The Personal Data Protection Authority (“Authority”) has determined a new exemption criterion regarding the obligation to register with the Data Controllers’ Registry (“VERBİS”) for data controllers whose main activity involves the processing of special categories of personal data, with its Board Decision dated 04.09.2025 and numbered 2025/1572. The said Decision was published in the Official Gazette on 1 October 2025 and entered into force.
Pursuant to Article 16/1 of the Law on the Protection of Personal Data No. 6698 (“Law” or “KVKK”), all natural and legal person data controllers processing personal data are obliged to register with VERBİS. Article 16/2 of the Law stipulates that, by considering objective criteria such as the nature and volume of the data processed, the legal grounds for processing, or the status of transfer to third parties, certain data controllers may be exempted from this obligation by a decision of the Board.
Within this framework, by the Board Decision dated 19.07.2018 and numbered 2018/87, data controllers with “fewer than 50 employees and an annual balance sheet total of less than TRY 25 million, whose main activity is not the processing of special categories of personal data” were exempted from the obligation to register with VERBİS. This Decision was amended by the Board Decision dated 06.07.2023 and numbered 2023/1154, and the balance sheet threshold was updated to TRY 100 million.
Most recently, with the Board Decision dated 04.09.2025 and numbered 2025/1572, for the first time, an exemption has also been introduced for data controllers whose main activity is the processing of special categories of personal data. According to the Decision, natural or legal person data controllers with fewer than 10 employees and an annual balance sheet total of less than TRY 10 million have been exempted from the obligation to register with VERBİS.
Decision of the Personal Data Protection Board dated 04/09/2025 and numbered 2025/1572
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