Turkey's Draft Digital Gaming Law: What You Need to Know

Turkey is preparing its first dedicated legal framework for digital gaming platforms. A draft bill prepared by the Ministry of Family and Social Services would bring Steam, Epic Games Store, PlayStation Store, Xbox Store, and other digital game distributors under a regulatory regime modelled on the country's existing social media laws. Here is what the draft proposes, what it means, and what happens next.

What is Turkey's draft E-Gaming Law?

The draft is an amendment to Law No. 5651 (İnternet Ortamında Yapılan Yayınların Düzenlenmesi ve Bu Yayınlar Yoluyla İşlenen Suçlarla Mücadele Hakkında Kanun), Turkey's primary internet regulation statute. It would introduce a new "Supplementary Article 5" (Ek Madde 5) specifically targeting digital games distributed, played, or updated over the internet.

The bill creates two new legal categories:

• Game provider (oyun sağlayıcı): the entity that develops or publishes the game
• Game distributor (oyun dağıtıcı): the platform that distributes games to end users (Steam, Epic, PS Store, etc.)

This is Turkey's first attempt at a dedicated regulatory framework for the gaming sector. Until now, digital games have been regulated only through the general provisions of Law No. 5651 — the same statute used to block websites, social media platforms, and (infamously) Wikipedia from 2017 to 2019.

Why is Turkey regulating digital games now?

Three factors are driving the legislation:

1. Child protection concerns. The Ministry of Family and Social Services has identified digital games as a gap in Turkey's online child safety framework. While social media platforms are subject to detailed obligations under Law No. 5651 (as amended by Laws No. 7253 and 7418), gaming platforms have operated without equivalent oversight — despite being heavily used by minors.

2. The need for a legal counterpart. When Turkish authorities need to address in-game fraud, child exploitation, or consumer complaints involving foreign platforms, they currently have no local entity to contact. The representative requirement is designed to create a jurisdictional anchor, just as it did for social media companies.

3. Tax and fiscal oversight. Requiring platforms to establish legal presence in Turkey enables more effective application of the digital services tax and creates a basis for fiscal audit.

The Turkish Game Developers Association (TOGED) has noted that these discussions are not new — a gaming-specific legal framework has been debated across various government agencies for approximately a decade. The current draft represents an acceleration, not a sudden shift.

What are the main obligations under the draft law?

The draft introduces four principal obligations:

Local representative requirement

Foreign-based game distribution platforms whose daily access from Turkey exceeds a specified threshold must appoint an official representative in Turkey. If the representative is a natural person, they must be a Turkish citizen resident in Turkey. If a legal entity, the representative must be structured as a branch office.

This directly mirrors the existing social media representative requirement under Articles 4/A and 4/B of Law No. 5651, which already applies to platforms like Meta, Google, TikTok, X, LinkedIn, and Spotify.

Mandatory age rating

All games offered to users with Turkish IP addresses must carry recognised age ratings. Games without ratings would be prohibited from sale. The draft references international classification systems such as PEGI (Pan European Game Information) and ESRB (Entertainment Software Rating Board), while also contemplating consideration of "local sensitivities."

Parental control requirements

Game distributors must provide effective parental control tools covering account settings, in-game purchases, and usage time monitoring. The underlying principle is protection of children by design — platforms must build age-appropriate safeguards into their architecture, not bolt them on as an afterthought.

Rapid content removal mechanisms

Platforms must establish systems for the swift removal of illegal or harmful content. BTK (the Information and Communication Technologies Authority) would gain the power to order content modification or removal, and to request user data and technical logs on public interest or child safety grounds.

What happens if platforms don't comply?

The enforcement mechanism follows a graduated escalation model — identical to the one already applied to social media platforms:

At 90% bandwidth throttling, downloading a modern 100GB game could take months — making the sanction equivalent to a de facto access ban.

This is not hypothetical. Turkey applied the same escalation sequence to social media platforms beginning in 2020. X (formerly Twitter) was the last major holdout, but established its Istanbul representative office in May 2024 after facing advertising bans and throttling threats.

How does this compare to the current legal situation?

Currently, Turkey's only tool for addressing problematic gaming content is the general blocking mechanism under Law No. 5651. A prosecutor or judge can order complete access blocking with a single decision. Even if the platform resolves the issue, restoring access requires a new judicial decision.

This blunt mechanism has been applied to gaming platforms:

• Discord was blocked in Turkey in 2022 over child exploitation concerns
• Roblox was blocked in 2024 on similar grounds

In both cases, millions of legitimate users lost access because of content issues that, on social media platforms subject to the representative regime, would have been handled through graduated enforcement rather than outright blocking.

TOGED has made an important observation that has been largely overlooked in the public debate: the draft's graduated enforcement model may actually be preferable to the current status quo. Under the new framework, platforms would receive warnings, face escalating fines, and have opportunities to achieve compliance — rather than facing an immediate, total block at a prosecutor's discretion.

Will Steam be banned in Turkey?

Almost certainly not — at least not as a direct result of this legislation.

The most likely scenario is that major platforms (Steam, Epic, PlayStation Store, Xbox Store) will comply with the representative requirement, just as social media companies did. The cost of establishing a Turkish office is substantially lower than the revenue these platforms generate from Turkey's estimated 40 million gamers.

There is a precedent for withdrawal: PayPal exited Turkey in 2016 rather than comply with local payment licensing requirements. But PayPal's Turkish revenue was modest relative to compliance costs. For major gaming platforms, the calculation is different.

The more realistic risk is not a ban but a market that looks different: local representation, age gates on certain content, and potentially some content restrictions or removals driven by BTK enforcement.

What about independent game developers?

This is where the draft raises its most serious practical concern.

The mandatory age rating requirement could have a devastating impact on indie developers. The major international rating systems — PEGI, ESRB, and IARC (International Age Rating Coalition) — are designed primarily for commercial releases. While IARC offers a free, automated questionnaire-based rating that already interfaces with Steam, the question is whether Turkey would accept existing IARC ratings or require a separate national classification.

Industry estimates suggest that approximately 60% of Steam's catalogue consists of indie titles, many produced by solo developers or small studios without the resources for formal classification in individual markets.

If the age rating requirement is strictly enforced with Turkey-specific criteria, a majority of games on Steam could become inaccessible to Turkish users — not through intentional censorship, but through regulatory friction that small developers cannot navigate.

This is the provision most likely to be softened during the legislative process. A pragmatic approach would accept existing international ratings (PEGI, ESRB, IARC) rather than requiring Turkish-specific classification.

How does Turkey's approach compare internationally?

Turkey's draft sits at an interesting intersection of international approaches:

European Union: The EU regulates gaming platforms primarily through horizontal legislation. The Digital Services Act (DSA) imposes transparency, content moderation, and risk assessment obligations on all very large online platforms, including game distributors. Article 28 DSA specifically requires platforms to protect minors, but takes a systems-based approach (requiring platforms to implement tools and processes) rather than mandating per-game classification. The Audiovisual Media Services Directive (AVMSD) similarly requires age verification measures but leaves implementation details to platforms.

Australia: The Online Safety Act 2021 empowers the eSafety Commissioner to enforce age verification and content standards across online services, including games — a model closer to Turkey's proposed BTK enforcement powers.

China: The most prescriptive regime globally — strict playtime limits for minors (one hour per day on weekends and holidays), real-name registration, and content pre-approval by the National Press and Publication Administration.

South Korea: Abolished its controversial "shutdown law" (which banned minors from gaming between midnight and 6 AM) in 2021, shifting toward voluntary self-regulation and parental control tools.

Turkey's draft borrows the representative and escalation model from its own social media regulation (which has parallels with the DSA's local establishment rules for VLOPs), while the age rating mandate and BTK content oversight powers lean closer to the Chinese and Australian approaches.

What are the key legal concerns?

Several serious legal issues deserve attention beyond the public debate:

Data protection

The draft empowers BTK to request user data and technical log records from platforms on public interest or child safety grounds. This intersects with Turkey's Personal Data Protection Law (KVKK, Law No. 6698) and raises questions about:

• What constitutes adequate legal basis for such disclosures?
• How do cross-border data transfer rules apply when a platform's servers are in the EU (where GDPR Chapter V transfer restrictions would apply)?
• What safeguards exist against disproportionate or overbroad data requests?

Consumer rights

If platforms face 90% throttling, users who have invested thousands of dollars in digital game libraries would lose effective access to their purchases. The consumer protection implications under Turkey's Consumer Protection Law (Law No. 6502) are significant and unaddressed in the current draft. Digital purchases create ongoing contractual relationships — can a regulatory sanction against the platform extinguish the consumer's access rights?

Proportionality

Bandwidth throttling as a regulatory sanction raises fundamental proportionality questions. The Turkish Constitutional Court's landmark 2019 Wikipedia decision established that restrictions on access to online services must be proportionate to the legitimate aim pursued. A 90% bandwidth reduction — which functionally constitutes a complete ban on a download-dependent service — would face serious constitutional challenge.

Content control and "local sensitivities"

The draft's reference to "local sensitivities" in the age rating framework is vague and potentially expansive. Without precise criteria, this could enable ideological content filtering rather than evidence-based child protection. International best practice separates objective harm criteria (violence levels, explicit content, gambling mechanics) from subjective cultural judgments. The draft conflates the two.

When will this law take effect?

The draft remains in its early stages. Several steps are required before any legislation takes effect:

1. Finalisation of the draft text — ongoing negotiations between the Ministry, BTK, TOGED, and other stakeholders
2. Parliamentary submission — committee review and floor debate
3. Enactment — parliamentary vote and presidential approval
4. Implementing regulations — detailed secondary legislation by BTK (which historically takes months to years)

TOGED's 5 February 2026 statement confirmed that the draft has not yet reached a stage suitable for public consultation. Even after enactment, the implementing regulations would need to define critical details: access thresholds triggering the representative requirement, acceptable age rating systems, technical standards for parental controls, and data request procedures.

Realistically, this is a process measured in months to years, not weeks.

What should gaming platforms do now?

For platforms operating in Turkey, the prudent approach is:

• Engage early with TOGED and BTK while the draft is still being shaped. History shows that platforms that participated constructively in Turkey's social media regulation process fared better than those that resisted.
• Audit your age rating coverage — determine what percentage of your catalogue carries PEGI, ESRB, or IARC ratings and plan for potential gaps.
• Assess parental control capabilities against the draft's requirements.
• Monitor the legislative process closely — the final version will likely differ materially from the leaked draft.

What should Turkish gamers expect?

The most realistic scenario is not the loss of Steam or other platforms, but a Turkish gaming market with:

• Local platform offices handling Turkish regulatory compliance (as already exists for social media)
• Age gates on certain content categories
• Enhanced parental controls (which many platforms already offer)
• Potentially, some content restrictions on specific titles that fail to meet age rating or content standards

Whether this outcome is acceptable depends on whether the regulatory framework that emerges is genuinely focused on child protection and consumer safety, or whether it becomes another tool for content control dressed in the language of family values. That is the question worth watching as this legislation develops.