Application Principles Regarding the New Exemptions from the VERBIS Registration Obligation Announced
The Public Announcement (Announcement) regarding the application principles of the Personal Data Protection Board’s (Board) decision dated 04.09.2025 and numbered 2025/1572 was published on 12.01.2026.
As is known, pursuant to Article 16 of Law No. 6698 on the Protection of Personal Data, natural and legal persons processing personal data are required to register with the Data Controllers’ Registry Information System (VERBIS). However, exemptions from this obligation may be introduced within the framework of objective criteria determined by the Board.
In this context, pursuant to the Board’s decision dated 04.09.2025 and numbered 2025/1572, the following data controllers have been exempted from the VERBIS registration obligation:
- Data controllers with fewer than 50 employees and an annual financial balance sheet total of less than TRY 100 million, whose main activity does not consist of processing special categories of personal data.
- Data controllers, whose main activity consists of processing special categories of personal data, if they have fewer than 10 employees and an annual financial balance sheet total of less than TRY 10 million.
The VERBIS Q&A Guide published by the Personal Data Protection Authority states that the term “annual financial balance sheet total” refers to the total amount indicated in the balance sheets attached to the annual tax returns of data controllers keeping books on a balance sheet basis. However, the absence of such information for data controllers not keeping books on a balance sheet basis has given rise to uncertainties in practice.
In this respect, the Board Decision dated 25.12.2025 and numbered 2025/2393 has clarified how the annual financial balance sheet criterion should be applied. Accordingly, the following criteria shall be considered when determining data controllers exempt from the VERBIS registration obligation:
- For data controllers keeping books on a balance sheet basis, both the annual number of employees and the annual financial balance sheet total criteria shall apply cumulatively.
- For data controllers not keeping books on a balance sheet basis, only the annual number of employees criterion shall apply, as no annual financial balance sheet total information is available.
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