BOARD’S DECISION REGARDING THE EXEMPTION FROM THE OBLIGATION TO REGISTER WITH DATA CONTROLLERS’ REGISTRY
Pursuant to Article 16(2) of the Law on the Protection of Personal Data No. 6698 (“the Law”), real and legal person data controllers who process personal data are required to register with the Data Controllers’ Registry (“VERBIS”) prior to start to process personal data. However, the same article of the Law provides that, by taking into account the objective criteria set by the Personal Data Protection Board (the “Board”) such as the nature and quantity of the data processed, whether data processing arises from the law, or the fact of transferring the data to third parties, the Board may provide derogation from the obligation of registration with VERBIS.
In this context, the Board has previously adopted several decisions outlining exemptions from registration obligation. Notably, in decision 2018/87 dated 19 July 2018, the Board ruled that data controllers whose main field of activity is not the processing of special categories of personal data, and who have fewer than 50 employees annually and an annual financial balance sheet total is less than TRY 25 million would be exempted from the obligation to register with VERBIS. This financial threshold of TRY 25 million was later revised to TRY 100 million by the Board’s decision dated 6 July 2023 and numbered 2023/1154.
Recently, by the Board’s decision dated 04.09.2025 and numbered 2025/1572 (the “Decision”), it has also been decided to exempt some real or legal person data controllers, whose main field of activity is the processing of special categories of personal data. According to the Decision, real or legal person data controllers with fewer than 10 employees and whose annual financial balance sheet total is less than TRY 10 million have been exempted from the obligation to register with and notify VERBIS.
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