Turkey's Rules for Influencer Advertising: An Overview of the Advertisement Board's Guideline

Social media influencers have become one of the most powerful marketing channels in Turkey, and the regulator has taken notice. The Guideline on Commercial Advertising and Unfair Commercial Practices by Social Media Influencers, adopted by the Turkish Advertisement Board (Reklam Kurulu) at its meeting no. 309 dated 4 May 2021, sets out how influencer marketing must be conducted so that consumers can always tell paid promotion apart from genuine personal content.

Purpose, Scope and Legal Basis

The Guideline is designed to steer advertisers, advertising agencies, media organizations and everyone else involved in advertising through influencer campaigns. It applies to all consumer-facing commercial advertisements and commercial practices carried out by social media influencers. Its legal foundation lies in Articles 61, 62, 63 and 84 of the Consumer Protection Law No. 6502 and in the Regulation on Commercial Advertising and Unfair Commercial Practices.

A "social media influencer" is defined broadly as any person who engages in marketing communication through a social media account with the aim of selling or renting goods or services belonging to themselves or an advertiser, or of informing or persuading a target audience. This wide definition means the rules reach not only celebrity influencers but essentially anyone who monetizes their social presence.

The Core Principle: No Hidden Advertising

The central rule is simple. Advertising conducted through influencers must be expressed clearly and be distinguishable as advertising. Covert advertising in audio, written or visual form is prohibited on social media just as it is in any other medium.

Whenever an influencer receives a benefit from an advertiser — money, free products, discounts or similar advantages — the commercial relationship must be openly disclosed using at least one of the statements prescribed for the relevant platform. The disclosure labels themselves must meet strict presentation standards. They must stand out against the colors and background of the post, be large enough to read easily, be noticeable at first glance without the consumer having to take any additional action, and remain visible even when placed among other hashtags or captions. The interface and technical features of each platform must be taken into account so that the commercial nature of the post is apparent the moment the consumer encounters it.

Direct Obligations of Influencers

Article 6 imposes a set of personal prohibitions on influencers themselves. An influencer may not promote a product or service they have not actually experienced in a way that creates the impression of endorsement or first-hand use. Health claims that would breach sector-specific legislation are forbidden, as are claims about scientific research or test results that are not objective, measurable, numerically supported and provable.

Influencers are also barred from promoting or steering consumers toward goods and services offered by doctors, dentists, veterinarians, pharmacists and health institutions — a notable restriction in a market where wellness and aesthetic content is widespread. Further, an influencer cannot create the impression of having purchased a product that was in fact gifted by the advertiser, and cannot pose as an ordinary consumer for as long as they are receiving benefits from the advertiser in connection with that product. If effects or filters are applied to images in an advertisement for a product, the fact that the image has been filtered must be stated clearly. Finally, the systematic creation or bulk use of fake or non-existent identities to communicate about a product or service is prohibited — a rule aimed at bot accounts and fake engagement.

Platform-Specific Disclosure Requirements
The Guideline tailors its disclosure mechanics to four categories of media.

Video platforms. On services such as YouTube and Instagram TV, and in live streams, the disclosure must appear continuously within the video, in its title or description, or at the start of the segment containing the advertisement — and it must be visible without the viewer having to click "read more". Acceptable statements include wording such as "This video contains advertising for [advertiser]" or "This video contains a paid collaboration with [advertiser]".

Photo and message platforms. On Instagram, Facebook, Twitter and similar services, the post or its caption must include identifying information about the advertiser (name, brand or trade name) together with at least one prescribed label, such as #Reklam (advertisement), #Sponsor, #İşbirliği (collaboration), #Ortaklık (partnership) or phrases like "provided by @[advertiser]" or "received as a gift from @[advertiser]".

Podcasts. Advertisements in podcasts must be disclosed in written and spoken form at the beginning, middle and end of the broadcast, using statements analogous to those for video.

Ephemeral content. For formats that are visible only briefly, such as Snapchat and Instagram Stories, the advertiser's identifying information and one of the prescribed labels must be displayed for the entire duration of the post.

The Advertiser Cannot Hide Behind the Influencer

Article 11 places substantial duties on advertisers. They must inform influencers about the Guideline, require compliance with the Consumer Protection Law, the Regulation and the Guideline itself, extend that requirement to any third parties the influencer is permitted to use, and actively work to secure compliance while taking measures against violations. Crucially, an advertiser cannot escape these obligations by arguing that compliance is the influencer's own responsibility. Advertisers who can demonstrate that they fulfilled these duties are deemed to have made the best efforts reasonably expected of them.

Liability and Enforcement

Responsibility under the Guideline is individual and cumulative: advertisers, advertising agencies, media organizations and each influencer are separately accountable for compliance. Correcting or remedying a non-compliant advertisement after the fact does not eliminate liability for the violation already identified. The Guideline also cannot be interpreted or applied in a manner contrary to Law No. 6502 or to the Regulation's provisions on covert advertising, and it enters into force upon the Board's decision.

Practical Takeaways

For brands and influencers operating in Turkey, the message is clear. Every sponsored post, gifted product and paid collaboration must be labeled visibly and immediately, using the exact type of wording the Guideline prescribes for the platform in question. Health-adjacent promotion is largely off limits, filtered product imagery must be flagged, and fake engagement is prohibited outright. Advertisers, for their part, should build Guideline compliance into their influencer contracts and monitoring processes, because Turkish law will not allow them to shift the blame onto the influencer when the Advertisement Board comes knocking.