ARTIFICIAL INTELLIGENCE LAW IN TÜRKİYE: The Legal Foundations of AI Governance in Türkiye in Light of the Presidential Decrees Dated 25 December 2025

ARTIFICIAL INTELLIGENCE LAW IN TÜRKİYE: The Legal Foundations of AI Governance in Türkiye in Light of the Presidential Decrees Dated 25 December 2025

PAGE 1 – INTRODUCTION

Türkiye does not yet have a standalone and comprehensive Artificial Intelligence Law that regulates artificial intelligence in a holistic manner. However, this does not mean that artificial intelligence applications operate within a legal vacuum.

With Presidential Decree No. 191 dated 25 December 2025, artificial intelligence was, for the first time, explicitly addressed within the framework of central administrative structures, defined mandates, and oversight mechanisms. As a result, artificial intelligence has ceased to be merely an element of technology policy and has become an independent field of administrative activity embedded within public administration.

This approach demonstrates that artificial intelligence law in Türkiye, unlike the classical statute‑based regulatory model, has been shaped primarily along the axis of administrative law prior to the enactment of a specific AI statute.

PAGE 2 – GOVERNANCE MODEL IN ARTIFICIAL INTELLIGENCE LAW

Presidential Decree No. 119 introduced amendments to numerous presidential decrees and concretised the governance model by defining institutional authorities and responsibilities in the field of artificial intelligence. This model reflects a centralised, top‑down structure in which public security considerations play a dominant role.

Artificial intelligence is no longer addressed solely as an area of private‑sector innovation or R&D activity; rather, it is considered together with public services, digital government, and national security perspectives.

This clearly demonstrates that artificial intelligence law in Türkiye is being shaped through administrative organisations prior to the adoption of normative legislative regulations.

PAGE 3 – THE MINISTRY OF INDUSTRY AND TECHNOLOGY TRACK

Through the amendments introduced by Presidential Decree No. 119 dated 25 December 2025 to Presidential Decree No. 1, the organisational structure of the Ministry of Industry and Technology was revised, and the Directorate General of National Technology was restructured as the Directorate General of National Technology and Artificial Intelligence.

The Directorate General of National Technology and Artificial Intelligence is tasked with formulating artificial intelligence policies, developing principles for trustworthy and ethical AI, strengthening data and computational infrastructure, and ensuring coordination among public institutions.

From a legal perspective, this structure primarily frames artificial intelligence as a technology area that generates economic value and is closely linked to industrial policy.

PAGE 4 – ARTIFICIAL INTELLIGENCE INFRASTRUCTURE AND ADMINISTRATIVE OVERSIGHT

With the new regulations, data centres, cloud computing infrastructures, and the technical foundations of artificial intelligence systems have been subjected to standard‑setting, certification, and authorisation processes.

This development indicates that AI infrastructure is no longer merely a technical matter, but has become a direct subject of administrative permitting and oversight.

In particular, infrastructure choices relating to personal data protection legislation, data security, and data sovereignty have become decisions that produce direct legal consequences for companies.

PAGE 5 – THE CYBERSECURITY PRESIDENCY AND PRESIDENTIAL DECREE NO. 177

Pursuant to the provisions added to Article 4 of Presidential Decree No. 177 under the regulations dated 25 December 2025, the scope of authority of the Cybersecurity Presidency, affiliated with the Presidency of the Republic, has been expanded.

The Presidency has been authorised to monitor artificial intelligence applications used by public institutions, protect algorithms utilised within digital government infrastructures against cyber risks, and ensure the security of public digital platforms.

Furthermore, a Public Artificial Intelligence Directorate General has been established within the Cybersecurity Presidency. This Directorate General will determine the areas in which artificial intelligence may be used, the manner of such use, and the applicable limitations within the public sector.

PAGE 6 – DIVISION OF RESPONSIBILITIES AND INSTITUTIONAL COORDINATION

The current regulatory framework does not envisage an explicit conflict of authority between the Ministry of Industry and Technology and the Cybersecurity Presidency.

While the Ministry of Industry and Technology focuses on development, industrial policy, and infrastructure, the Cybersecurity track operates from the perspectives of public security, digital government, and cyber risk.

This structure reflects a centralised governance model based on a functional division of responsibilities.

PAGE 7 – NPARTNERS’ ANALYSIS AND OUR 2026 OUTLOOK

The Directorate General of National Technology and Artificial Intelligence established through these presidential decrees, together with the expanded authority of the Cybersecurity Presidency, constitutes the institutional and legal foundation of artificial intelligence law in Türkiye for the statutes, presidential decrees, communiqués, and secondary legislation that are likely to be enacted as of 2026.

Accordingly, it is evident that the existing administrative structures will serve as the principal axes shaping the future of artificial intelligence law in Türkiye. Let's Manage Your Artificial Intelligence Legislation Compliance Process Together The rapidly evolving artificial intelligence legislation and new administrative audit processes in Turkey may have critical legal consequences for your business. Contact Npartners' expert legal team to minimize your risks and ensure full compliance with the new regulations in the 2026 perspective.

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