AI Lawyer in Istanbul, Turkey

Artificial Intelligence Lawyer in Turkey

There is currently no single Turkish statute that answers every legal question created by artificial intelligence.

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Instead, AI activities can fall within several existing legal frameworks.

 

For example, an AI platform that processes customer information may raise questions under the Law No. 6698 on the Protection of Personal Data (KVKK). An AI development project may involve copyright, software rights, trade secrets or licensing. An AI-enabled consumer service may create obligations under consumer legislation. An automated recruitment tool may require consideration of employment and privacy issues.

 

This is why simply asking whether something is “legal AI” or “illegal AI” often does not provide a useful answer.

 

The more useful questions are:

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• What does the system do?

• What data does it process?

• Who controls it?

• Who supplies the technology?

• Who uses the output?

• Where are the users located?

• Where is the data processed?

• What contractual relationships exist?

• What could happen if the system produces an inaccurate result?

• Which Turkish or foreign laws apply?

 

The answers provide the foundation for a meaningful legal assessment.

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AI Law in Turkey: A Developing Legal Environment

AI regulation in Turkey is developing alongside the technology itself.

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The KVKK has already addressed generative AI from a personal-data perspective. Its official “Generative Artificial Intelligence and Personal Data Protection Guide” considers the lifecycle of generative AI systems and the processing of personal data under Turkish data-protection law.

 

At the legislative level, AI-related proposals are also being discussed in the TBMM. It is important, however, to distinguish between a law that has been enacted and a legislative proposal that is still being considered. A proposal should not be treated as binding law merely because it has been submitted to Parliament.

 

Businesses should therefore monitor both:

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1. laws and regulations that are already in force; and

2. regulatory and legislative developments that may change the legal environment.

 

This distinction is particularly important for technology companies building products that may remain on the market for many years.

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What Does an AI Lawyer Actually Handle?

AI legal work is not limited to reviewing an AI policy or writing a privacy notice.

Depending on the project, an AI lawyer may become involved at several stages.

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This can include:

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• reviewing the proposed AI business model;

• identifying regulatory requirements;

• assessing data-processing arrangements;

• reviewing AI vendor agreements;

• drafting AI-related commercial contracts;

• examining intellectual-property ownership;

• advising on confidentiality and trade secrets;

• assessing international data transfers;

• preparing internal AI policies;

• reviewing AI procurement;

• considering consumer-facing disclosures;

• assessing employment-related uses of AI;

• addressing AI-related disputes; and

• monitoring regulatory developments.

 

The work is often collaborative. Lawyers may need to understand the technology sufficiently to communicate effectively with founders, developers, product managers, compliance teams and information-security professionals.

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AI Legal Services in Istanbul

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AI Regulatory Assessment

Before introducing an AI system, a business can benefit from understanding its legal position before the product reaches customers.

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A regulatory assessment may examine:

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• the purpose of the system;

• whether it is developed internally or supplied by a third party;

• the role of the organisation;

• the type of information processed;

• whether personal data is involved;

• whether sensitive information is involved;

• where data is stored;

• whether information crosses national borders;

• how users interact with the system;

• whether human review is required;

• the contractual structure; and

• the jurisdictions in which the product will operate.

 

The result is not necessarily a lengthy compliance document.

 

Often, the most useful outcome is a clear understanding of what the business needs to change before deployment.

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AI Contracts

AI projects can involve a surprisingly large number of contracts.

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These may include:

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• AI software development agreements;

• SaaS agreements;

• API agreements;

• technology licensing agreements;

• cloud-service agreements;

• data-processing agreements;

• outsourcing agreements;

• distribution agreements;

• reseller agreements;

• research and development agreements;

• confidentiality agreements; and

• strategic technology agreements.

 

Traditional software contracts do not always deal adequately with AI-specific issues.

 

An AI agreement may need to address:

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• ownership of models and improvements;

• training data;

• permitted uses;

• restrictions on data and prompts;

• confidentiality;

• security;

• model changes;

• service availability;

• output-related responsibilities;

• intellectual-property claims;

• indemnification;

• liability limits;

• audit rights;

• regulatory compliance; and

• termination.

 

The right provisions depend heavily on the particular AI product and relationship.

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AI and Personal Data Protection in Turkey

Personal data is one of the most important legal considerations in artificial intelligence.

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AI systems can process information supplied by customers, employees, applicants, patients, website visitors or other individuals. They can also combine information from different sources and generate new inferences from existing data.

 

That makes the data-protection assessment particularly important.

 

The KVKK's official generative AI guidance specifically considers personal-data processing throughout the lifecycle of generative AI systems.

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Lawful Processing

A business should identify the appropriate legal basis for processing personal data and ensure that the processing is compatible with the applicable requirements.

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Purpose and Data Minimisation

AI systems can process enormous quantities of information. That does not automatically mean that an organisation should provide the system with every piece of information it possesses.

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A narrower dataset may sometimes be both safer and more appropriate.

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Sensitive Personal Data

AI projects involving sensitive information require particular care because the consequences of inappropriate processing may be significant.

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Transparency

Businesses should consider how individuals will be informed about the processing of their information and whether additional transparency measures are necessary.

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International Data Transfers

Many AI services operate through international cloud infrastructure.

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A Turkish business therefore needs to understand where information goes, which service providers have access to it and which legal mechanisms govern the transfer.

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Profiling and Automated Decisions

AI can be used to classify, score or profile individuals.

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Where such processing can materially affect people, additional legal and governance questions may arise.

 

The KVKK has also examined AI-related data-protection issues across areas including employment, health, finance and transportation.

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Can Employees Put Company Information Into Chatbots?

This is a practical question many organisations now face.

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An employee may paste a contract, customer complaint, source code, financial document or internal report into an AI tool simply because the tool can summarise or analyse it within seconds.

 

The organisation may then discover that it has created an unexpected confidentiality, data-protection or intellectual-property issue.

 

For this reason, businesses should consider an internal AI-use policy covering matters such as:

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• approved AI applications;

• prohibited uses;

• confidential information;

• personal data;

• customer information;

• source code;

• trade secrets;

• human review;

• verification of AI-generated information;

• record keeping; and

• responsibility for AI-assisted work.

 

A useful AI policy does not necessarily have to prohibit AI.

 

Its purpose is usually to establish where AI can be used safely and where additional controls are needed.

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AI and Intellectual Property

Artificial intelligence creates intellectual-property questions at several different points.

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There is the material used to train or operate an AI system.

 

There is the software, model, database or technology behind the system.

 

And there is the material produced by the system.

 

These are separate questions and should not automatically be treated as one.

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AI Training Data and Copyright

Businesses developing or fine-tuning AI systems should examine the legal status of the material used in the process.

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Depending on the circumstances, this can involve:

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• copyright;

• database rights;

• trade secrets;

• licensing restrictions;

• contractual restrictions; and

• other third-party rights.

 

The Directorate General of Copyright under Türkiye's Ministry of Culture and Tourism provides official information concerning Turkish copyright matters.

 

AI and copyright are also developing areas of legislative attention. Businesses should therefore distinguish current law from proposed amendments when assessing their position.

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AI-Generated Content

The fact that an AI system generated a piece of text, image, audio or other material does not by itself answer every question about ownership or third-party rights.

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A legal assessment may need to consider:

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• the degree of human contribution;

• the underlying material;

• the system used;

• contractual terms;

• licences;

• third-party rights; and

• the applicable intellectual-property rules.

 

The Turkish Patent and Trademark Office (TÜRKPATENT) is an important official source for Turkish industrial-property matters, including patents, trademarks and designs.

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AI and Software Development

AI-assisted programming has quickly become part of many software-development environments.

 

Developers may use AI to:

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• generate code;

• explain existing code;

• identify potential bugs;

• create documentation;

• produce test cases;

• translate code;

• assist with debugging; or

• explore technical solutions.

 

This can improve productivity, but it also raises legal questions.

 

For example:

 

Who owns AI-assisted code?

Could generated code contain material subject to an open-source licence?

Was confidential source code entered into an external AI service?

Does the software-development agreement permit the use of AI tools?

Has the developer reviewed the output before incorporating it into the product?

 

These questions connect AI law with software licensing, intellectual property, confidentiality and commercial contracting.

 

Businesses can also review our broader information technology law practice in Istanbul.

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AI and Employment Law

AI is increasingly being used in the workplace.

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Examples include:

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• recruitment screening;

• CV analysis;

• employee scheduling;

• performance analysis;

• workplace monitoring;

• automated communications;

• workforce planning; and

• document processing.

 

These applications may create questions concerning personal data, workplace privacy, transparency, discrimination, contractual rights and human oversight.

 

The KVKK has recognised employment as one of the areas requiring attention when considering AI and personal-data protection.

 

Employers should also consider whether employees understand how AI tools are being used and who is responsible for reviewing important outputs.

 

An AI recommendation should not automatically become an unquestioned employment decision simply because it was produced by software.

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AI and Consumer Protection

Consumer-facing AI can create legal issues that are easy to overlook.

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Consider an online business using an AI chatbot to answer customer questions.

 

What happens if the chatbot:

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• gives the wrong price;

• makes a misleading statement;

• promises a service the company does not provide;

• incorrectly describes a product;

• provides inaccurate financial information; or

• gives a customer a materially different answer from the company's actual contractual terms?

 

The technology may have produced the statement, but the business still needs to consider its legal responsibilities.

 

AI systems used in advertising, recommendations, sales and customer support should therefore be considered alongside consumer and commercial-law requirements.

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AI and Competition Law in Turkey

Artificial intelligence is also changing the competitive landscape.

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The Turkish Competition Authority has undertaken a sector inquiry concerning artificial intelligence and its effects on markets and competition. The Authority's work examines the AI value chain and the changing competitive environment surrounding the technology.

 

Potential competition-law questions can arise around:

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• access to data;

• access to computing resources;

• platform dependency;

• exclusive arrangements;

• algorithmic pricing;

• information sharing;

• interoperability;

• market concentration; and

• relationships between technology providers and downstream businesses.

 

For companies operating in concentrated technology markets, these questions can become important during commercial negotiations, investments and strategic partnerships.

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AI and Cybersecurity

Artificial intelligence and cybersecurity are closely connected.

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AI can help identify patterns and detect threats, but an AI system can itself become part of an organisation's security risk.

 

Legal review may therefore consider:

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• access controls;

• security responsibilities;

• cloud providers;

• incident response;

• confidential information;

• system vulnerabilities;

• third-party access;

• cybersecurity obligations; and

• contractual allocation of risk.

 

AI governance should not exist in isolation from the organisation's broader information-security programme.

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Who Is Responsible When AI Makes a Mistake?

This is one of the most common practical questions.

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The answer depends on the circumstances.

 

Potentially relevant parties may include:

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• the developer;

• the AI provider;

• the software supplier;

• the business deploying the system;

• an employee operating the system; or

• another party involved in the transaction.

 

The legal analysis may depend on what the system was designed to do, how it was configured, what instructions it received, what contractual commitments were made and whether human review was expected.

 

The important point is that AI does not automatically become the legal decision-maker simply because it generated the output.

 

The underlying contractual, statutory and professional responsibilities still need to be identified.

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AI Governance for Turkish Companies

AI governance sounds complicated, but the practical starting point can be straightforward.

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A company should know:

What AI do we use?

Why do we use it?

What information does it receive?

Who can access that information?

Who supplied the technology?

What happens to our data?

Who reviews the output?

Who is responsible when something goes wrong?

Which laws apply?

 

These questions can form the foundation of an internal AI governance framework.

 

A larger organisation may develop formal procedures covering:

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1. AI inventory;

2. risk classification;

3. data mapping;

4. vendor assessment;

5. intellectual-property review;

6. security controls;

7. human oversight;

8. employee training;

9. incident management;

10. documentation;

11. periodic review; and

12. regulatory monitoring.

 

The appropriate level of governance should reflect the organisation's size, sector and actual use of AI.

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EU AI Act and Turkish Companies

A Turkish company's location outside the EU does not, by itself, answer whether the EU AI Act matters.

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The European Commission's official guidance makes clear that certain AI Act obligations can apply to providers established outside the EU, including in circumstances involving AI systems whose output is used in the EU.

 

This makes the EU framework particularly relevant to some Turkish:

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• software companies;

• SaaS providers;

• AI developers;

• exporters;

• technology suppliers;

• multinational groups;

• platforms; and

• businesses serving European customers.

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AI Act Transparency Rules

The EU's Article 50 transparency obligations apply from 2 August 2026.

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The European Commission explains that these rules cover certain AI interactions and AI-generated or manipulated content. Depending on the circumstances, providers and deployers may have obligations concerning disclosure of AI interaction, machine-readable marking, deepfakes, biometric categorisation and certain AI-generated public-interest content.

 

The Commission has also published guidelines on AI Act transparency obligations and a Code of Practice on transparency of AI-generated content.

 

Other AI Act requirements apply according to the Act's phased timetable. The official AI Act Service Desk records, among other dates, 2 December 2027 for certain Annex III high-risk AI rules and 2 August 2028 for high-risk AI systems embedded in regulated products.

 

For a Turkish business with European operations, the question is therefore not simply “Are we in Turkey?” but rather “What role do we play in the AI value chain, where is the system placed on the market or used, and what connections do we have with the EU?”

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International AI Governance

AI businesses increasingly operate across several jurisdictions.

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That makes international frameworks useful even when they are not themselves Turkish legislation.

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The OECD AI Principles address areas including human rights, fairness, transparency, robustness, security and accountability.

 

The OECD has also published Due Diligence Guidance for Responsible AI, providing a practical framework for enterprises developing or using AI.

 

Another important international reference is UNESCO's Recommendation on the Ethics of Artificial Intelligence, which addresses human rights, dignity, transparency, fairness and human oversight.

 

These instruments should not be confused with Turkish statutes. They can nevertheless provide useful reference points when a company is designing an internal AI governance framework or operating across borders.

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AI Due Diligence for Investors

AI can become one of the most important assets in a technology business.

It can also become one of its less visible legal risks.

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During an acquisition or investment, due diligence may need to examine:

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• ownership of AI technology;

• software licences;

• training datasets;

• third-party data;

• open-source components;

• customer agreements;

• data-protection compliance;

• cybersecurity;

• intellectual-property disputes;

• regulatory correspondence;

• AI-related warranties;

• supplier dependencies; and

• restrictions on commercial use.

 

For investors, the question is not merely “Does this company use AI?”

 

A more useful question may be:

 

“What exactly does the company own, what does it license, what data does it rely on, and what legal rights support its AI product?”

 

AI due diligence can therefore become part of wider M&A legal work in Turkey.

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AI and Commercial Transactions

AI increasingly appears in ordinary commercial agreements.

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A business might acquire:

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• an AI-powered customer-service platform;

• an AI analytics product;

• an automated document-review service;

• an AI-powered cybersecurity solution; or

• a generative-AI API.

 

The contract should reflect the actual technology.

 

For example, a customer may want to know:

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• whether the provider can change the underlying model;

• whether customer data is used for training;

• what happens when an AI model is retired;

• whether outputs are guaranteed to be accurate;

• how security incidents are handled;

• whether the provider can subcontract processing;

• whether audit rights are available; and

• what happens to the data when the agreement ends.

 

These are commercial questions with technological consequences.

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AI Disputes and Litigation

AI-related disputes may involve several areas of law at once.

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A dispute might concern:

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• an AI software contract;

• intellectual-property ownership;

• unauthorised use of training material;

• confidential information;

• personal-data processing;

• inaccurate AI-generated content;

• consumer claims;

• employment decisions; or

• technology performance.

 

When a dispute arises, understanding the technical facts becomes important.

 

Lawyers may need to establish:

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• what the system was instructed to do;

• what data it received;

• what output it generated;

• who reviewed the output;

• who controlled the relevant system;

• what the contract required; and

• what records remain available.

 

This is one reason AI disputes can require close cooperation between legal and technical teams.

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AI in the Legal Profession

Artificial intelligence is also changing how lawyers work.

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Legal teams may use AI for:

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• document classification;

• contract review;

• legal research assistance;

• summarisation;

• translation;

• due diligence;

• knowledge management; and

• administrative tasks.

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But legal technology does not eliminate professional responsibility.

 

Confidentiality, accuracy, verification and professional judgment remain important.

 

The Turkish Ministry of Justice and its technology-related institutions have also been developing AI-supported applications within the justice system, illustrating that AI is becoming relevant to legal and judicial processes as well as private business.

 

For law firms and legal departments using AI, the same principles apply: understand the tool, protect confidential information, verify important outputs and establish appropriate human oversight.

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A Practical AI Legal Review

For a company considering an AI project, the legal review can follow a simple sequence.

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1. Understand the Technology

Start with what the system actually does rather than what it is called.

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2. Identify the Participants

Clarify who develops, supplies, operates and controls the system.

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3. Map the Data

Identify what information enters the system and where it travels.

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4. Review Intellectual Property

Determine who owns the technology, licences it and has rights in relevant inputs and outputs.

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5. Examine the Contract

Review data use, confidentiality, security, liability, warranties, indemnities and termination.

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6. Consider Users

Ask what customers, employees or other individuals need to know about the AI system.

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7. Establish Human Oversight

Identify decisions that require meaningful human review.

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8. Check Cross-Border Requirements

Determine whether the system is connected with another jurisdiction, particularly the EU.

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9. Create Practical Controls

Turn the legal analysis into policies, contractual clauses and operational procedures.

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10. Revisit the Assessment

AI systems change. Models change, suppliers change, data changes and products evolve.

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A legal review should therefore be capable of evolving with the technology.

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Frequently Asked Questions About AI Law in Turkey

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Is artificial intelligence specifically regulated in Turkey?

AI-related activities can already be subject to existing Turkish laws, including rules concerning personal data, intellectual property, contracts, consumers, employment, competition and cybersecurity. AI-specific legislative and regulatory developments are also continuing.

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Is there one comprehensive Turkish AI Act?

The Turkish AI legal framework should not currently be treated as one comprehensive statute covering every AI application. Businesses should assess the specific activity against the laws and regulations that apply to it.

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Does KVKK apply to AI?

Where an AI system processes personal data, Turkish data-protection law may apply. The KVKK's official guidance on generative AI specifically addresses these issues.

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Can confidential company information be entered into an AI chatbot?

A company should not assume that this is safe merely because the AI tool is commercially available. Its terms, data practices, security arrangements and the company's own confidentiality and data-protection obligations should be reviewed first.

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Who owns AI-generated content?

There is no single answer for every type of AI-generated material. Ownership and third-party rights can depend on human contribution, the underlying material, contractual terms, licensing and the applicable intellectual-property rules.

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Does the EU AI Act affect Turkish companies?

It can. Certain AI Act provisions can apply to operators outside the EU depending on their role, activities and connection with the EU market. The European Commission provides detailed guidance on scope and application.

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When did the EU AI Act transparency obligations begin?

The Article 50 transparency obligations began applying on 2 August 2026, subject to the specific transitional arrangements described by the European Commission.

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Are Turkish AI legislative proposals already binding law?

No. A bill or proposal before the TBMM should be distinguished from legislation that has been enacted and entered into force.

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What should an AI contract contain?

Depending on the technology and transaction, it may need provisions dealing with data, confidentiality, intellectual property, permitted use, security, model changes, warranties, liability, indemnities, audit rights, regulatory compliance and termination.

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Why Businesses Need a Practical Approach to AI Law

Artificial intelligence does not fit neatly into one legal category.

A single AI project can touch data protection, intellectual property, commercial contracts, technology law, cybersecurity, employment, consumer protection, competition and international regulation.

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That is why a useful AI legal review should begin with the business and technology rather than with a generic checklist.

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At Kurucuk & Associates, we approach AI matters by first understanding the system, the commercial purpose and the parties involved. We then consider the legal issues that arise from that particular arrangement.

 

Our related practice areas include information technology law, personal data protection, cybercrime, intellectual property, commercial law, technology transactions and mergers and acquisitions.

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Official Sources for AI Regulation and Policy

Businesses monitoring AI developments can consult the institutions responsible for the relevant areas.

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Useful official sources include:

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• Personal Data Protection Authority (KVKK) — Turkish personal-data protection.

• Turkish Competition Authority — competition law and AI-related market developments.

• Turkish Grand National Assembly (TBMM) — legislative proposals and parliamentary developments.

• Ministry of Justice of Türkiye — justice and legal-system developments.

• Directorate General of Copyright — Turkish copyright matters.

• Turkish Patent and Trademark Office (TÜRKPATENT) — patents, trademarks and designs.

• European Commission — Artificial Intelligence — EU AI regulatory developments.

• EU AI Act Service Desk — practical information concerning the AI Act.

• OECD AI Principles — international AI principles.

• UNESCO Recommendation on the Ethics of AI — international ethical and human-rights framework.

 

These sources are particularly useful because AI regulation is developing quickly. Checking the current official position is preferable to relying on an old article, social-media post or general AI summary.

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AI Lawyer in Istanbul, Turkey

Kurucuk & Associates assists Turkish and international clients with legal matters involving artificial intelligence and emerging technology.

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Our work can include:

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• AI regulatory assessments;

• AI contracts;

• technology agreements;

• personal-data protection;

• international data-transfer issues;

• intellectual-property matters;

• confidentiality and trade secrets;

• AI governance policies;

• commercial transactions;

• technology due diligence;

• employment-related AI issues;

• consumer-facing AI systems;

• competition-law considerations; and

• AI-related disputes.

 

The appropriate legal strategy depends on the technology and circumstances. An AI chatbot used for customer service presents different issues from an AI recruitment platform, a generative-AI developer, an automated financial system or an AI-enabled medical technology.

 

The starting point is therefore the actual system, not the label attached to it.

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Kurucuk & Associates

Ağaoğlu Maslak 1453, Maslak Mahallesi, Taşyoncası Street, T4-B Block, Unit 195, -5th Floor, 34398 Sarıyer, Istanbul, Turkey

Telephone: +90 (212) 812 25 00
WhatsApp: +90 545 290 18 25
Email: info@kurucuk.com.tr