An Exemption Criterion Has Been Published by the Personal Data Protection Board for Data Controllers Whose Main Activity Is the Processing of Special Categories of Personal Data Regarding the Obligation to VERBİS Registration

10/1/2025

The Personal Data Protection Board (“Board”) has updated the exemption criterion specified in its decision dated 06.07.2023 and numbered 2023/1154, which regulates exemptions from the obligation of data controllers to register with the Data Controllers’ Registry Information System (VERBİS), through its decision dated 04.09.2025 and numbered 2025/1572, published today in the Official Gazette (“Update Decision”).

With this Update Decision, data controllers whose main activity is the processing of special categories of personal data have also been included within the scope of exemption under certain conditions. Accordingly, if data controllers whose main activity is the processing of special categories of personal data employ less than 10 employees annually and their annual financial balance sheet total is less than 10 million Turkish Lira, they will be exempt from the VERBİS registration obligation. For data controllers whose principal activity does not consist of the processing of special categories of personal data, no amendments have been made; the exemption from the VERBİS registration obligation for data controllers with less than 50 employees per year or with an annual financial balance sheet total of less than 100 million Turkish Lira remains unchanged.

You can access the Update Decision published by the Board here.

Işılay Işık,Associate

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