Important Regulatory Changes Regarding Courier and Transportation Activities

Recently published amendments in the Official Gazette have introduced significant updates to the regulations governing courier and transportation services. These updates are particularly relevant for businesses operating through online platforms, bringing new obligations and definitions into effect. In this announcement, we will highlight the key points of the changes made in the legislation listed below.

Under the Regulation Amending the Road Transport Regulation, published in the Official Gazette dated May 15, 2025, and numbered 32901:

• The term “distribution operator” has been removed from the scope of the Road Transport Regulation. Instead, the term “courier operator” has been introduced into the legislation. Pursuant to this new definition, natural or legal persons who, in the capacity of a carrier, are (i) either authorized under the Authorization Regulation Regarding the Postal Sector published in the Official Gazette dated 3 June 2014 and numbered 29019 (ii) engaged in commercial/private transportation activities, and who ensures the transportation and/or distribution of courier items under their supervision and control;
• The term “courier shipment” is defined the items weighing up to 30 kilograms and/or having a volume of up to 300 decimeters cubed, which are transported/distributed without any sorting/transshipment process and without additional packaging by the carrier;
• It has been regulated that natural and legal persons who will operate as courier operators for commercial or private purposes within a province or between neighboring districts of different provinces shall be granted a P1 or P2 authorization certificate, depending on the nature of their activities;
• While the obligations of courier operators have been detailed, certain changes have been made to the criteria for obtaining and renewing authorization certificates, as well as the vehicle requirements. As per the recent amendments, applicants for a P1 authorization certificate must own at least 5 self-owned motor vehicles and have a capital or operating capital of at least TRY 100,000. Whereas, the applicants for a P2 authorization certificate must own at least 30 self-owned motor vehicles and have a capital or operating capital of at least TRY 500,000. Legal entities holding a P1 authorization certificate are required to either employ at least one person holding a medium-level professional competency certificate, or themselves possess such a certificate.

The Regulation Amending the Road Transport Regulation

Under the Regulation Amending the Authorization Regulation on the Postal Sector, published in the Official Gazette dated March 8, 2025 and numbered 32835:

• The definition of “platform” has been added to the legislation. In this way, e-commerce marketplaces and other e-commerce environments have been brought under the scope of postal services legislation. Accordingly, a platform is defined in the regulation as a digital environment such as a website, mobile site, or mobile application where goods or services are sold or offered for sale;
• In connection with this definition, the concept of “platform-based postal services” has also been introduced. This refers to postal services whereby the acceptance, collection, processing, dispatch, distribution, and delivery of products sold or offered for sale on the platform are planned, executed, or coordinated by the platform or on its behalf;
• It has been regulated that services provided by businesses that deliver their own products directly to buyers through employees working under an employment contract shall not be considered as postal services;
• The minimum share capital requirement for companies wishing to provide postal services has been increased. Companies aiming to provide postal services at a national level must have a minimum paid-in share capital of TRY 5,000,000, while those wishing to operate at a provincial level must have at least TRY 1,000,000 in paid-in share capital;

The Regulation Amending the Authorization Regulation on the Postal Sector

Under the Regulation Amending the Regulation on Electronic Commerce Intermediary Service Providers and Electronic Commerce Service Providers, published in the Official Gazette dated March 15, 2024 and numbered 32842, and the Official Gazette dated March 8, 2025 and numbered 32835:

• Changes have been made to the minimum elements of intermediary contracts for medium, large, and very large scale electronic commerce intermediary service providers. In this context, it is contemplated that electronic service providers’ rights on data access and portability to be included in the intermediary contracts.;
• It has been regulated that if a change is made in intermediary contracts in favor of electronic commerce service providers, the contract change shall enter into force immediately without any waiting period;
• Changes have been made to the obligations of electronic commerce intermediary service providers. In this context, one of the notable obligation is that during the contract period and for one year after its termination, electronic commerce service providers must provide technical means for viewing, recording, and copying without alteration the information contained in the internal communication system.
• It is contemplated that when calculating the license fee for electronic commerce intermediary service providers, sales made abroad shall not be considered. Moreover, it is also articulated that, subject to certain conditions, these sales and investment projects with incentive certificates can be deducted from the transaction volume to apply an additional discount.

The Regulation Amending the Regulation on Electronic Commerce Intermediary Service Providers and Electronic Commerce Service Providers

Under the Regulation Amending the Universal Postal Services Regulation, published in the Official Gazette dated May 22, 2025 and numbered 32907:

• Key concepts such as universal postal service, universal postal service provider, universal postal service obligor, and service provider have been added to the regulation as definitions;
• New provisions have been introduced regarding universal postal service revenues and collection principles. According to these provisions, if contribution declarations are incomplete, incorrect, not submitted on time, or not paid, the Ministry shall grant an additional one-month period and if the deficiency is not resolved within this period, the service provider’s authorization may be revoked. It is also articulated that unpaid contributions shall be collected by the tax office, together with late payment interest, in accordance with Law No. 6183.

The Regulation Amending the Universal Postal Services Regulation