I. Introduction
The Regulation on Geographic Data Permits (the “Regulation”), published in Official Gazette No. 33400 of 14 October 2026, requires individuals, private-law legal entities and foreign individuals and legal entities that collect, produce, share or sell geographic data within the National Geographic Data Responsibility Matrix (the “Matrix”) for commercial purposes to obtain a permit from the Ministry of Environment, Urbanisation and Climate Change (the “Ministry”).
The Regulation entered into force on publication and provides no transition period for new applications; it also provides for an administrative fine for activity carried on without a permit. Companies engaged in commercial activity involving Matrix data should therefore review without delay whether their activities require a permit and what their existing permit documents cover.
II. The Permit Requirement and Its Scope
The Regulation limits the permit requirement to data within the Matrix, which lists the geographic data themes and the public bodies responsible for them. An application must accordingly state the theme and subtheme under which the data appears in the Matrix, the area of work and the intended activity. Where a company is a branch within the meaning of the Turkish Commercial Code, its head office must obtain a single permit; where a company is an agency, the head office for which it acts must do so.
As to the documents to be submitted and the way the fee is calculated, the Regulation distinguishes according to whether the company carrying on the activity is established in Türkiye. As a foreign legal entity is defined as a company with legal personality that is not established in Türkiye, a company established in Türkiye falls outside that definition even if it belongs to a foreign group, and is subject to the rules for domestic companies.
III. The Application and the Permit Fee
Under the Regulation, an application must be made by a person authorised to sign, through the Ministry’s electronic infrastructure, before the start date of the commercial activity concerned, and the Ministry will notify the outcome of its assessment within thirty days of the application. An individual or private-law legal entity whose application documents the Ministry has approved must pay the permit fee within fifteen days; if payment is not made in that time, the application will be treated as invalid. Once the fee has been paid, the approved permit contract notified to the applicant must also be accepted and approved through the electronic infrastructure by the authorised or responsible person acting for it.
The Regulation asks foreign individuals and legal entities for the originals and notarised translations of documents on their commercial activities in their country of establishment, together with notarised documents legally proving their undertakings with the persons or firms that will carry out their activities in Türkiye. Legal entities established in Türkiye are asked for documents and declarations on registration, tax, data security and staff qualifications. The fee follows the same distinction. For Turkish-citizen individuals and private-law legal entities, the Regulation sets the fee on the basis of the number of data themes, the area of work, the permit term and annual net sales or sales revenue; for foreign individuals and legal entities, the fee is 1,250 times the permit coefficient amount multiplied by the duration coefficient. The coefficient amount and the amounts in the net sales schedule will be increased every year by the revaluation rate, and the current fees will be published in the unit price list of the Ministry’s Revolving Fund Enterprise.
IV. Obligations After the Permit Is Granted
The Regulation requires individual and private-law legal entity permit holders to apply again when the data, area of work or permit term stated in the document changes, or when the activity continues after the term has ended, and states that these persons may not transfer the permit document to third parties. When a legal entity’s name or partners change, the change must be notified through the electronic infrastructure within fifteen days, together with the Turkish Trade Registry Gazette in which it was published. The end of the activity, the end of the undertakings that foreign individuals or legal entities have made with the persons or firms carrying out their activities in Türkiye, and changes in contact details, vehicles or staff must be notified to the Ministry within the same fifteen-day period.
The permit holder must also submit its activity report and its data information (metadata) to the electronic infrastructure every twelve months. It must further provide all the geographic data it has worked on, free of charge and at the Ministry’s request, for use in disaster and emergency management work; the Regulation provides that this obligation continues after the permit term has ended.
V. Fee Exemptions and Permit Exemptions
The Regulation provides for a fee-free permit for geographic data collection, production or sharing carried out for public institutions and public legal entities, and for Turkish-citizen individuals and private-law legal entities in the year in which they first begin commercial activity, but in both cases it keeps the obligation to obtain a permit. Where data obtained from activities carried out for public institutions is made the subject of trade, sold and shared, a fee must also be paid.
The Regulation exempts legal entities holding electricity and natural gas distribution licences from both the permit and the fee for the activities covered by their distribution licence, provided that they register with the electronic infrastructure, and states that if they use the same data in commercial activity outside the distribution licence they must obtain a permit and pay the fee. In addition, requesting address details for the purpose of issuing invoices, and sharing the address and location data of the head office, branches and agencies through which a business operates on its website or social media accounts, do not require a permit, including for foreign individuals and legal entities.
VI. Status of Existing Permit and Licence Documents
Companies that already hold a permit or licence document do not have to renew it because of the new Regulation. While the Regulation repeals the previous Geographic Data Permits Regulation and Geographic Data Licence Regulation, it provides that documents issued under them will remain valid until the end of the period for which they were issued.
VII. Conclusion
The Regulation restates the permit requirement for commercial activities involving geographic data within the Matrix, with new rules on applications, fees and notifications. Because the permit document cannot be transferred, and because the required documents and the fee depend on whether the applicant is established in Türkiye, the company in whose name the permit will be obtained must be identified before the activity begins, and the application must be made in that company’s name. Businesses that obtain geographic data services from another company would also be well advised to state clearly in the supply contract who will make the application and who will arrange data sharing with the Ministry. The Regulation provides that, where unauthorised activity is detected, the person carrying it out is to be given fifteen days from notification to apply for a permit. Turkish-citizen individuals and private-law legal entities that do not apply within that period will be fined the highest one-year permit fee for the year in which the activity was detected, and foreign individuals and legal entities twice the one-year permit fee. For permit holders, failure to perform the obligations under the permit contract may lead to suspension of the permit, and failure to remedy the deficiencies relating to a suspended permit within the time set may lead to its cancellation.
