one; we wrote a candid comparison in overlay vs scanner.

cerez.io's accessibility toolkit combines automated WCAG 2.2 scanning with an on-page assistance widget and an accessibility statement generator, so a team working toward Circular 2025/10 can measure against the standard, give users concrete assistance options, and keep the statement and scan history that a review commission or auditor will want to see. It supports and documents the work; the conformance itself is engineered by your team.

Frequently Asked Questions

Does Turkey legally require website accessibility in 2026?

Short answer: Yes. Presidential Circular 2025/10, published on 21 June 2025, makes web and mobile accessibility a binding obligation for the sectors it lists. The first-wave deadline of 21 June 2026 has passed, so for public institutions, banks, private hospitals, universities, transport companies and the other first-wave sectors the obligation is already in force. E-commerce providers must conform by 21 June 2027.

Who must comply with Presidential Circular 2025/10?

Short answer: Public institutions, municipalities and universities, plus named private sectors: banks, private hospitals, private schools, transport companies, Group A travel agencies and electronic communications operators with 200,000 or more subscribers, all with the 21 June 2026 deadline. E-commerce service providers form the second wave with a deadline of 21 June 2027.

Does Turkey use WCAG or EN 301 549 as its standard?

Short answer: Turkey's circular requires WCAG 2.2 Level A together with the Ministry of Family and Social Services checklist (31 criteria, 126 questions). EN 301 549 is the related European standard under the EAA, not the standard of the Turkish circular, although the technical overlap with WCAG is substantial.

Are there fines for inaccessible websites in Turkey right now?

Short answer: There is no published fine tariff specifically for websites yet. Law 5378's administrative fine schedule of 5,000–25,000 TL per finding currently targets physical accessibility. The near-term risks for web are review commission findings, TİHEK oversight, procurement eligibility and reputation, and the enforcement framework may well develop further.

Does the circular affect foreign companies selling into Turkey?

Short answer: It can. Scope follows sector and activity in the Turkish market, not headquarters location. A Turkish subsidiary in a listed sector, or an e-commerce operation serving Turkish customers, should treat its Turkish-market websites and apps as in scope and confirm edge cases with Turkish counsel.

Sources

• Presidential Circular 2025/10, Official Gazette, 21 June 2025, issue 32933 (PDF, Turkish)
• TİHEK press statement on Circular 2025/10 (Turkish)
• W3C, Web Content Accessibility Guidelines (WCAG) 2.2
• Directive (EU) 2019/882, the European Accessibility Act

If you are building a Turkish-market accessibility program, start by measuring where you stand. Start free with an automated WCAG 2.2 scan and an accessibility statement for your site, or review plans and pricing. This article is for information purposes and is not legal advice.