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Obligations Imposed Upon Influencers in Advertising and Sanctions Applicable Thereto
General Overview
Commercial advertising, the statutory details whereof are regulated comprehensively under Article 61 of the Law on Protection of Consumers (LPC, Law No. 6502), is defined as "announcements in the nature of marketing communications conducted in any medium through written, visual, audio, or derivative means by advertisers for the purpose of promoting the sale or lease of a good or service, or informing or persuading the target audience, in connection with trade, business, craft, or a profession." Under Article 62, unfair commercial practices are defined as "A commercial practice shall be deemed unfair if it fails to comply with the requirements of professional diligence and materially distorts, or is likely to materially distort, the economic behavior regarding a good or service of the average consumer whom it reaches or to whom it is directed." Furthermore, paragraph three of the same article specifies that where an unfair commercial practice is executed via advertising, Article 61 shall apply.
Influencers are classified as content providers under Law No. 5651, its derivative secondary legislation, and general principles of law, while simultaneously holding the legal status of media publishers with respect to the LPC and advertising activities.[1] Pursuant to Article 61/7 of the LPC, media publishers/influencers, alongside advertisers, are statutorily bound to comply with Article 61, as well as the provisions of derivative regulations and guidelines cross-referenced therein.
A) Fundamental Principles Governing Commercial Advertising
Article 61 of the LPC establishes that commercial advertisements must fundamentally conform to principles set forth by the Advertising Board, public morality, public order, and personal rights, while remaining truthful and honest, thereby making an indirect statutory reference to the administrative and regulatory determinations of the Advertising Board. Article 5 of the Regulation on Commercial Advertising and Unfair Commercial Practices enumerates the core principles governing advertisements as follows (which are likewise articulated under Article 61 of the statute):
a) Advertisements shall not contain expressions or imagery contrary to general principles of morality.
b) Advertisements shall not harbor qualities detrimental to public health.
c) Advertisements shall not contain elements that disrupt public order, induce, condone, encourage, or support acts of violence, unlawful conduct, or reprehensible behaviors.
d) Advertisements shall not contain expressions or imagery exploiting the sick, children, the elderly, or disabled individuals.
e) Advertisements shall not contain disparagement, exploitation, prejudice, or discrimination based on language, race, color, gender, political thought, philosophical belief, religion, sect, or analogous characteristics.
f) Advertisements shall not be conducted in a manner infringing upon human dignity and personal rights.
g) Advertisements shall not contain expressions or imagery concerning a person's private or social life without prior authorization; shall not reference that person; and shall not depict or state a person's private property in a manner creating the impression of personal endorsement for the relevant product or organization.
h) Advertisements shall not exploit consumers' fears or superstitious beliefs.
i) Advertisements shall not contain expressions or imagery depicting patients prior to and following medical treatment.
j) Advertisements shall not contain expressions or imagery concerning illness, injury, or derivative conditions in a manner causing public anxiety or deception.
k) Advertisements shall not contain any presentation or description ignoring safety rules or presenting situations that could pose safety hazards.
Detailed regulations regarding the requirement of truthful and honest advertising are codified under Article 7 of the Regulation. Pursuant to the relevant provisions, advertisements must be prepared with a sense of economic and social responsibility and in a manner avoiding unfair competition; prepared taking into account the perception level of the average consumer and the probable impact of the advertisement upon the consumer; and shall not abuse the consumer's trust or exploit their lack of experience and knowledge. Furthermore, advertisements shall not contain expressions or imagery capable of directly or indirectly misleading consumers on any matter, foremost including: features of the good such as its nature, composition, supply, utility, risk, accessories, manufacturing method and date, fitness for purpose, manner of use, shelf life, scope of application, technical specifications, yield and performance, quantity, origin, or environmental impact; attributes of the service; commercial title, trade name, status, and scope of authority of the person or entity offering the good or service; value and actual total price payable for the good or service; other payment terms such as hire-purchase, leasing, installment sales, or credit sales; conditions governing delivery, exchange, repossession, warranty, post-sales services, spare parts, or maintenance and repair; intellectual and industrial property rights; official recognition, authorization, medals, awards, diplomas, and derivative credentials; charitable contributions; or statutory rights or potential risks facing consumers.
Mandatory permits, authorizations, approvals, or registration certificates required for a good or service pursuant to relevant legislation cannot be utilized in advertisements to create the impression that the good or service is distinct from or superior to competitors. Statutory consumer rights cannot be presented in advertisements as if they constitute supplementary privileges granted to consumers. Regarding elements contained in advertisements: a) Citations from research findings or scientific publications shall not be distorted. b) Statistics shall not be presented in a manner producing results divergent from reality. c) Scientific terminology shall not be utilized misleadingly. d) Claims shall not contain scientific terminology or phrasing presenting them as possessing a scientific foundation that they lack in fact.
B) General Statutory Obligations
Following the framework principles, detailed general rules and obligations are codified across the legislation:
First and foremost, advertisements must be executed in a manner rendered clearly recognizable as such. Pursuant to Article 6 of the Regulation, an advertisement must be explicitly identifiable as an advertisement, irrespective of its form or the medium in which it is published. (Advertisements deploying electronic devices or derivative tools producing images of extremely short duration, or structured in a format imperceptible or unrecognizable to viewers so as to achieve subliminal perception, are prohibited. Advertisements must be visually and audibly distinguishable from editorial content. Where a title, logo, set, or music identified with a text, broadcast, or program published in any medium is deployed in an advertisement, the commercial nature of the message must be easily recognizable by consumers. Where visual or sound effects identified with news broadcasts or public service announcements are deployed in an advertisement, the commercial nature of the message must be easily recognizable by consumers.)
Under Article 61 of the LPC and Article 22 of the Regulation, "surreptitious advertising" (cover/hidden advertising)—which constitutes a substantial portion of online advertising activities and has reached manipulative proportions—is strictly prohibited. Pursuant to the relevant article, the inclusion of names, brands, logos, or other distinctive signs or expressions, alongside commercial titles or trade names associated with goods or services, within texts, news items, broadcasts, or programs without explicitly designating them as advertising, presented in a promotional manner for advertising purposes, constitutes surreptitious advertising. Surreptitious advertising via audio, written, or visual means across all communication channels is strictly prohibited.
Article 23 of the Regulation sets forth a series of criteria for evaluating surreptitious advertising. Pursuant to these provisions, in evaluating texts, news, broadcasts, and programs containing information and imagery regarding names, brands, logos, or other distinctive signs, trade names, or corporate representatives: a) The information and imagery regarding names, brands, logos, trade names, or representatives must remain harmonious, unexaggerated, and proportionate relative to the format, subject, content, presentation, positioning, and duration of the text, news, broadcast, or program; b) Texts, news, broadcasts, or programs published within the framework of the right to inform, disseminate, and receive information must satisfy the consumer's need for enlightenment and information; c) Specific promotional references encouraging the lease or purchase of goods or services in a manner intentionally steering consumer preferences must be absent. In texts, news, broadcasts, and programs aimed at informing consumers by testing products or within tourism, folklore, and urban documentaries, elements such as signage or posters cannot be highlighted excessively, nor can detailed contact information be included. In urban spaces, street scenes, interviews, and venues hosting news-worthy sporting, cultural, or artistic events, signage or posters containing names, brands, logos, or commercial titles cannot be depicted in an exaggerated manner.
Detailed provisions governing comparative advertising are set forth in the statute and regulation. Pursuant to Article 61 of the LPC, comparative advertising comparing competing goods or services satisfying the same needs or intended for the same purpose is permissible. However, advertisers bear the burden of proving the veracity of claims made in their commercial advertisements. (Article 9 of the Regulation details the burden of proof.) Article 8 of the Regulation dictates that comparative advertisements are permissible strictly under the conditions that: a) Competitors' product names, brands, logos, trade names, or other distinctive elements are omitted; b) They are not deceptive or misleading; c) They do not induce unfair competition; d) The compared goods or services satisfy identical needs or target identical purposes; e) They compare matters providing utility to the consumer; f) They objectively compare one or more material, essential, verifiable, and typical features of the compared goods or services, including price; g) Claims grounded in objective, measurable, numerical data are proven via scientific tests, reports, or documentation; h) They do not disparage or discredit competitors' goods, services, activities, or other attributes; i) Comparisons regarding goods or services with designated geographical origins involve products originating from the identical geographic location; j) They do not induce confusion regarding the advertiser's and competitor's brand, trade name, business name, or other distinctive marks, goods, or services; k) They conform to principles established by the Advertising Board. In food advertisements, matters falling under health claims pursuant to relevant legislation cannot form the subject of comparison. Utilizing matters under nutrition claims as comparative elements in advertisements must conform to relevant legislative provisions. Comparative advertising of dietary supplements is strictly prohibited under all circumstances. Regarding sectors where price regulations and significant market power obligations are defined by competent administrative authorities, price comparisons in advertisements are legally precluded.
Deceptive advertisements are prohibited under Article 61 of the LPC. Pursuant to the relevant norm, advertisements deceiving consumers or exploiting their lack of experience and knowledge cannot be conducted. Article 29 of the Regulation enumerates deceptive actions within unfair commercial practices—which may likewise be executed via advertisements—as follows:
(1) Commercial practices containing false information, or which, even if the information presented is factually accurate, deceive or are likely to deceive the average consumer when evaluated in light of all circumstances of presentation, thereby causing or harboring the potential to cause the consumer to enter into a legal transaction that they would not have entered into under normal conditions, are deemed deceptive.
(2) Actions deceiving or likely to deceive consumers regarding the following matters are evaluated as deceptive actions:
a) The existence, nature, supply, utility, risk, application, composition, accessories, post-sales services, manufacturing method and date, performance, fitness for purpose, quantity, technical specifications, origin, expected results of use, results of tests and controls conducted, environmental impacts, and other material features of a good or service;
b) The scope of commitments by the commercial actor, nature of the marketing process, sponsorship support, or statements and symbols indicating approval of the good or service by competent authorities;
c) The price, price calculation methodology, payment terms, or specific price advantages of a good or service;
d) Statutory rights possessed by the consumer or potential risks;
e) Services, spare parts, exchange, or repair services regarding a good or service;
f) Attributes, qualifications, titles, and other rights of the commercial actor or representative, such as identity, assets, capabilities, status, institutional memberships, commercial rights, intellectual and industrial property rights, or awards and honors conferred by competent authorities.
(3) A commercial practice is deemed deceptive if it materially distorts or harbors the potential to materially distort the economic behavior of the average consumer and incorporates the following possibilities:
a) Inducing confusion with a competitor's good, service, brand, or other distinctive attribute; b) Failure by the commercial actor to fulfill obligations codified within rules of conduct established by professional chambers or analogous organizations to which they belong regarding the relevant operational domain or commercial practice.
Article 30 of the Regulation enumerates deceptive omissions as follows: (1) Where a commercial actor conceals material information in a proposal directed to a consumer to establish a legal relationship, presents the proposal unintelligibly or at an inappropriate time, or fails to inform the consumer of the purpose of an obviously intentional commercial practice, thereby causing or harboring the potential to cause an average consumer to enter into a legal transaction that they would not have entered into under normal conditions, the existence of a deceptive omission is established. (2) Where required information cannot be conveyed due to temporal or spatial limitations of the communication medium utilized to transmit commercial conditions to the consumer, the evaluation of whether a deceptive omission exists is conducted taking into account those limitations and the measures adopted by the commercial actor to deliver the information to consumers via alternative means.
Article 11 of the Regulation mandates that advertisements shall not unfairly exploit the reputation of others. Accordingly, the name, emblem, logo, or derivative distinctive corporate identity elements of a person, institution, or organization cannot be deployed in a manner misleading consumers. Furthermore, no person or entity may unfairly benefit from the name of another, a trade name belonging to a firm or institution, intellectual and industrial property rights, or reputation accrued through an advertising campaign.
Pursuant to Article 12 of the Regulation, advertisements cannot imitate the text, slogan, visual presentation, music, sound effects, or derivative elements of another advertisement in a manner misleading consumers or inducing confusion. A good or service cannot be presented in advertisements as an imitation or copy of another good or service possessing a protected brand or trade name.
Obligations concerning advertisements containing price information are regulated under Article 13 of the Regulation; obligations regarding discounted sales advertisements under Article 14; obligations concerning lotteries, contests, and promotional advertisements under Article 15; obligations regarding testimonial advertisements under Article 16; and obligations concerning environmental claims under Article 17. Aggressive commercial practices are prohibited under Article 31, while disparaging others in advertisements is codified as a prohibited act under Article 10.
Detailed regulations governing how visuals, written text, and audio statements must be incorporated into advertisements are set forth under Articles 18, 19, 20, and 21 of the Regulation.
Specific obligations regarding children in advertisements are regulated under Articles 24 and 24/A of the Regulation; core obligations regarding financial service advertisements under Article 25; and Article 26 dictates: "Advertisements for goods or services subject to specialized advertising regulations—such as pharmaceuticals, human medicinal products, medical devices, healthcare services, foods, dietary supplements, cosmetic and cleaning products, tobacco products, and alcoholic beverages—must additionally conform to relevant provisions governing advertising and promotion in their specific legislation." Article 27 sets forth core obligations regarding direct sales and tele-shopping advertisements under "other matters," establishing that timeshare or long-term holiday services cannot be promoted as investment instruments (excluding timeshare property contracts), and that advertisements for services offered by fortune-tellers, mediums, astrologers, alongside illegal gambling and betting advertisements, are strictly prohibited under all circumstances.
C) Specific Obligations Imposed Upon Social Media Influencers
Pursuant to Article 12 of the Guideline on Commercial Advertising and Unfair Commercial Practices by Social Media Influencers, influencers are held legally accountable for the provisions of the Guideline. Under Article 5/1 of the Guideline, influencers are strictly prohibited from engaging in surreptitious advertising. Article 5/2 mandates that in posts where financial gain and/or benefits such as free or discounted goods or services are provided by an advertiser, this commercial advertising relationship must be explicitly disclosed using at least one of the expressions specified under Articles 7, 8, 9, and 10 of the Guideline, depending on the platform where the post is executed. Article 5/3 dictates that when fulfilling this mandatory disclosure, the tags and statements utilized pursuant to Articles 7, 8, 9, and 10 must be:
a) Distinguishable from colors and background media utilized within the post and displayed in an easily readable font size;
b) Positioned and presented in a manner ensuring that consumers comprehend the post as a commercial advertisement upon initial encounter without requiring supplementary actions (such as clicking);
c) Displayed visibly among other tags or explanations where multiple disclosures are incorporated;
d) Presented in a manner instantly discernible at first glance by consumers, taking into account the interface and technical specifications of the platform.
Article 6/1-f dictates that where an influencer deploys effects or filtering applications in a commercial advertisement for any good, they must explicitly state that the imagery has been filtered.
Article 6 of the Guideline regulates that an influencer shall not:
a) Share posts for commercial advertising purposes regarding a good or service they have not yet experienced in a manner endorsing or creating the perception of having experienced said good or service;
b) Make health claims regarding a good or service in violation of relevant legislation;
c) Assert claims regarding scientific research and test results that are non-objective, unmeasurable, ungrounded in numerical data, and incapable of proof;
d) Direct consumers to or promote goods or services offered by medical doctors, dentists, veterinarians, pharmacists, or healthcare institutions;
e) Create the impression that a good or service gifted by an advertiser was purchased by themselves;
f) Create the impression of acting merely as an ordinary consumer during the period in which financial gain or benefits (such as free or discounted goods/services) are received from an advertiser regarding the commercial advertisement of a good or service;
g) Systematically generate and/or deploy fake or non-existent identities en masse to communicate about a good or service via social media.
The specific tags and statements codified under Articles 7, 8, 9, and 10—at least one of which must be incorporated into the internet content or caption by the influencer when executing commercial advertising—are as follows:
Advertisements Executed on Video Sharing Platforms (ARTICLE 7) – In advertisements executed on video sharing platforms such as YouTube and Instagram TV, or within live streams, at least one of the following written and oral disclosures must be incorporated continuously throughout the video, within the video title, in the description box, or at the beginning of the relevant advertising segment, without compelling consumers to click fields such as "read more":
"This video contains advertisements for [Advertiser]." – "This video contains a paid partnership with [Advertiser]." – "With the support of [Advertiser]." – "I received these products as a gift from [Advertiser]." – "Thanks to [Advertiser] for sending these products."
Advertisements Executed on Photo and Message Sharing Platforms (ARTICLE 8) – In photos or messages shared on platforms such as Instagram, Facebook, and Twitter, or within captions thereof, at least one of the following tags or explanations must be incorporated alongside identifying information such as the name, brand, or trade title of the advertiser:
#Ad (#Reklam) – #Advertisement/Promotion (#Reklam/Tanıtım) – #Sponsor – #Partnership (#İşbirliği) – #Collaboration (#Ortaklık) – "In partnership with @[Advertiser]" – "Provided by @[Advertiser]" – "Received as a gift from @[Advertiser]"
Advertisements Executed on Podcast Platforms (ARTICLE 9) – In advertisements executed via podcasts, at least one of the following written and oral disclosures must be incorporated at the beginning, middle, and conclusion of the broadcast:
"This podcast contains advertising regarding [Advertiser]." – "This podcast consists of a paid collaboration with [Advertiser]." – "With the support of [Advertiser]." – "I received the products (mentioned in my podcast) as a gift from [Advertiser]."
Advertisements Executed on Ephemeral Content Platforms (ARTICLE 10) – In advertisements where content remains visible strictly for a short duration, such as Snapchat and Instagram Stories, at least one of the following tags or explanations must be incorporated throughout the display duration alongside identifying information regarding the advertiser:
#Ad (#Reklam) – #Advertisement/Promotion (#Reklam/Tanıtım) – #Sponsor – #Partnership (#İşbirliği) – #Collaboration (#Ortaklık) – "In partnership with @[Advertiser]" – "Provided by @[Advertiser]" – "Received as a gift from @[Advertiser]"
D) Statutory Sanctions
1) Sanctions for Advertisements Breaching Core Principles and Obligations (LPC)
Pursuant to Article 77/12 of the LPC, an influencer acting in breach of Article 61 (and derivative secondary legislation cross-referenced thereunder) may be subjected to an order for the suspension of the advertisement, correction via identical methods, administrative fines, and, where deemed necessary, a temporary suspension order for up to three months. The Advertising Board may impose these sanctions cumulatively or individually based on the nature of the infringement. Where the non-compliance occurs via the internet, an administrative fine of 114,326 TRY may be imposed pursuant to the Communiqué on Administrative Fines Applied in 2021 under Article 77 of Law No. 6502. However, where the administrative infringement is repeated within one year, the Advertising Board may increase the administrative fine up to tenfold. Thus, an online content provider executing commercial advertising may face an administrative fine of up to 1,143,260 TRY in cases of recidivism.
Sanction determinations of this nature are rendered by the Advertising Board constituted under Article 63 of the LPC, and the execution of the Board's sanction orders is carried out by the Ministry of Customs and Trade.
a) Illustrative Precedents
a.1. File No: 2020/5183
Respondent: Merve BOLUĞUR
Subject Advertisement: Advertisements and promotions published on the individual's personal Instagram account "mervebolugur" regarding the product designated "Fable Slim Tea."
Publication Date: August 2020
Medium: Internet
Factual Findings: At the Advertising Board's meeting No. 304 dated 08.12.2020, an administrative fine of 104,781 TRY alongside a suspension order was imposed upon Erol ÜLKER pursuant to Articles 63 and 77/12 of Law No. 6502 regarding advertisements for dietary supplements designated "Fable Tea Amaranth Seed Mixed Herbal Tea" and "Fable Tea Amaranth Seed Mixed Herbal Capsule" published across websites www.fablesiparis.net and
Evaluation/Judgment: Upon investigation, advertisements published on the individual's Instagram account in August 2020 regarding "Fable Tea Amaranth Seed Mixed Herbal Tea" incorporated phrasing creating the impression that the product assists in weight loss and eliminates edema. Furthermore, a perception was generated among followers that the individual actually utilized the product and derived health benefits therefrom.
The statements in the subject advertisements constitute health claims. Through such statements, the dietary supplement product was promoted as if it were a pharmaceutical or human medicinal product by generating the impression that it slims users, maintains body form, assists in weight loss, and eliminates edema. Under prevailing legislation, utilizing health claims for dietary supplements is strictly prohibited. Making any health claim regarding a product mandates prior authorization from the competent administrative authority (Turkish Pharmaceuticals and Medical Devices Agency of the Ministry of Health). Because no authorization was obtained from the competent authority for these statements, their veracity cannot be deemed scientifically proven; thus, consumers were deceived and misled through scientifically unproven assertions.
Furthermore, the advertisements generated a false perception that the product was genuinely utilized and its claimed efficacy personally experienced, which did not reflect reality—rendering the advertisements deceptive, misleading, and contrary to provisions governing "Testimonial Advertisements" in the Regulation on Commercial Advertising and Unfair Commercial Practices.
Additionally, because these promotional posts failed to explicitly disclose their commercial nature, provisions governing "Surreptitious Advertising" in advertising legislation were likewise infringed.
Consequently, the subject promotions were found non-compliant with:
Article 24/3 of Law No. 5996 on Veterinary Services, Plant Health, Food and Feed;
Articles 5/a, 5/b, 5/c, 5/ç, and 5/d of the Regulation on Health Claims of Products Offered for Sale with Health Claims;
Article 7 of the Turkish Food Codex Regulation on Food Labeling and Consumer Information;
Articles 5/1, 5/2, 8/2, 9/1, 9/2, 13/1, and 13/2 of the Turkish Food Codex Regulation on Nutrition and Health Claims;
Articles 5/1-b, 6/1, 7/1, 7/2, 7/3, 7/4, 7/5-a, 9, 16/1, 22/1, 26, and 32 of the Regulation on Commercial Advertising and Unfair Commercial Practices;
Article 61 of Law No. 6502 on the Protection of Consumers.
Accordingly, an administrative fine of 104,781 TRY alongside an order for the suspension of the subject advertisements was imposed upon advertiser Merve BOLUĞUR pursuant to Articles 63 and 77/12 of Law No. 6502.
a.2. File No: 2021/723
Respondent: Meryem CAN
Subject Advertisement: Videos published on the individual's YouTube account titled "I tested viral photo hacks 2" and "Detecting liars with a lost phone ad."
Publication Date: 24.12.2020
Medium: Internet
Factual Findings: In the video titled "I tested viral photo hacks 2," photographs were taken featuring the "Huawei P40 Pro" smartphone, accompanied by statements such as: "Normally, guys, it's not really possible to take these kinds of poses, these kinds of photos with a cell phone, but because the Huawei P40 Pro offers shutter settings in Pro mode, you can take these photos," and "We had to shoot in a very dark environment. Normally, shooting in such dark environments with an ordinary cell phone camera is not easy, in fact it's impossible. But with the P40 Pro's low light mode, as you can see, we were able to take vivid, quite clear photos like this."
Evaluation/Judgment: Upon investigation, the advertisement promoted the "Huawei" brand phone by emphasizing camera quality—claiming that unlike other phones, it takes vivid, clear photos even in the dark, transfers photos to a computer "with just one touch/button," and zooms clearly at 50.0x—thereby advertising the brand. However, despite an existing advertising contract with the firm, no disclosure regarding the commercial partnership was incorporated into the video, failing to render the commercial nature of the content recognizable and constituting surreptitious advertising for the "Huawei" brand without required advertising disclosures.
Furthermore, in the video titled "Detecting liars with a lost phone ad," imagery of a "Huawei" smartphone, headphones, and smartwatch were featured alongside explanations of watch features—such as stress tests and music pairing—without incorporating advertising disclosures, thereby executing surreptitious advertising for the "Huawei" brand.
Consequently, the subject promotions were found non-compliant with:
Articles 6, 7/1, 7/2, 7/3, 7/4, 7/5, 22, 23, and 32 of the Regulation on Commercial Advertising and Unfair Commercial Practices;
Article 61 of Law No. 6502 on the Protection of Consumers.
Accordingly, an order for the suspension of the subject advertisements was imposed upon media publisher Meryem CAN pursuant to Articles 63 and 77/12 of Law No. 6502.
2) Sanctions Where Advertising Constitutes Unfair Competition (TCC)
The Turkish Commercial Code (TCC) contains specific provisions governing defendant status and civil liability regarding online publications.[2] Where statutory requirements under the TCC are satisfied, civil litigation originating from unfair competition—including claims for pecuniary and non-pecuniary damages—may be instituted directly against influencers.
Article 62/1-a of the TCC additionally codifies a penal norm linked to unfair competition. Pursuant thereto: "Any person who intentionally commits one of the acts of unfair competition specified under Article 55 shall... unless the act constitutes an offense requiring a heavier penalty, be punished with imprisonment for up to two years or a judicial fine upon complaint by any person entitled to file a civil action pursuant to Article 56, for each act falling within the scope of the relevant paragraph."
Atty. Alp Öztekin, LL.M.
