How to Set Up an Airline Ticket Sales Agency: TÜRSAB, IATA and Legal Requirements

Which legislation applies to establishing an airline ticket sales agency in Türkiye?

The basic regulations for establishing a travel agency that commercially makes reservations and sells tickets in Türkiye for the flights of other airline operators are Law No. 1618 on Travel Agencies and the Association of Travel Agencies and the Travel Agencies Regulation. An operating license must be obtained from the Ministry and TÜRSAB membership must be completed. Tax registration, registration with the trade registry, setting up a website or entering into a contract with a ticket supplier does not replace these establishment steps. Article 5 of the Regulation lists reservation and ticket sales relating to air transport vehicles among the services specific to travel agencies. [1] [2]

The general administrative route of the application runs through the Ministry of Culture and Tourism and TÜRSAB. That only airline tickets will be sold is not a general rule requiring an establishment application to the SHGM for every new agency. Opening a workplace at an airport or carrying out a different aviation activity must be assessed separately. An airline operator’s direct sale of its own product, within the regulations to which it is subject, is likewise not the same legal situation as an independent travel agency selling the tickets of other operators; the distinction in Article 6 of the Regulation must be borne in mind. [2] [3] [4]

For this reason, one should not start only with the question “which ticketing system will I use?” On whose behalf the sale will be made, which company will assume responsibility towards the customer, which services will be offered and where the workplace will be located should be determined together. The activity license required under public law and the commercial authority for ticket supply are different matters.

How should Groups A, B and C be assessed for airline ticket sales?

The agency group determines the services the business may carry out. This choice should not be made on application cost alone. If hotel reservations, transfers, tours or package tours are to be offered alongside airline tickets, the whole activity model must be assessed. [1] [2]

The basis of the table is Article 3 of Law No. 1618, Article 7 of the Regulation and the Ministry’s explanation of the groups. [1] [2] [5]

Why does the word “international” in Group B matter?

The wording of the Law and the Regulation is not the same: while Article 3 of the Law refers to tickets of international transport vehicles for Group B, Article 7 of the Regulation uses a more general definition of reservation and sale. It should not be concluded from the Regulation’s provision that the statutory limit has disappeared. In particular, for a venture that will sell only domestic flight tickets or will carry out domestic and international sales together, the suitability of Group B for the specific model should be clarified in writing with the Ministry and TÜRSAB before the application. [1] [2] [5]

Group B and C agencies may perform the service provided by a Group A agency and market its products. However, this assignment must be documented in writing or by contract. Organizing the whole of a tour or package tour belonging to Group A by Group B or C is not within the scope of this possibility of authorization. Entering into a contract does not by itself widen the license group. [2] [5]

Who may apply; what should be considered in establishing the company?

A new travel agency operating license is granted to a legal entity. The Ministry’s explanation on title applications also states that only legal entities may apply. The tax registration of a sole-proprietor business opened in the name of a natural person does not meet this requirement. In projects structured through a limited liability or joint-stock company, the establishment of the company and the licensing of the agency are carried out as separate stages. The legal-entity condition in the legislation also does not mean that all company types may be accepted as equally suitable without assessment. [6] [3]

The object of activity in the articles of association must include tourism or travel agency business; the persons who will represent the company and the application address must appear current in the trade registry documents. It is important for the healthy progress of the file that a person authorized on behalf of the company signs the application, that the company’s correct title is used in bank payments and that the addresses in the documents match one another. [2] [3] [4]

The establishment of the company does not remove the personal requirements sought of managers. The age, certain convictions, commercial reputation and other relevant conditions in Article 8 of the Law are examined separately. As regards the application documents, an identity and criminal record declaration is provided for board members and representatives in joint-stock companies, and for managers and representatives in limited liability companies. This current application arrangement for limited liability companies should not be confused with the document list in older texts that covers all shareholders. The scope of the declaration and the substantive eligibility conditions are assessed separately. [1] [2] [7] [8]

What are the workplace and staff requirements?

The workplace must actually be suitable

TÜRSAB inspects the suitability of the workplace and the staff records at the address given in the application. The Ministry may also inspect when it considers it necessary. Therefore, merely giving an address or submitting a lease does not mean that the workplace meets all the establishment conditions. [2]

According to Article 17 of the Regulation, the workplace must be in a place that those wishing to receive services can reach freely and on equal terms, a sign showing the agency’s title must be visible from outside, and it must be arranged in a size suited to the activities of the chosen group. Electronic communication equipment suited to carrying out transactions by telephone, fax and the internet is also listed in the provision. The workplace should not be planned as a space in which other activities incompatible with the agency services permitted by the legislation are carried out together. [2]

Instead of a single minimum number of square meters valid for all agencies, the legislation contains a size criterion suited to the activity and location. Where more than one travel agency is located in the same independent unit, each must have a sufficient, clearly separated area in which it can carry out its independent activity. This provision does not mean that any shared office or virtual office service is automatically accepted as suitable; the actual arrangement must meet the inspection criteria. [2] [8]

Aiming at sales over the internet does not by itself remove the requirement of a licensed workplace. The second paragraph of Article 17 of the Regulation treats online sales as tied to the workplace for which an operating license has been issued. Therefore planning for the workplace should be done together with investments in software and sales channels. [2] [8]

At least one qualified staff member must be employed

At the head office and at each branch, staff holding at least one of the qualifications specified in Article 35 of the Regulation are employed. A vocational high school, associate degree or bachelor’s degree in hotel management and tourism; an information officer foreign-language certificate of achievement; or a guide certificate issued by the Ministry falls within this scope. In Group C, the information officer certificate of achievement is sufficient; a separate foreign-language certificate is not required for this option. [9]

The agency owner, if they hold the required qualification and actually work in the agency, may be counted as staff in their own agency. Merely being a shareholder in the company or attaching someone’s diploma to the file does not replace the requirement of actual work. The SGK documents showing the employment relationship of the staff and the related declarations are assessed together in the application file. Changes of staff must be notified to TÜRSAB within thirty days at the latest; the qualified-staff condition is maintained after the license is obtained. [2] [7] [9]

How is the title application made, and when does the thirty-day period begin?

At the first stage, an application is made to the Ministry for a travel agency title. The company’s trade name and the agency title to be used serve different functions. That a domain name has been obtained or a trademark registered does not replace the Ministry’s finding the agency title suitable. For titles that cause confusion with existing agencies, the restrictions in Article 5 of the Law must also be taken into account. [1] [2] [3]

The requested titles are indicated in order of preference in the application. According to the Ministry’s explanation, once a title in the sequence is found suitable, the later options are not considered. The petition, the title request information, the company’s trade registry documents and the application annexes published by the Ministry are prepared; if there is one, the name registration certificate is also attached. The current application explanation provides for the documents to be delivered to the Ministry by hand or by post. The application and delivery records must be kept. [3]

According to the process explanation published by the Ministry, the petition must state the request clearly; it must contain the name, surname, signature and title of the person authorized to represent the legal entity, as well as the telephone, fax, full address, the date of application and the company stamp. The date of application also matters for querying the title request on the tracking screen. In the printed petition used for a new establishment, the legal entity’s trade name is written in the “agency title” field; since there is not yet an operating license, the license number field is left blank. The requested agency titles may in addition be shown in order of preference on the title request form or in the petition. These are the Ministry’s explanations on the use of the current form; the current form should be used in the application. [3]

That the title has been found suitable is notified to the applicant and to TÜRSAB. The thirty-day period for applying to TÜRSAB runs from the notification of the suitability decision to the applicant. The date of the decision within the Ministry and the date of notification to the applicant should not be treated as the same. The notification document is part of the file and of the time-limit tracking. Because starting preparations on company documents, the workplace and staff after title approval may strain the period, it is useful to complete these preparations beforehand. [2] [3] [7]

Which documents are in the TÜRSAB application file?

The document list should be prepared by examining together the current regulation and the forms and explanations published by the institution receiving the application. The main groups of documents are below. [2] [4] [7]

The trade registry certificate should not be thought of as a document that merely shows the company’s trade name. In the explanation published by TÜRSAB, the MERSİS number, trade name, head office and, if any, branch address, field of activity, capital and the persons with authority of representation at the time the document was issued are among the information in the certificate. It should be checked that these fields in the file reflect the company’s latest status and agree with the application documents. This explanation concerns the checking of the current registry certificate; it does not create additional new document items under different names. [7]

The formal requirements of documents that must be originals or certified copies should be observed. In certain cases the Regulation allows a copy to be certified by the official concerned upon presentation of the original. Therefore it should not be assumed that every document must necessarily be separately taken for notarization; the current method of acceptance should be checked document by document. [2]

Why do the legislation and the application list differ on the specimen signature circular?

With the amendment dated April 7, 2021, subparagraph 9/1-e of the Regulation, on the specimen signature circular among the new establishment documents, was repealed; and the same wording relating to the documents sent to the Ministry was also removed from the text of Article 18. By contrast, the accessible application explanations of the Ministry and TÜRSAB continue to request the specimen signature circular. [10] [3] [7]

Because of this difference, it is not correct to present the specimen signature circular as an unchanging requirement of the legislation relying on a repealed subparagraph. In preparing the file, the unit accepting the application should be asked by which document or registry record authority of representation and signature will be verified. In this way both the current regulation is taken into account and any notice of deficiency that could arise from the published list of procedures is clarified in advance.

How do the review, workplace inspection and licensing proceed?

TÜRSAB first reviews the file, assesses the accuracy of the declarations and inspects the workplace. Once conformity is established, the membership registration fee and the annual dues are requested in writing. In the current process published by TÜRSAB, there is also attendance at an information meeting for newly established agencies by the representatives of the applicant who has performed the payment obligation. [2] [7]

The Association forwards its assessment to the Ministry. The Ministry reviews the file, asks for any deficiency to be completed and, if it considers it necessary, carries out a separate inspection. On a positive assessment, the approval of the authority and the transactions for drawing up the operating license are carried out. The license is sent to the relevant Provincial Directorate of Culture and Tourism to be delivered to the applicant. [2] [4] [7]

Can an agency be established in exactly thirty days?

The thirty days provided for an application made upon notification of the title is a period the applicant must observe. The period for completing deficiencies is likewise thirty days. TÜRSAB’s explanation of the period for completing its review and sending the file to the Ministry concerns another stage of the process. These cannot be put together to conclude that “everything from the establishment of the company to the start of sales is completed in exactly thirty days.” [2] [7]

In planning, the title assessment, notification, recruitment of staff, workplace inspection, deficiencies, payment, the meeting and Ministry licensing should be tracked separately. The opening date should not be committed to customers as definite based solely on the day the application documents were delivered.

What are the establishment fee, annual dues and security for 2026?

The amounts below are based on official institutional announcements published for 2026. The current announcement, the request letter and the account details should be checked separately at the time of payment. It should be borne in mind that the amounts are collected for different purposes. [4] [11] [12]

TL 44,000 should not be counted twice in the budget, once as the title application fee and once as the new operating license fee. The payment record should be matched in the file by evaluating the Ministry’s application and fee explanations together. The arithmetic total of the TÜRSAB establishment fee, the annual dues and the Ministry license fee is TL 725,742.94. This total is not the entire establishment cost of the business. The costs of company formation, capital, rent, equipment, staff, software, accounting and commercial supply relationships are planned separately. [3] [4] [11] [12]

For example, on the assumption that the security for Group A is provided in cash, these three payments together with the TL 7,000 security come to TL 732,742.94. This calculation shows only the total of the items stated; it is not a comprehensive investment budget or profitability calculation. If the security is met by a bank letter, the cash outflow and bank costs differ.

How is the establishment security provided; what changes for a branch?

For the security values to be accepted, the Regulation refers to Article 34 of Law No. 4734. The letter of guarantee must be firm and unlimited in time, and must correctly state the agency title and the company’s trade name. Cash security must be paid from the company’s account; according to the Ministry’s explanation, security payments made from a personal account are not accepted. The establishment security is a guarantee given for the obligations under the public regulation; it should not be merged with the security that a commercial supplier may separately request. [2] [13]

For each branch, 25 percent of the head office group’s security is required: TL 1,750 for Group A, TL 1,500 for Group B and TL 1,250 for Group C. In addition, in the 2026 announcement the branch establishment fee is TL 649,278.98, and the Ministry’s branch permit license fee is TL 44,000 for each branch. That a license has been obtained for the head office does not remove the branch establishment procedures and the workplace-staff conditions specific to the branch. [11] [12] [14]

If the security later falls short, the missing amount must be made up within thirty days of the Ministry’s notification. This obligation rules out the idea that the initial establishment security is provided once and need not be monitored afterwards. [2]

What routes may be followed if the application is incomplete or unsuccessful?

Failure to apply to TÜRSAB within the period after the notice of title suitability, failure to complete notified deficiencies within thirty days, or submitting documents and declarations contrary to the facts may lead to the application being removed from the active docket. The process in Article 20 of the Regulation is also observed for deficiencies returned from the Ministry’s review. Being unable to complete a document in time and submitting a document contrary to the facts are not the same situation; in the second case a criminal complaint is additionally provided for. [2]

If TÜRSAB rejects the application, it must state the reasons. Under Article 19 of the Regulation, the applicant may file an objection with the Ministry within ten days of notification. In the objection, the grounds for rejection, the documents in the file and the deficiencies alleged to have been remedied must be explained concretely. This ten-day period is the special route for TÜRSAB’s rejection; it does not mean that the application or litigation periods against all of the Ministry’s acts are the same. As regards the final act, the legal route is determined by separately examining the act and the notification. [2]

Is everything paid refunded?

Under Article 12 of the Regulation, if an application that TÜRSAB found suitable and sent to the Ministry is not found suitable by the Ministry, the membership is cancelled and the membership registration fee is refunded by TÜRSAB. A refund is also provided for the establishment security where the application is not found suitable by the Ministry. However, these provisions do not mean that, in every case of withdrawal or removal from the docket, dues, the Ministry fee and special service costs can all be automatically recovered. Each item must be assessed on the basis of its collection basis and the outcome of the application. [2] [7]

Cancellation or withdrawal after the license is obtained is different. Under Article 31 of the Regulation, the establishment security is held for one year; if there is no situation requiring set-off, it is refunded at the end of the period. For this reason it is not sound to treat the security as a definite expense at the time of payment and as freely available cash that can be recovered immediately on closure. [2]

When a refund of cash security is requested, an application is made to the Ministry by petition. The bank receipt, the match between the entitled person and the applicant, and the match of the tax number and bank account details must be checked. If the person making the application and the entitled person differ, the representation must be documented. The arising of the right to a refund and the documents required for the refund to be completed are separate matters. [15]

Is IATA accreditation mandatory for airline ticket sales?

In setting up an airline ticket sales agency, the operating license, IATA accreditation, the airline’s ticketing authority and the sales system used must be assessed separately. The basis of travel agency activity in Türkiye is the Ministry operating license suited to the relevant group and TÜRSAB membership. IATA accreditation does not replace this public-law status. Conversely, an operating license alone does not provide the possibility of directly issuing the tickets of every airline. [16][17]

How to choose between GoLite and GoStandard?

IATA’s GoLite and GoStandard models are aimed at the agency’s differing needs, particularly as regards its payment and financial risk structure. GoLite is an accreditation model offered with simpler participation conditions. GoStandard allows wider use of standard payment solutions. In choosing, one should look not only at the application fee but also at the collection method, working capital, expected sales volume and the refund burden. [18]

Under GoLite there is no access to BSP Cash; IATA EasyPay and the permitted card methods become important. GoStandard may, if the relevant conditions are met, also cover the use of BSP Cash. “Cash” here does not mean that the customer must pay in banknotes; it describes the payment method in which the agency remits sales proceeds to the BSP in the prescribed order. EasyPay, in turn, is based on a pre-funded electronic wallet. [19]

It would not be correct to say that “under GoLite no security is requested under any circumstances.” The minimum financial security facility in IATA’s general promotion is different from the guarantee obligation that may arise because of a specific risk. The current Resolution 812 regulates the possibilities of financial security in respect of card transactions and ADM risk even in accreditation without a cash facility. The current criteria applicable to Türkiye and the agreement submitted in the application should be examined together. [17]

Why are the BSP and the airline’s ticketing authority different?

The BSP — Billing and Settlement Plan standardizes sales reporting, payment remittance and settlement between participating airlines and IATA-accredited agencies. It is not an operating permit or an unlimited sales permission for every airline. [20]

Ticketing authority is the authority an airline gives an agency so that it can issue tickets in the airline’s name. In IATA Resolution 812, the airline’s appointment and ticketing authority are separately regulated; the airline may grant or withdraw the authority. For this reason an entrepreneur should not invest on the assumption that “once I get an IATA number, I can open all airlines for sale immediately.” The target airlines, the payment methods to be used and the conditions under which the authority may be suspended should be determined from the outset. [17]

Can a NON-IATA sub-agency and consolidator model be used?

A business that has no IATA accreditation of its own but holds the required travel agency status may operate under a contractual model in which it obtains tickets through an authorized main agency. In the sector, consolidator is used for an intermediary business that meets demand from different sales channels with its own agreements and ticketing infrastructure. This commercial designation is not a separate permit that replaces the operating license in Turkish law.

TÜRSAB’s statement addressed to IATA and NON-IATA members expressly addresses the practice in which IATA agencies give NON-IATA sub-agencies online sales access. The same statement warns against making this access available to persons and workplaces without an operating license. Therefore a sub-agency arrangement cannot be designed as a method of carrying out unlicensed activity by using another’s license. The main agency’s granting of access does not remove the sub-agency’s own legal obligations. [21]

This model may reduce some initial accreditation and infrastructure burdens; on the other hand, it creates dependence on the main agency in pricing, commission, credit limit, refund period and system access. The choice should not be made only on the basis of the initial establishment cost. Who will complete the change and refund transactions of existing passengers if the main agency’s activity or access stops should be settled in the contract.

What does a TIDS code provide?

TIDS — Travel Industry Designator Service is an IATA identification program that enables travel sellers to be recognized in reservation systems. According to IATA’s explanation, TIDS does not give the right to issue tickets through the BSP. That the Ministry license is requested in applications from Türkiye also shows that TIDS is not an alternative to national authorization. A TIDS code, IATA accreditation and an airline’s sales authority are not the same concepts. [22]

What should be considered when choosing GDS and NDC infrastructure?

A GDS — Global Distribution System is a distribution system that serves the agency in accessing airline content and in managing reservations and tickets. Having a GDS account does not show that the business using the account has completed all its commercial and legal authorizations. [23]

NDC — New Distribution Capability is an IATA data standard that improves the transmission of offer, order and related service information between airlines and sales channels. IATA states that the standard is also open to the use of third parties and of businesses that are not IATA members. It cannot be concluded from this technical openness that anyone can sell airline tickets without a license. An NDC connection works together with an appropriate business status and a sales contract. [24]

In entering into a technology contract, one should not merely try out the price search and the first ticketing screen. Through which channel name corrections, itinerary changes, partial use, flight cancellations, extra baggage and refund processes are to be carried out should be examined. The speed of the first sale does not mean that after-sales transactions can also be completed in the same system. Particularly for transactions that must be transferred to another system, additional fees, support period and transaction authority must be clear.

In a practical assessment, the system’s training needs, support outside working hours, the ability to obtain transaction records and access to continuing reservations when the contract ends should be addressed together. In this way the choice of software ceases to be merely a technical purchasing decision; the enforceability of the service promise the agency makes to its customer is also assessed.

Which risks should be regulated in main agency and airline contracts?

The headings below are not a statutory standard list that must be present with the same content in every contract. They guide the commercial and legal risk assessment of a contract prepared according to the sales model. Airline rules, the distribution system’s terms and the agreement between agencies should be consistent with one another.

Collection, commission and deposit

Separating the ticket price from the service fee

The contract should explain who receives the money from the customer, into whose account the payment passes, how the ticket price is separated from the agency service fee and when the parties pay each other. The gross sales amount is not the same as income the agency can use freely. On which records reconciliation will be made, and who will bear exchange-rate differences and payment institution deductions, should also be determined.

Use and refund of the deposit

For a deposit or advance payment made to the main agency, the purpose of use, limit increases, top-up calls, set-off conditions and the refund schedule at the end of the contract should be written out. This amount should not be confused with the establishment security provided for the Ministry or with the financial security assessed under IATA. Keeping large balances with a single supplier may affect both new sales and customers’ pending transactions if access is cut off. For this reason, access to daily balance and transaction reports should be backed by contractual assurance.

Refunds, changes and ADM

Managing the passenger’s refund request

In the refund process, it should be determined who will receive the request, who will forward it to the airline, how the amount received will be transferred to the customer and what will happen to the service fee. Voluntary cancellation, cancellation of the flight by the airline and the agency’s erroneous transaction should not be concluded under the same heading. The payment term between agencies does not replace the mandatory rules applicable to the passenger.

Objection to a debit record and set-off

ADM — Agency Debit Memo is a debit record that the airline directs to the agency. This record, which may be encountered for reasons such as the application of a wrong fee or rule, may under the parties’ contract be sought to be passed on to the sub-agency as well. [19] The contract should regulate which type of transaction is under whose control, the forwarding of the supporting document, by whom and when the objection will be made, and whether the disputed amount can be automatically set off. An approach that provides for the unquestioning acceptance of an amount for which no reasons and no transaction history are shown creates a serious risk of dispute.

Chargeback, system access and termination of the contract

Chargeback refers to the payment process in which the recovery of the price comes into question because of an objection relating to a card transaction. On which side the risk remains should be examined according to the arrangements among the business collecting the card payment, the airline, the payment institution and the main agency. Relying only on a clause that “all loss belongs to the sub-agency,” without determining customer verification, transaction evidence, notification period and responsibility for preparing defense documents, does not provide adequate risk management.

The definition of user accounts by staff member, the limiting of access authorizations, the closing of the account when an employee leaves and the process to be applied in a suspicious transaction should also be regulated. A single shared password makes it harder to prove who carried out a transaction. After termination, a separate transition plan should be set up for continuing service to customers, transferring records, closing refund balances and the protection of personal data. If the business works with a foreign supplier, the applicable law, competent authority and notification arrangement should also be assessed separately.

Which legal distinctions matter in selling airline tickets online?

Opening a website and ETBİS registration are not the same thing

Selling tickets over the internet, which constitutes travel agency activity, does not remove the need for an operating license suited to the activity. A website, a mobile application and a supplier screen are sales channels; that the channel works technically does not prove that the person operating it holds the necessary authorization. [16]

As regards ETBİS, the generalization that “every business visible on the internet must register” is not correct. The Ministry’s explanations set out registration models for those selling in their own electronic commerce environment, those providing intermediation and, under certain conditions, businesses in Türkiye selling on a foreign platform. Sales only on a domestic marketplace, a site used solely for promotion and contracts concluded exclusively through individual means of communication are not assessed within the same scope. [25]

In addition, Article 1/3 of Law No. 6563 does not treat those authorized under Law No. 1618 and operating exclusively within the scope of that authorization as an electronic commerce service provider or an electronic commerce intermediary service provider for the purposes of applying the Law. This provision should not be read as a general exemption removing all electronic commerce obligations. [26] The scope of the ETBİS Communiqué itself, where and by whom the sale is made, whether the activities are limited to authorized agency business only, and the Ministry’s practice must be assessed together. In particular, an automatic exemption should not be assumed for models with mixed activities or that provide a sales environment for different businesses. ETBİS registration also does not replace the travel agency operating license. [25][27]

Is there an automatic fourteen-day right of withdrawal for an airline ticket?

Article 2/2-h of the Distance Contracts Regulation leaves passenger transport services outside the scope of the Regulation, subject to certain obligations. Therefore, merely on the basis that the ticket was bought over the internet, it cannot be said that every airline ticket carries an unconditional fourteen-day right of withdrawal. [28]

However, the obligations to provide information on the essential characteristics of the service, the identifying information of the relevant provider and intermediary, and the total price including taxes are reserved. The rules requiring express consent for additional payments and that the ordinary tariff not be exceeded in telephone communication relating to the contract are also preserved. On the sales screen, flight information, baggage and fare class conditions, the total payment and any separately charged service fee must be displayed in an understandable way. [28]

This scope exception does not remove all of the consumer’s rights arising from Law No. 6502. Unfair contract terms, defective service and the passenger rights applicable to the specific case are assessed separately. [29] Where the agency sells a separate consultancy or other service, the legal nature of that service should be examined separately; the passenger transport exception should not extend automatically to all additional services.

How should ticket notifications and campaign messages be separated?

Notifications relating to reservation, collection and performance of the purchased service should not be managed in the same process as campaign messages. The commercial communications legislation regulates the cases in which no prior consent is sought for certain transaction notifications; this possibility cannot be used by adding advertising. Adding a new holiday campaign to a message about a change in flight time requires the message to be assessed separately. [30]

For campaign SMS, e-mail and calls, applicable consent, İYS registration and refusal processes should be set up. The Ministry explains the obligation to record consent and refusal notifications forwarded to the service provider in the İYS within three business days. [31] The will to buy a ticket, marketing consent and the condition for processing personal data are separate matters. A sales flow should not be designed that forces the customer to give unnecessary marketing consent in order to buy a ticket.

How should ticket, passport and reservation data be protected?

In ticket sales, names, contact details, the travel program and, where necessary, passport details are processed. The purpose and legal basis must be determined for each piece of information collected. Processing necessary for the conclusion or performance of the contract and processing for marketing purposes are assessed differently. Obtaining explicit consent collectively for every processing operation does not justify collecting data that is not needed. [32]

For example, that a passport number is necessary in a particular transaction does not by itself make it necessary to keep all pages of the passport continuously. The amount of data, access authorizations and the retention period should be set proportionately to the transaction. This is the application of the data minimization principle to ticket sales. [33] The privacy notice given to the customer must explain the data controller, the purposes of processing, the groups to which data is transferred, the legal bases and the rights of application. A privacy notice and explicit consent do not serve the same function. [34]

Transfer to a foreign airline, GDS and cloud service

The transfer of data to a foreign airline, to reservation infrastructure abroad or to a cloud service is assessed separately under Article 9 of the KVKK. The possibility of access from abroad to data held in Türkiye may also fall within the transfer review. In the current system, a distinction is made among an adequacy decision, appropriate safeguards and exceptions specific to incidental cases. It is not correct to regard a continuous international reservation flow as resolved by a general “I accept the transfer abroad” box alone. [35]

If the standard contract method is to be used, the roles of the parties as data controller or data processor must be correctly determined, the appropriate type of contract must be chosen and the five-business-day notification obligation from the completion of the signatures must be fulfilled. Not every supplier can automatically be regarded as a data processor. [35] In the commercial contract, data security, access, sub-service providers, breach notification, return and deletion of records should be addressed. This contractual arrangement does not remove the need to set up the required transfer mechanism separately.

If a sales office is to be opened at an airport, what should be examined with respect to the SHGM?

A ticket sales agency operating in the city or online and the opening of a workplace inside an airport should not be subjected to the same permit assessment. In the SHGM’s current list of legislation, there is a separate workplace opening and operating license regime under SHY-33B for terminals and health-related workplaces at airports open to civil air transport. [36]

For this reason, if a sales counter or office is planned inside an airport, whether the place and the activity fall within this regulation, the contract to be entered into with the airport operator and the relevant permit process should be examined before the investment. If ground services or another regulated aviation activity will be undertaken in addition to ticket sales, the authorization conditions for that activity are also assessed separately. Both the statement “all airline ticket agencies obtain an SHGM license” and the statement “the SHGM has no role at any stage” overlook the distinction between specific activities.

When may ticket sales begin?

Travel agency status is acquired through TÜRSAB membership and the Ministry’s operating license; agency activity begins after the operating license is obtained. Membership becomes final upon the Ministry’s issuing the license, and the year in which the license was issued is taken as the basis in determining the dues. Title approval, a favorable workplace inspection or a supplier contract alone does not create authority to start sales. [2] [7]

After licensing as well, the workplace and staff conditions must be maintained, the operating license must be kept in a visible place and changes must be notified by the relevant procedure. Agency activity should not be moved to a new address without waiting for the outcome of the address-change request. The completion of establishment is not limited to the permit conditions being met only on the first day; the business’s subsequent activities must also be carried out within the license group and the continuing compliance obligations. [2]

Which checks should be completed from establishment to the first sale?

In practice, the file, the workplace and the ticketing infrastructure may be prepared by different people. For this reason, it is useful before opening for a single responsible person to check the latest position together. The sequence below is not a statutory provision or a fixed completion period; it is a practical plan that can be used to follow the obligations explained above.

1. Put the activity model in writing. Determine the options: domestic and international, tickets only or additional travel services, physical office or online channel, direct airline relationship or sub-agency.
2. Match the company and the permit file. Ensure consistency among the trade name, authority of representation, object of activity, address, staff and agency group.
3. Document the start of the application periods. Keep the notification of title approval, notices of deficiency, delivery records and payment documents in date order.
4. Check the license and the ticketing authority separately. Obtaining the operating license does not mean that the commercial authority required for the relevant airline’s ticket has also been obtained. Verify that both are complete.
5. Test after-sales transactions. Without using real passenger data, check the price, baggage, service fee, change and refund flows in an authorized test environment. Make sure that a trial reservation does not create a real collection or ticket.
6. Complete the contract and data flow. The information to be given to the customer, the main agency contract, the collection arrangement, marketing consents and the personal data processing arrangement must complement one another.
7. Designate the person responsible after activity begins. Record who will monitor refund requests, payment reconciliation, user authorizations, staff changes and time-limited notifications.

This approach makes visible that completing the application documents and the business being in working order towards customers are different needs. In planning the establishment investment, working capital should be set aside not only for one-off fees but also for ongoing staff, software, rent and customer service costs.

Conclusion

Setting up an airline ticket sales agency requires choosing an appropriate company and agency group, completing the Ministry and TÜRSAB application, meeting the workplace-staff conditions and establishing the ticketing model by contract. The operating license, IATA accreditation, the airline’s ticketing authority and software access serve different functions. This distinction makes it possible to determine correctly both the establishment cost and the responsibility to be assumed towards the customer.

In preparing the application budget, the fees announced for 2026 should be matched with current payment records; the establishment security and commercial deposits should be tracked separately. If sales will be made over the internet, informing the consumer, commercial messages, data security and transfer of data abroad should be addressed as part of the sales flow. Examining the documents, supplier contracts and application periods together for the specific business model reduces disputes over authority and responsibility that may arise after establishment.

Frequently Asked Questions

Are TÜRSAB and an operating license needed even to sell only airline tickets?

The model of commercially selling the tickets of other airlines as a travel agency is assessed through the appropriate Ministry operating license and TÜRSAB membership. Selling only tickets, forming a company or obtaining a software account does not remove this framework. An airline’s direct sale of its own transport service is assessed differently. [1] [2]

Can an airline ticket sales agency be opened as a sole-proprietor business?

There is a legal-entity requirement for a new operating license. A sole-proprietor business opened in the name of a natural person does not meet this condition on its own. The company type, object of activity and representation structure should be determined together with the application model before establishment. [6] [3]

Can Group B sell every kind of domestic and international ticket?

It is not correct to widen the scope unconditionally on this point. The word “international” in the Law’s definition of Group B and the Regulation’s more general wording must be assessed together. For a domestic-only or mixed sales model, it is advisable to obtain a written explanation from the Ministry and TÜRSAB before the application. [1] [2] [5]

Who should sign the petition for the agency title?

The application is made in the name of the legal entity; the petition must contain the information and signature of the person authorized to represent the company, the company stamp and the other information the Ministry requests. If the file is pursued through a representative, the authority of representation must be separately documented. The order of title requests must be determined deliberately. [3]

Within how long after title approval must TÜRSAB be applied to?

The application is made within thirty days from the notification of suitability to the applicant. In calculating the period, it is not sufficient to look only at the date on which the decision was drawn up; the delivery or notification record of the notice must be kept. [2] [3] [7]

Can an agency without an IATA certificate sell airline tickets?

A business holding the required travel agency status may operate under a contractual ticket supply model through an authorized main agency or consolidator. Lacking IATA accreditation is not the same as lacking an operating license. Giving a sales password to a business without a license is not an appropriate solution. [21]

Does IATA accreditation automatically provide ticketing authority with all airlines?

No. The airline’s appointment of the agency and its ticketing authority are assessed separately. The relevant airlines, payment methods and the limits of the authority should be checked separately from the accreditation process. [17]

Can a ticket be issued through the BSP with a TIDS code?

According to IATA’s explanation, TIDS does not give the right to issue tickets through the BSP. This code, which serves to identify the travel seller, does not replace accreditation or the national operating license. [22]

Which official fees should be in the 2026 establishment budget?

The TÜRSAB establishment fee is announced as TL 649,278.98, the annual dues as TL 32,463.96 and the Ministry fee for a new operating license as TL 44,000. Their total is TL 725,742.94. The establishment security and other expenses such as the company, office, staff and software are not included in this total. Current institutional announcements should be checked at the time of payment. [3] [4] [11] [12]

What is the difference between security and dues?

Dues are an annual payment arising from membership. The establishment security, in turn, is a guarantee provided for the obligations specified in the legislation; when its conditions are met, a refund or set-off may come into question. The commercial/financial guarantees requested by the main agency or IATA are also separate from the establishment security. [2] [4] [17]

Can an agency be set up with a home or virtual office address?

The name of an address type alone is not sufficient. The actual workplace must meet the access, sign, suitable area, equipment, activity and staff requirements and must pass inspection. Selling only online does not by itself remove the requirement that activity be tied to a licensed workplace. [2] [8]

Can one withdraw free of charge within fourteen days from every airline ticket bought online?

No. Passenger transport services are regulated outside the scope of the Distance Contracts Regulation, subject to certain provisions on information and payment. In assessing cancellation or refund, the ticket conditions, whether the flight took place, consumer provisions and the relevant passenger rights are examined together. [28] [29]

Can ticket sales begin once registered with ETBİS?

ETBİS does not replace the travel agency operating license or the airline’s ticketing authority. The registration obligation is also determined by assessing together the sales channel, the business’s role, the scope of activity and the relevant legislation; no automatic obligation or automatic exemption can be concluded for all agencies. [25] [26] [27]

If the application is rejected, is everything paid refunded?

There is no single, automatic refund rule for every fee. For an application the Ministry does not find suitable, the provisions on the membership registration fee and the establishment security are examined separately. Annual dues, the Ministry fee and special service payments are assessed on the basis of their own collection basis and the outcome of the application. [2] [7]

Does the ten-day period against TÜRSAB’s rejection decision apply to all acts?

No. The ten-day period in Article 19 of the Regulation concerns an objection to be filed with the Ministry from the notification of TÜRSAB’s rejection decision. The Ministry’s final act, the route of litigation and the other periods are assessed separately. The decisions of different authorities should not be gathered under a single period. [2]

Is a separate permit needed to open a ticket office at an airport?

The activity and location of an office or sales counter inside an airport are examined separately with respect to the workplace license regime under SHY-33B and the airport operator’s conditions. It cannot be assumed that every ticket sales agency in the city is subject to the same license process. [36]

Sources

Date on which the sources were checked online: October 25, 2026.

1 — TÜRSAB (text of the law) — Law No. 1618 on Travel Agencies and the Association of Travel Agencies (1618 sayılı Seyahat Acentaları ve Seyahat Acentaları Birliği Kanunu). Assessed together with the establishment provisions, the relevant amending texts and current institutional explanations.

2 — TÜRSAB (text of the regulation) — Travel Agencies Regulation (Seyahat Acentaları Yönetmeliği). The text of the Regulation was read together with the 2021 amendments and current procedural explanations.

3 — Ministry of Culture and Tourism, General Directorate of Investment and Enterprises — Travel Agency Title Request (for Newly Established Travel Agencies) (Seyahat Acentası Unvan Talebi (Yeni Kurulacak Seyahat Acentaları İçin)).

4 — Ministry of Culture and Tourism, General Directorate of Investment and Enterprises — Travel Agency Operating License Request (Seyahat Acentası İşletme Belgesi Talebi).

5 — Ministry of Culture and Tourism, General Directorate of Investment and Enterprises — Travel Agency (Seyahat Acentası).

6 — Ministry of Culture and Tourism, Inspection Board — Amendment of Art. 4/3 of Law No. 1618 by Law No. 7244 (7244 sayılı Kanun ile 1618 sayılı Kanun m.4/3 değişikliği).

7 — Association of Turkish Travel Agencies (TÜRSAB) — New Operating License Application (Yeni İşletme Belgesi Başvurusu).

8 — Association of Turkish Travel Agencies (TÜRSAB) — Regulation Amending the Travel Agencies Regulation Published, with Old/New Comparison Text (Seyahat Acentaları Yönetmeliğinde Değişiklik Yapan Yönetmelik Yayınlandı ve Eski/Yeni karşılaştırma metni).

9 — Ministry of Culture and Tourism, General Directorate of Investment and Enterprises — Travel Agency Staff Change Request (This Request Is Made Through TÜRSAB) (Seyahat Acentası Personel Değişikliği Talebi (Bu Talep TÜRSAB Aracılığıyla Yapılır)).

10 — Ministry of Culture and Tourism, Inspection Board — Regulation Amending the Travel Agencies Regulation (Seyahat Acentaları Yönetmeliğinde Değişiklik Yapılmasına Dair Yönetmelik).

11 — Association of Turkish Travel Agencies (TÜRSAB) — Announcement on the 2026 Annual Dues and Travel Agency and Branch Establishment Fee Amounts (2026 Yılına İlişkin Yıllık Aidat, Seyahat Acentası ve Şube Kuruluş Ödentisi Miktarları Hakkında Duyuru).

12 — Ministry of Culture and Tourism, Kars Provincial Directorate of Culture and Tourism — Travel Agency License Fees and Bank Details (Seyahat Acenta Belge Ücretleri ve Banka Bilgileri).

13 — Ministry of Culture and Tourism, General Directorate of Investment and Enterprises — Agency Security Change Request (Acentanın Teminat Değişikliği Talebi).

14 — Ministry of Culture and Tourism, General Directorate of Investment and Enterprises — Branch Establishment Request (Şube Kuruluş Talebi).

15 — Ministry of Culture and Tourism, General Directorate of Investment and Enterprises — Cash Security Refund Transactions (Nakit Teminat İade İşlemleri).

16 — Republic of Türkiye Ministry of Culture and Tourism, Inspection Board Presidency — Travel Agencies Regulation (Seyahat Acentaları Yönetmeliği).

17 — IATA — IATA Passenger Agency Conference Resolution 812, Edition 46 Update 1.

18 — IATA — Travel Agent Accreditation.

19 — IATA — Airline Payment Framework — Annex Pack.

20 — IATA — Billing and Settlement Plan (BSP).

21 — Association of Turkish Travel Agencies (TÜRSAB) — Attention, Our IATA and NON IATA Members (Sayın IATA ve NON IATA Üyelerimizin Dikkatine).

22 — IATA — TIDS — Frequently Asked Questions.

23 — IATA — Airline Retailing — An industry vision for Offers and Orders.

24 — IATA — Distribution with Offers & Orders (NDC).

25 — Ministry of Trade — Electronic Commerce — Frequently Asked Questions (Elektronik Ticaret — Sıkça Sorulan Sorular).

26 — Grand National Assembly of Türkiye — Law No. 7416 Amending the Law on the Regulation of Electronic Commerce (7416 sayılı Elektronik Ticaretin Düzenlenmesi Hakkında Kanunda Değişiklik Yapılmasına Dair Kanun).

27 — Ministry of Trade, ETBİS — ETBİS Registration — E-Commerce Academy (ETBİS Kayıt — E-Ticaret Akademisi).

28 — Ministry of Trade, Adana Provincial Trade Directorate — Distance Contracts Regulation (Mesafeli Sözleşmeler Yönetmeliği).

29 — Ministry of Trade, General Directorate of Consumer Protection and Market Surveillance — Law No. 6502 on Consumer Protection (6502 sayılı Tüketicinin Korunması Hakkında Kanun).

30 — Ministry of Trade, Kayseri Provincial Trade Directorate — Regulation on Commercial Communications and Commercial Electronic Messages (Ticari İletişim ve Ticari Elektronik İletiler Hakkında Yönetmelik).

31 — Ministry of Trade — Press Release on Integrator Authorization (Entegratörlük Yetkisi Basın Açıklaması).

32 — Personal Data Protection Authority — Public Announcement on the WhatsApp Application (WhatsApp Uygulaması Hakkında Kamuoyu Duyurusu).

33 — Personal Data Protection Authority — Processing/Transferring Personal Data Beyond What the Purpose of Processing Requires — Violation of the Data Minimization Principle (İşlenme Amacının Gerektirdiğinden Fazla Kişisel Veri İşlenmesi/Aktarılması — Veri Minimizasyonu İlkesine Aykırılık).

34 — Personal Data Protection Authority — Public Announcement on Fulfilling the Obligation to Inform (Aydınlatma Yükümlülüğünün Yerine Getirilmesi Hakkında Kamuoyu Duyurusu).

35 — Personal Data Protection Authority — Guide on the Transfer of Personal Data Abroad (Kişisel Verilerin Yurt Dışına Aktarılması Rehberi).

36 — General Directorate of Civil Aviation — Sectoral Regulations — SHY-33B and SHY-22 (Sektörel Yönetmelikler — SHY-33B ve SHY-22). The SHGM legislation index for the existence of the airport license regime; specific permit conditions are examined separately.