Starting an e-commerce activity
Business model, role as seller or intermediary service provider, ETBİS and basic legal obligations.
Review the scopeE-commerce and internet law covers the legal framework of online sales, digital platforms, advertising, user content and the contracts connected to them. The responsibility of the seller, provider, marketplace, content or hosting provider, payment institution and advertising counterparty is determined by the role assumed in the specific transaction.
Güneş & Güneş Law Firm provides pre-launch legal design, regulatory compliance, contract infrastructure, platform–seller relationships, consumer processes, advertising review, content management and dispute resolution services for online stores, electronic commerce marketplaces, mobile applications, listing and reservation platforms, subscription systems, social commerce models, services hosting user content and cross-border sales channels.
In the review, the legal texts are considered together with the screens the user sees, the company’s actual workflow, third-party integrations and the records kept. Visibility of the pre-contractual information, the ability to submit a withdrawal request, proof of the discount calculation and follow-up of seller objections fall within the same scope of work.
IF YOU HAVE AN URGENT MATTER
If your seller account has been suspended, a payment transfer has stopped, unlawful content has been published or you have received an official notice, state the date of the action and the notice in your first communication. For approaching deadlines, contact the firm by telephone without waiting for a reply to the form.
Telephone and contact detailsFrom the establishment of the activity to its daily operation and the dispute stage, the role, contracts, interface and records are assessed together.
Business model, role as seller or intermediary service provider, ETBİS and basic legal obligations.
Review the scopeCommission, payment, intermediation agreement, account suspension, listing and objection processes.
Review the scopePre-contractual information, distance contract, delivery, withdrawal, return and subscription terms.
Review the scopeCampaigns, social media collaborations, AI advertising, reviews and content notices.
Review the scopeCookies, KVKK, İYS, payment flow and e-export obligations depending on the target country.
Review the scopeAdministrative review, consumer application, platform dispute, litigation and interim legal protection.
Review the scopeThe first step of the review is to determine not the company’s name or the software it uses but the role it assumes in the specific transaction.
| Situation | Key distinction | Point examined in the review |
|---|---|---|
| Selling on one’s own site / operating a marketplace | The obligations of a seller and of an intermediary platform differ. | Who forms the contract; who collects the price; who delivers the product? |
| Consumer transaction / transaction between merchants | Withdrawal and application provisions specific to consumers do not carry over to all B2B transactions. | The purpose of the purchase, the status of the parties and the contractual relationship. |
| Withdrawal / defective goods or services | The conditions and time limits for withdrawal without giving a reason are separate from those for rights arising from a defect. | The type of product or service, and delivery and information records. |
| Payment integration / payment service | Integration with a licensed institution does not place every money flow of the platform under the same legal status. | The flow of collection, custody, transfer, return and chargeback (ters ibraz). |
| Activity in Türkiye / services to users in the EU | The scope of the DSA does not arise automatically from every commercial contact with the EU. | The nature of the intermediary service, the target users and the connection with the EU. |
Application and notification time limits are determined for each transaction. Objecting to the platform, applying to an authority or submitting a consultation form does not by itself suspend other time limits for lawsuits and objections.
Basis: Law No. 6563 and secondary regulations · Distance contracts · EU digital services
You can review the scope of the service by opening the relevant area from the headings below. Depending on the needs of the business model, more than one area can be handled together.
The contract and revenue flow of a marketplace, direct sales, listing, reservation, subscription, membership, commission, advertising, dropshipping, social commerce or hybrid model is reviewed. Before launch, the parties, payment, delivery, return, data, content and responsibility points are mapped.
The company’s capacities as ETHS, ETAHS, seller, provider, intermediary service provider, content provider or hosting provider are determined transaction by transaction. If the same structure involves more than one capacity, the obligations are shown in separate columns.
An obligations inventory is prepared on the basis of Laws No. 6563, 6502, 5651, 6698, 6098 and 6102 and special regulations specific to the business model. The interface, contracts, internal processes and third-party integrations are reviewed against this inventory.
The identifying information, order flow, confirmation, registration, ETBİS and consumer processes of a business selling in its own electronic commerce environment are arranged. Selling through a marketplace and selling in the business’s own environment are distinguished.
The marketplace’s seller information, internal communication system, intermediation agreement, unfair commercial practices, data use, intellectual property right notices, advertising and licensing obligations are reviewed. The obligations are classified by net transaction volume, number of transactions and the other criteria in the law.
The monetary thresholds under Law No. 6563 that change annually, together with the electronic commerce license and independent review requirements, are assessed on the basis of current-period data. The transaction volume, the calculation excluding cancellations/returns, the connected economic unit and consolidated data are also checked separately.
For a business determined to be subject to ETBİS registration, domain names, mobile applications, warehouse/production sites, cross-border activity and change notifications are arranged. The position of a person selling on a domestic marketplace and that of a business selling in its own environment are not treated as the same. ETBİS registration is not a security certificate or an approval of the legal compliance of all activities. Because the ETBİS QR code practice has ended, descriptions of the old QR code obligation should not be confused with the current registration process.
The trust stamp is explained as not being a mandatory registration, and security, accessibility and service standards are assessed before an application. ETBİS registration or the trust stamp is not used as a statement that is sufficient by itself for compliance with all legislation and transaction security.
The trade name, business/brand information, MERSİS or tax information, head office address, registered electronic mail (KEP), verified contact details, seller capacity and the relevant professional rules are displayed in the appropriate place. The functions of the footer, seller profile, order page and pre-contractual information areas are separated.
Basis: Law No. 6563 and secondary regulations · ETBİS explanations
User acceptance, account security, permitted use, content license, intellectual property rights, fees, termination, suspension, liability, notices and dispute provisions are drafted according to the business model. Provisions that remove consumer rights or give the platform unlimited unilateral authority are not used.
The scope of services, commission, payment, ranking, advertising, logistics, data access, intellectual property rights, content measures, account restrictions, termination and notice procedure are clearly regulated. Consistency is ensured between contract amendments and the actual practice in the panel.
A proportionate verification flow is set up for the seller application, MERSİS/tax/tradesperson information, KEP, head office address, authorized person, bank account and, where necessary, sector permit. Identity information and documents with no recording purpose are not collected.
Practices that significantly disrupt the seller’s commercial activity, reduce its ability to make reasonable decisions or force it into a particular decision are assessed. Payment delays, unilateral fees, retroactive changes, unexplained ranking and disproportionate account restrictions are addressed by reviewing the contract and the actual process together.
The easy and free communication system between the platform and the seller is designed with notice, tracking number, responsible unit, time limit, reply and objection record. Consumer requests and seller business objections are not routed to the same queue or the same reply template.
Who will use sales, price, performance, advertising, customer, search and ranking data, and for what purpose, is determined. The platform’s use of data while competing with the seller, the seller’s access to its own data and the handover of data when the contract ends are reviewed under Law No. 6563, competition law, contract law and KVKK.
The effects of search results, the recommender system, commission, sales performance, delivery, advertising and sponsorship are assessed. The main parameters that must be disclosed to the user and the seller and the technical details that are trade secrets are determined in a balanced way.
Sponsored results, showcase placements, coupons, free shipping, loyalty programs, cross-selling and in-platform advertising spaces are regulated according to their legal nature. An interface and record standard is established so that advertising is separated from organic results, the fee is disclosed in the contract and the consumer is not misled.
Suspension of a seller’s or user’s account, removal of a product from the listing, reduction of visibility and termination of the contract are reviewed in terms of law, contract, reasons and proportionality. A decision procedure is prepared on behalf of the platform; an objection, a request for records and a litigation strategy are prepared on behalf of the seller.
A notice-and-objection flow is set up for claims of infringement of trademarks, designs, patents, copyright, photographs, catalogs and product content. The document proving ownership, the infringing link, the declaration, the measure, the seller’s reply and the record of repeat infringement are reviewed proportionately.
A decision matrix is prepared for prohibited or permit-requiring products, misleading listings, counterfeit products, health claims, illegal services and content infringing the rights of third parties. Notice, interim measure, review, reasons, objection and the necessary application to an authority are separate stages.
For products offered through distance sales, the role of the manufacturer, importer and the relevant economic operator is reviewed, together with the identification of the product, the necessary conformity information and safety warnings. A process is prepared for receiving product safety notices, removing risky products from listings, cooperating with the competent authority and, where necessary, recall communications. The duties of the seller and the marketplace are not treated as the same; technical regulations specific to the type of product are also checked separately.
Basis: Law No. 6563 and secondary regulations · Online product safety
The obligations of content, hosting, access or social network providers to provide information, give notices, keep records and implement decisions are reviewed under the current provisions. No general assumption is used that the platform is automatically responsible for all content or has no responsibility at all.
The correct legal route is determined for reasoned notices concerning personality rights, private life, trademark/copyright, unfair competition, suspicion of a criminal offense or consumer safety. A request or objection is prepared taking into account legislative amendments, Constitutional Court decisions, freedom of expression and proportionality.
The connection of a review to an actual transaction, publication criteria, equal treatment of positive and negative reviews, fake reviews, the seller’s right of reply and personal data risk are regulated. The verification and complaint publication rules in force from August 1, 2026 are carried into the interface processes.
Before content is removed, an account is closed or the contract version changes, preservation of the relevant URL, date, order number, notice and transaction record is considered. A screenshot alone is not regarded as sufficient in every case; the integrity of the record, the manner in which it was obtained, personal data and, where the specific case requires, preservation of evidence through a notary or a court are addressed together.
Basis: Advertising regulations · Changes to duties under Law No. 5651 · Social network and gaming platforms
A pre-contractual information form specific to the type of sale, the distance contract, the withdrawal notice and the sample form are prepared. A single text is not used for goods, services, digital content, subscriptions, reservations and custom-made goods.
It is ensured that the product/service, tax, delivery, additional costs, time and contract terms are clearly shown before payment. Pre-selected additional services, unclear buttons, fees that appear at the last stage and missing order confirmation are corrected in the interface.
The consumer’s notice of withdrawal, return of the goods and refund of the price are separate stages. As a rule, the start of the fourteen-day right of withdrawal and of the time limits for returning the goods and refunding the price, the exceptions and the duty to inform are reviewed together. For a return made with the carrier specified in the pre-contractual information, return costs cannot be imposed on the consumer; if no carrier is specified, return costs also cannot be requested from the consumer. The platform’s role in collecting payment, its responsibility for returns and the evidence records are assessed separately. Rights arising from defective goods or services are addressed separately from the right of withdrawal without giving a reason.
The seller or provider must perform its obligation within the time it has committed to after the order reaches it. Except for goods prepared according to the consumer’s request or personal needs, this period for the sale of goods cannot exceed thirty days. Merely handing goods over to a cargo carrier is not considered delivery to the consumer. Being out of stock is not, by itself, accepted as impossibility of performance. Delivery, loss and damage, notice of impossibility, termination of the contract and refund of the price are reviewed taking into account the different roles of the seller, the platform and the carrier.
Basis: Distance contracts · Consumer legislation
For applications, online education, games, memberships, streaming, downloadable content and automatic renewal models, the scope of the service, time of delivery, usage license, termination, return and defect provisions are regulated. An exception to withdrawal is not assumed; the consumer’s prior information and the necessary consent are shown in the specific flow.
Applications and defenses are prepared in disputes concerning defective goods/services, non-delivery, withdrawal, refund of the price, unfair terms and platform liability. The monetary threshold that changes every year and the subject-matter jurisdiction, territorial jurisdiction, mediation and time limit conditions are verified as of the date of application.
In B2B sales that are not consumer transactions, the order, acceptance, notice of defect, invoice, delivery, payment, limit of liability and jurisdiction/arbitration provisions are addressed. Provisions specific to consumers do not automatically apply to transactions between merchants; review under the rules on general terms and conditions and on unfair competition remains reserved.
Deceptive interfaces that steer the user toward an unwanted selection, membership, additional payment or data consent are reviewed. Accept and reject options, subscription cancellation, account closure, hidden costs and pressure-creating countdown designs are regulated by taking law, accessibility and user experience into account together.
Basis: Distance contracts · Consumer legislation · Subscriptions
The price before the discount, the lowest price in the last ten days, conditional sales, coupons, loyalty benefits, personalized offers and stock/time statements are reviewed under the current advertising rules, including the provisions that entered into force on August 1, 2026. The campaign rule and the result on the checkout or payment screen must be the same.
A preliminary check is made for the accuracy of the advertisement, proof, covert advertising, health/environmental claims, price, consumer reviews and unfair commercial practices. Advertising Board (Reklam Kurulu) review, defense, submission of documents, suspension and administrative sanction processes are followed.
Where there is a benefit such as money, a discounted product/service or participation in an event, the advertising nature of the post is clearly stated. The brand–agency–content creator agreement regulates the script, mandatory disclosure, intellectual property rights, measurement, crisis and responsibility for content that violates legislation.
The use of AI characters that cannot be distinguished from humans and content giving the impression of an experience/recommendation by a digital copy of a real person are reviewed under the 2026 advertising provisions. The production tool, permission, source, disclosure and approval records are kept in the campaign file.
Disclosure of targeting criteria to the user, the ability to change preferences, the condition for processing personal data and data sharing with the advertising platform are assessed together. The prohibition on targeted advertising to children through profiling based on personal data is applied at the product, audience and interface level.
Basis: Advertising regulations · Discounted sales
Consent, the merchant/tradesperson exception, service notifications, the right to refuse, the Message Management System (İYS) record, the role of the intermediary service provider and evidence records are arranged. For SMS, e-mail, calls and app notifications, the content and the recipient group are reviewed separately.
The compatibility of customer account, order, recommendation, advertising, analytics, cookie, fraud prevention and support processes with the personal data inventory is ensured. Detailed data protection work is carried out within the linked KVKK service; commercial message consent, cookie preference and acceptance of the contract are not combined in a single declaration of intent.
Basis: Law No. 6563 and secondary regulations · KVKK transfers · KVKK cookie guide
The capacity in which the platform receives the price, whether it holds it, when it transfers it to the seller and who bears the risk of returns and chargebacks are shown in the contract and the panel. Providing a payment service and integrating a licensed provider are distinguished; an activity that requires a license is addressed separately under the relevant financial legislation.
The target country, targeting of consumers, applicable law, jurisdiction, tax/customs, product, return, data transfer and local representation requirements are reviewed country by country. For services intermediating for EU users, where the conditions are met, the Digital Services Act (DSA), platform transparency, seller traceability and content objection routes are coordinated with legal counsel in the country concerned.
Basis: KVKK transfers · EU digital services
Requests for information and reviews by the Ministry of Trade (Ticaret Bakanlığı), the Advertising Board, the Information and Communication Technologies Authority (Bilgi Teknolojileri ve İletişim Kurumu), the Cyber Security Presidency (Siber Güvenlik Başkanlığı), the Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu) and, depending on the business model, other competent authorities are assessed. The current allocation of duties, time limit, authority, scope, the meaning of the records, corrective action and the route of recourse against an administrative sanction are determined for the specific file.
In disputes between platform and seller, seller and consumer, brand and content creator, software/integration and internet content, mediation, litigation, arbitration and, where the conditions are met, interim injunction/precautionary attachment routes are pursued. It is ensured that order, panel, log, contract version, notice, payment, delivery and communication records are placed in the file in a lawful manner.
Basis: Law No. 6563 and secondary regulations · Distance contracts · Changes to duties under Law No. 5651
In addition to the legal texts, transaction screens, operations, third-party contracts and evidence records are also reviewed.
The same company may be an electronic commerce service provider in one transaction, an intermediary service provider in another, a content provider with regard to its own content and a hosting provider to the extent that it offers space to third parties. A statement such as “We are only a platform” or “We only provide technology” does not by itself determine the legal outcome. Between whom the contract is formed, on whose behalf the price is collected, who creates the product or service information, who manages the delivery and return process, what authority is exercised over the content and how revenue is earned are examined together.
| Appearance of the activity | Likely role | Core legal review |
|---|---|---|
| Sale of goods/services from one’s own site or application | Electronic commerce service provider; seller/supplier | Law No. 6563, Law No. 6502, pre-contractual information, order, delivery, withdrawal and return |
| A marketplace that brings third-party sellers together with buyers | Electronic commerce intermediary service provider; intermediary in distance contracts | Intermediation agreement, seller information, unfair commercial practices, request system and records |
| Listing, reservation or matching environment | Intermediary, content provider or hosting provider, depending on the business model | Party to the contract, listing verification, responsibility for content and sector-specific permits |
| Hosting of user reviews, videos, listings or posts | Content provider/hosting provider and platform operator | Law No. 5651, content notices, personality rights, intellectual property rights and records management |
| Regular sales through social media | Seller/supplier and, where the conditions are met, electronic commerce service provider | Distance contract, identifying information, advertising, payment and consumer rights |
| Providing subscriptions or digital content | Supplier; digital service operator | Establishment, renewal, termination, exception to withdrawal, digital delivery and defective service |
| Commission, prominence or advertising revenue | Platform/advertising medium | Ranking, fees, advertising transparency, targeting, data use and competition law |
| Platform services to users in the EU | In addition to Turkish law, the DSA and other EU rules where the conditions are met | Target market, representation, seller traceability, content notices and transparency |
The legal role is determined not by the name the company has chosen but by the actual model. If the same interface includes consumer transactions, contracts between merchants and user content, each flow is assessed under its own rules.
All stages, from membership to the retention of records, are assessed together.
| Transaction stage | Legal review | Core record to be retained |
|---|---|---|
| Company and business model | Role, permit, registration, tax and cross-border structure | Corporate decisions, process map and authority records |
| Seller onboarding | Verification of identity/business information and the intermediation agreement | Application, verification and contract version |
| Product/listing entry | Mandatory information, product safety, intellectual property rights and prohibited content | Listing version, source and time of approval |
| Ranking and prominence | Main parameters, advertising nature and fee | Ranking rule, campaign and sponsor records |
| Before the order | Pre-contractual information, total price and additional fees | Text shown to the user and interface version |
| Order and payment | Clear payment obligation, confirmation and payment role | Order, timestamp, approval and payment reference |
| Delivery/performance | Time, stock, impossibility, damage and logistics | Shipment, delivery, service activation and notification |
| Withdrawal/return | Notification channel, exception, carrier and refund of the price | Request, confirmation, shipment and time of return |
| Review/complaint | Verification, publication principle and reply time | Purchase verification, moderation and reply |
| Account/content measure | Contract, law, reasons and objection | Notice, reason for the decision, review and outcome |
| Retention/deletion | Legislation, proof, KVKK and security | Retention rule, access, deletion and audit record |
This approach ensures that the screen presented to the consumer, the legal text and the company’s internal practice are the same. A template text disconnected from the actual order and return flow can conceal corporate risk.
The table below is a general review framework. The company’s size, role, target market, type of product/service, number of transactions and net transaction volume may change the scope of some obligations.
| Topic | Core rule | Practical check |
|---|---|---|
| ETHS/ETAHS role | Determined by the actual activity and the contract structure | Have the transaction, price, data, delivery and content flows been mapped? |
| ETBİS | Businesses that conduct e-commerce in their own environment, ETAHSs and certain cross-border sellers may fall within the scope of registration before starting the activity | Are the registration, domain name, application, warehouse and change notifications up to date? |
| Identifying information | The trade name, head office, contact details, KEP and other information depending on status must be accessible | Is the information in the footer, on the seller page and on the order screen consistent? |
| Intermediation agreement | The minimum elements and the prohibitions on unfair commercial practices are taken into account | Are commission, payment, data, ranking, suspension, termination and notice clear? |
| Internal communication | ETAHS–ETHS communication is conducted through an easy and free system | Are tracking, reply, objection and version records kept? |
| Pre-contractual information | Goods/services, the parties, total price, additional costs, withdrawal and the route for seeking redress are disclosed before payment | Is the text on the screen shown the same as the text on the durable medium? |
| Order | The payment obligation must be clear and the order must be confirmed electronically | Can the button, total price, approval and time record be audited? |
| Delivery | Goods must be delivered within the committed time. Except for goods prepared according to personal needs, the period cannot exceed thirty days. | Are handing over to the carrier and delivery to the consumer distinguished; are stock and notification records preserved? |
| Withdrawal | Unless an exception applies, the consumer may, as a rule, withdraw within fourteen days | Is the notification channel clear; are the exception information/consent present in the specific flow? |
| Refund of the price | In cases of withdrawal and other returns, the rules on time limit and means of payment apply | Do the request, shipment of the product, start date and refund record match? |
| Additional payment | An explicit choice by the consumer is required instead of a pre-selected additional fee | Are insurance, shipping, donation, membership or additional services selected automatically? |
| Discount price | As of August 1, 2026, the lowest price of the previous ten days is generally used as the basis | Are the price history and campaign calculation kept in an unalterable record? |
| Targeted advertising | The display criteria and the change of preferences are explained in an easy way | Are the targeting logic, data source and preference panel consistent? |
| Advertising to children | Targeted advertising through profiling based on personal data is prohibited | Are age, audience, product and advertising network checks carried out? |
| Social media promotion | A post involving a benefit is clearly indicated as advertising/promotion | Are there a contract, a pre-publication check and a screen recording? |
| AI advertising | An indistinguishable digital character is disclosed; the prohibition concerning the digital copy of a real person is observed | Are the permission, production record, disclosure and final approval retained? |
| Consumer review | A review taken from a medium where the purchase cannot be verified cannot be published | Are verification, moderation, reason for rejection and the seller’s reply recorded? |
| Commercial electronic message | Consent/exception, İYS, refusal and content rules apply | Can the source, date, channel, scope of the permission and the refusal be proven? |
| Content and intellectual property rights | Notice, review, interim measure, objection and repeat record are conducted proportionately | Are the rights document, URL, seller’s reply and reasons for the decision kept together? |
| Law No. 5651 | Information, record and decision-implementation obligations vary according to the status of the actor | Have the content/hosting provider role and the current provision been verified? |
| Monetary thresholds | The thresholds under Law No. 6563 may be updated by the annual rate of change | Have the 2026 criteria and the connected economic unit been recalculated? |
| KVKK/cookies | The processing condition, privacy notice, preference, security and transfer regime are reviewed separately | Have mandatory and non-mandatory cookies been separated? |
| Cross-border activity | The consumer, platform, product, tax and data rules of the target country are added | Has the country-specific legal check and the need for local representation been determined? |
| Product safety | The safety obligations applicable to the product, the economic operator and the listing are reviewed. | Are the mandatory information, warning, notification and recall flow defined? |
The legal audit in the live environment is not carried out through a text file alone. The minimum areas of review are as follows:
Even if one of these areas is operated by an external service provider, the company’s legal responsibility may continue according to the contract, the role and the specific transaction. The infrastructure provider agreement, the data processing arrangement, the service level and change management are therefore added to the main compliance file.
In platform management, decision authority, legal grounds and technical implementation should be defined in advance:
If automated decisions or risk scores are used, the inputs, the possibility of error, human review and the route of objection must be explained. The system should not leave a legal characterization that requires the assessment of a real person solely to a model output.
The same platform structure can give rise to different obligations depending on the products and services sold. Sector-specific regulations are assessed together with the general e-commerce rules.
Multichannel sales, marketplace agreements, stock and price alignment, discount campaigns and consumer return processes.
Explore the retail, distribution and franchise sectorSaaS, app membership, digital content, subscription renewal, platform rules and third-party integrations.
Explore the technology, software and digital services sectorReservation platforms, commission, cancellation and payment terms. The exception to withdrawal for accommodation services for specified dates is reviewed separately.
Explore the tourism and accommodation sectorDelivery, loss and damage, carrier records, return logistics and the allocation of responsibility between the platform and the carrier.
Explore the transportation, logistics and aviation sectorTarget country rules, e-export, customs, product safety, cross-border returns and personal data transfer.
Explore the import, export and international trade sectorA manufacturer’s direct online sales, dealer relationships, accuracy of product information, traceability and the recall process.
Explore the manufacturing and industry sectorThe scope of the work and its deliverables are determined in writing after the initial assessment.
A summary of the business model, the target user, the sales channel, the revenue method, the payment/delivery flow and the current problem are determined. At first contact, the entire contract archive, customer data or panel exports are not requested.
The scope of the service is clarified as pre-launch design, review of the existing system, a specific contract, an administrative review or a dispute. The power of attorney, the project team, the form of delivery and the secure document-sharing method are determined.
The parties, contract, price, product/service, advertising, content, data and third-party providers are shown in a single workflow. The company’s statements, the live interface, the technical records and the contract version are reviewed separately.
For each obligation, the legal basis, current practice, risk, corrective action, responsible unit and completion criterion are written down. Matters affecting consumer rights or an ongoing administrative/litigation time limit are placed first. The client is presented with the priority tasks, the options that require a decision and the order of implementation.
Contracts, policies, screen texts, buttons, notifications, e-mail/SMS templates and internal procedures are tied to the same legal design. Acceptance scenarios are prepared for developers and checklists for legal and operations teams.
Membership, shopping, withdrawal, return, review, advertising, seller application and account measure are tested with sample scenarios. Updates are made as the legislation, monetary threshold, advertising rule, platform feature and third-party contract change. Progress and outstanding tasks are reported to the client at agreed intervals.
Güneş & Güneş Law Firm provides legal services from its headquarters in Antalya to companies, start-ups, platforms, sellers, providers and rights holders throughout Türkiye. On-site actions required by the file and follow-up in other cities are coordinated, as needed, with the relevant colleagues.
Güneş & Güneş Law Firm has been active since March 18, 1999 in the areas of commerce, contracts, consumer matters, disputes and international transactions. E-commerce files are reviewed not under the heading of technology alone or consumer law alone, but together with the company’s actual revenue, transaction, data, advertising and platform structure.
The legal text, the interface and operations must describe the same way of working. The consumer’s rights to information, withdrawal, return and application are assessed together with the business’s need for records, proof and continuity of service. Concluding a contract with a third party does not automatically remove a responsibility imposed directly by law.
Communication is possible in Turkish, English, German and Russian. Where necessary, coordination is arranged with the relevant authorized counsel in the country concerned for foreign regulations.
A brief summary of the activity is sufficient at first contact. We request the detailed records, limited to what is needed, once the engagement and the scope of the review have been determined.
Real customer data, card details, passwords, access keys or production system backups are not requested by ordinary e-mail. If sample records are needed for the review, personal data is reduced, anonymous or synthetic data is used where possible, and a secure sharing channel is set up. Review our approach to confidentiality and information security.
The fee is determined according to the scope of the business model, the sales channels to be reviewed, the number of contracts and records, the target countries, the stage of the administrative review or lawsuit and the work the matter requires. For advisory work, contract revision, ongoing legal support and dispute follow-up, the scope and fee are agreed in writing. Court fees, expenses, translation and third-party expert fees are explained separately.
A first response to your consultation request is given within 48 hours. This period is not the time in which the file will be concluded. For urgent or time-limited matters, please contact the firm by telephone. Submitting a form does not by itself create an attorney–client relationship; the engagement and service terms are determined separately.
Depending on the business model, terms of use/membership terms, pre-contractual information, a distance contract, a withdrawal form, privacy/cookie notices and a commercial message arrangement may be required. Instead of a ready-made package, a text suited to the product, parties, payment, delivery and return flow should be prepared.
ETHSs operating in their own electronic commerce environment, ETAHSs, and persons established in Türkiye who make cross-border sales through certain foreign platforms may fall within the scope of registration. The position of those who sell only through a domestic marketplace is assessed separately.
No. Registration shows that the relevant registration/notification obligation has been fulfilled; it is not a certificate of overall compliance in terms of consumer, contract, advertising, data, product, tax or security matters.
An ETHS is a person who engages in electronic commerce for its own goods or services. An ETAHS provides an environment for other ETHSs to engage in electronic commerce. The same company may hold both capacities in different activities.
A person selling through a domestic ETAHS may not have an ETBİS registration/notification obligation on that basis alone. The result may differ if the person has its own site or application or operates on a foreign platform.
The law, the intermediation agreement, the notice, unfair commercial practices and the specific violation are reviewed together. Situations requiring an urgent legal/security measure are not the same as ordinary termination or restriction; the reasons and the objection record are important.
The provisions on the service, commission, payment, ranking, advertising, data access, intellectual property rights, communication, restriction, termination, amendment and disputes must be clear. The mandatory provisions of the law cannot be removed by contract.
As a rule, it is fourteen days in distance contracts. There are exceptions depending on the type of goods/services; incomplete information can affect how the period applies. The specific transaction and the current regulation should be checked.
No. An exception may come into play for a service performed instantly in an electronic environment or intangible content delivered instantly; however, the type of contract, the time of performance, the pre-contractual information and the consumer’s consent are reviewed in the specific flow.
The order must be fulfilled within the time committed by the seller or provider. Except for goods prepared at the consumer’s request or according to personal needs, this period for the sale of goods cannot exceed thirty days. Handing goods over to a cargo carrier does not mean they have been delivered to the consumer.
As a rule, a fourteen-day period applies to the refund of the price upon withdrawal; the starting point is not the same in every transaction. For goods that have been delivered, the date they were handed to the carrier specified in the pre-contractual information is taken into account; where a different carrier is used, the date the goods reach the seller is taken into account. For withdrawal before delivery and for service contracts, the date of notice is the basis. The platform’s collecting and holding the price also affects its responsibility separately.
When goods are sent back with the carrier specified in the pre-contractual information, the consumer cannot be held responsible for the return costs. If no carrier is specified for the return, these costs also cannot be charged to the consumer. The use of a different carrier, the carrier not serving your location and the case of defective goods are reviewed under their own conditions; a single shipping rule does not apply to all situations.
As of August 1, 2026, the general rule is that the lowest price applied within the last ten days before the start of the discount is used as the basis. There is a special rule for perishable goods and for services; conditional campaigns may also fall within scope.
Whether the campaign is open to everyone, its condition, the presentation of the price and the perception it creates in the consumer are reviewed. Conditional sales advertisements may also fall within the scope of the current discounted sales provisions.
Where there is a benefit such as a product, discount, service or event, the advertising/promotional nature of the post must be clearly stated. The contract and the content approval process must be set up according to this requirement.
If a digital character that cannot be distinguished from a human is used, this must be clearly stated. In addition, there is a prohibition regarding advertisements that give the impression that a real person’s digital copy has experienced or recommended the product.
Targeted advertising to children by means of profiling based on personal data is prohibited. Not only the advertising text but also age/audience selection, the data source, the advertising network and the recommender system must be reviewed.
Consumer reviews taken from media where the purchase process cannot be verified cannot be published. The source of the review, the verification method and the display of different review headings must comply with the current rules.
No. Their purposes, legal bases and the consequences of refusal/withdrawal are different. Commercial message consent, the data processing condition, cookie preference and acceptance of the contract must be managed separately and in an understandable way.
Law No. 6563 and the relevant Regulation may include a prior-consent exception for merchants and tradespeople; however, the right of refusal, content, İYS and KVKK obligations continue. The recipient’s actual status and the source of the contact address must be checked.
The restrictions under Law No. 6563, competition law, the contract and KVKK are assessed together. The platform’s position, the type of data, the purpose, access and the competitive relationship with the seller are decisive.
The nature of the content is determined in terms of crime, personality rights, private life, trademark/copyright, unfair competition or consumer safety. A platform notice, a civil/criminal action, administrative routes or the current routes under Law No. 5651 are selected according to the type of event.
The DSA mainly regulates intermediary digital services; the position of a direct seller is not the same as that of a platform. Whether the service is offered in the EU, the user base, the role, the size and the exceptions in the regulation are examined case by case.
A brief summary of the business model, the website or application address, the company’s seller/platform role, the target countries and the problem to be solved are sufficient for the initial assessment. Detailed contracts, panel and user records are requested in stages after the engagement and the secure sharing method have been determined.
According to the statement of the Ministry of Trade, the ETBİS QR code practice ended as of August 2025. This does not remove the ETBİS registration and notification obligations to which the business is subject. The trust stamp is also a practice different from ETBİS registration.
Yes. Alongside the contract and consumer rights, the product’s safety, traceability, mandatory information and warnings are also reviewed. In risky product notices, removal of listings and, where necessary, recall processes, the duties of the seller, importer and marketplace are determined according to their own roles.
Consumer applications, disputes concerning defective goods and services.
Membership, seller, supplier and service agreements.
Receivables between merchants and commercial disputes.
Data processing, cookies, breaches and transfer processes.
Copyright, design, software and content rights.
Use of trademarks, counterfeit products and infringement notices.
Domain name registration, conflict with a trademark and digital trademark protection.
Campaigns, social media collaborations and content creator advertising.
Applications to remove reviews, posts and search results.
Digital business models and artificial intelligence applications.
Infrastructure, license, service level and cloud agreements.
The nature of payment activity and regulatory obligations.
Account takeover, digital fraud and criminal allegations.
Platform practices and competition reviews.
Cross-border sales and customs procedures.
Safety, conformity and recall for products sold online.
Cybersecurity Law, to the extent the file requires, is evaluated together.
This page has been prepared for general information purposes; it does not contain an assessment of a specific case or a commitment as to results. The legislation in force on the date of the transaction, the status of the parties and the scope of the file must be reviewed together. Source check date: October 4, 2026.
The official legislation index for roles, intermediation, contracts, unfair commercial practices, licensing and commercial messages.
Ministry of Trade: withdrawal, return, refund amount, carrier and platform responsibility.
Amendments concerning advertising, profiling, artificial intelligence, social media promotion and reviews as of August 1, 2026.
Announcement of July 29, 2026: ten-day price history, conditional sales and exceptions.
Scope of registration and notification; the end of the QR code practice.
The framework of Article 9 of KVKK; appropriate safeguards and standard contract mechanisms.
Cookie purposes, privacy notice, processing conditions and the preference mechanism.
Access to the regulation that entered into force on April 1, 2025 for products offered through distance communication means.
European Commission: scope and obligations of intermediary services offered to recipients in the EU.
Amendments affecting the current allocation of duties under Law No. 5651.
The provisions concerning social network and gaming platforms and their different entry-into-force dates must be assessed together.
Official texts on Law No. 6502, distance contracts, unfair terms and dispute resolution routes.
Ministry of Trade explanations on subscriptions, termination, fees and consumer applications.
You can briefly share your business model, the relevant website or application address and the matter you want assessed. Let us determine the scope of the review and the next steps in the first meeting.