Introduction
Law No. 7578 amended Law No. 5651, prohibiting social media platforms from providing services to individuals under the age of 15 and requiring them to provide segregated services for users aged 15 to 18. These provisions will enter into force in November. The Regulation on the Provision of Age-Segregated Services for Children by Social Network Providers and on Age Verification, published in the Official Gazette on 10 October 2026, further specifies these requirements.
A) Mandatory Age Verification and the E-Government Method
Under the Regulation, age verification is mandatory for accounts created after the provisions enter into force. If this procedure is not completed, the social media platform will not accept the request to create a new account.
Since existing accounts created before the entry into force of the Regulation are also subject to the prohibition applicable to users under the age of 15, it is clear that these accounts must, in principle, also be verified. Accordingly, Article 1 (provisional) of the Regulation provides that verification for existing accounts must also be completed by 31 March 2027. Under the Regulation, this verification must be carried out through the E-Government system.
B) What Will Happen to Existing Accounts That Have Not Been Verified?
Article 1 (provisional) of the Regulation stipulates that existing social media accounts created before its entry into force must undergo verification through the E-Government system by 31 March 2027. The obligation to ensure that this verification is carried out has been imposed on social media platforms. The provision further stipulates that, where verification through the E-Government system establishes that an account is being used by a person under the age of 15, the account must be closed. However, the Regulation does not specify what will happen to accounts for which verification has not been carried out at all.
The relevant provision places the responsibility for ensuring that all accounts undergo verification by 31 March 2027 on social media platforms. Article 11 further provides that failure to fulfil this obligation will be subject to the administrative sanctions prescribed under Law No. 5651. Accordingly, social media platforms must request that their users complete the verification process in order to fulfil their legal obligations. If users nevertheless fail to complete verification following such a request, several possible scenarios may arise.
First, Article 6 of the Regulation stipulates that, even where an account has been verified, if it is established that the account is being used by a person under the age of 15, the social media platform must suspend the account and close it if verification is not subsequently completed. Since this provision, which applies to verified accounts, may a fortiori be applied to unverified accounts, it follows that if an existing account has not been verified by 31 March 2027 and suspicions arise that it is being used by a person under the age of 15, the account should be suspended and closed if verification is not completed.
Second, in the case of accounts where no such suspicion exists, social media platforms will seek to ensure that age verification is carried out by 31 March 2027 in order to fulfil the obligation imposed by Article 1 (provisional) of the Regulation and avoid the applicable sanctions. However, the Regulation does not specify what will happen if a user fails to complete age verification despite being notified. The provision establishes that social media platforms will be subject to sanctions if age verification is not carried out. Therefore, social media platforms may choose to suspend and ultimately close accounts that have not undergone age verification in order to avoid being subject to sanctions. At present, however, it does not appear possible to reach a definitive conclusion on this matter.
C) Will the State Be Able to See Users’ Account Information, and Will Platforms Be Able to See Citizens’ Personal Information During Verification?
During age verification, users’ social media usernames will not be entered into the E-Government system. Consequently, the process will not enable the State to determine who uses which social media account. Article 7 of the relevant Regulation expressly states that the E-Government system will not have access to user information held by social media platforms, and social media platforms will not have access to citizens’ personal information held by the E-Government system. Through the E-Government system, only an age verification token indicating the user’s age will be transmitted to the social media platform. Accordingly, there is no mechanism whereby usernames are automatically matched with identity information through the E-Government system.
At this point, it should be noted that, under Additional Article 4 of Law No. 5651, social media platforms are required to provide the log records necessary to identify the perpetrator in response to official requests. Therefore, when you create a social media account and complete age verification, your identity will not be matched with your username through this process, and the identity of the person using the account will not thereby become known. However, if your activities become the subject of a legal dispute, platforms cannot refuse to disclose the relevant information on the grounds that they are entitled to keep it confidential.