Administrative Monetary Fines under Law No. 6698 on the Protection of Personal Data: Current Risks and Compliance Assesment

The administrative monetary fines announced by the Personal Data Protection Authority for 2026 have been increased by applying a revaluation rate of 25.49% compared to 2025. This increase has significantly amplified the economic impact of the sanctions that may be imposed in the event of violations of personal data protection obligations.
 

Main Areas of Violation Carrying High Risk
 

As of 2026, non-compliance with the following obligations may give rise to substantial administrative monetary fines:
 

• Failure to fulfil the information obligation, either entirely or in accordance with the prescribed procedures,
• Failure to implement the necessary technical and administrative measures to ensure the security of personal data,
• Failure to comply with the decisions of the Personal Data Protection Board within the prescribed time limits,
• Acting in violation of the registration and notification obligations with the Data Controllers' Registry (VERBİS),
• Failure to submit notifications regarding standard contractual clauses within the required time limits.

In particular, in cases involving violations of data security obligations or non-compliance with the decisions of the Board, the upper limit of the administrative monetary fines prescribed for 2026 reaches TRY 17,092,242.
 

Comparative Assessment for the 2025-2026 Period;
 

The administrative monetary fines determined for 2026 have been established by applying a 25.49% increase to all minimum and maximum thresholds that were applicable in 2025. The categories of violations set out below are among those most frequently subject to sanctions in the Authority's practice and represent the highest financial risk for companies.

In the event of failure to fulfil the information obligation:
 

• 2025: TRY 68,083 - TRY 1,362,021
• 2026: TRY 85,437 - TRY 1,709,200

In the event of a breach of obligations relating to data security:
 

• 2025: TRY 204,285 - TRY 13,620,402
• 2026: TRY 256,357 - TRY 17,092,242

In the event of failure to comply with the decisions of the Personal Data Protection Board:
 

• 2025: TRY 340,476 - TRY 13,620,402
• 2026: TRY 427,263 - TRY 17,092,242
   

In the event of non-compliance with the registration and notification obligations with the Data Controllers' Registry (VERBİS):
 

• 2025: TRY 272,380 - TRY 13,620,402
• 2026: TRY 341,809 - TRY 17,092,242

In the event of failure to submit notifications regarding standard contractual clauses within the prescribed time limits:
 

• 2025: TRY 71,965 - TRY 1,439,300
• 2026: TRY 90,308 - TRY 1,806,177
   

These figures clearly demonstrate that the Authority addresses violations of personal data protection obligations within the framework of an increasingly deterrent sanctions policy.
 

Key Risks Highlighted in Light of the Authority's Practice
 

An analysis of the Authority's decisions and enforcement practice indicates that the most frequently sanctioned violations primarily include incomplete or merely formalistic privacy notices, inadequate technical and administrative data security measures, failure to comply with VERBİS obligations, and data transfer processes that are not conducted in accordance with procedural requirements.
 

In this context, it is of critical importance not only to maintain written documentation, but also to effectively integrate KVKK compliance into operational processes, enhance employee awareness, and regularly update internal procedures in line with the decisions of the Personal Data Protection Board.
 

Conclusion and Assessment
 

The administrative monetary fines determined for 2026 and increased by a revaluation rate of 25.49% clearly demonstrate that compliance with the KVKK cannot be regarded as a deferrable or secondary matter. Any lack of compliance may result not only in the risk of administrative monetary fines, but also in reputational damage, disruption of business operations, and an increase in legal disputes.
 

In this context, it is of paramount importance for companies to reassess their existing KVKK compliance frameworks by taking into account the updated penalty amounts applicable for 2026, to update their risk analyses, and to adopt a proactive compliance approach. In line with these considerations, it is recommended that companies prioritise a review of their current status, particularly with respect to data security measures, the alignment of privacy notices with actual processing activities, and compliance with VERBİS obligations.