Skip to content

RTÜK and Access Blocking Practices

Article 82 of Law No. 7103 added to Law No. 6112 on the Establishment of Radio and Television Enterprises and Their Broadcasting Services a new Article 29/A, entitled “Presentation of Broadcasting Services via the Internet”, on 21.03.2018. The related Regulation on the Provision of Radio, Television and On-Demand Broadcasts via the Internet was published in the Official Gazette no 30849 and entered into force on 01.08.2019. As discussed below, the Regulation was updated and expanded twice in 2024.

RTÜK has been equipped under Article 29/A with the authority to apply content-removal and access-blocking sanctions to unlicensed broadcasts on the Internet. Under that provision, where RTÜK identifies an Internet broadcast by persons or entities that hold no provisional broadcasting right or broadcasting licence, or whose rights have subsequently been revoked, the Supreme Council may request from a criminal judge of peace the removal of the content in question and/or the blocking of access to the broadcast. These decisions are taken within twenty-four hours without a hearing, and are enforced through BTK.

Article 29/A covers not only domestic broadcasters but also overseas-based media service providers. Where a broadcast is directed at Türkiye and contains commercial communication elements directed at the Turkish market, it can be brought within the scope of access blocking even if its broadcast language is not Turkish. In such cases, overseas media organisations wishing to broadcast into Türkiye are also required to obtain a licence and/or broadcast transmission authorisation from RTÜK.

Through this provision, RTÜK has established a comprehensive digital censorship and licensing mechanism not only over content producers but also over content carriers and overseas-based broadcasters. Aligned with the 2024 amendments to the Regulation, the provision in particular subjects digital broadcasting within national borders to a regime of strict oversight and pressure.

The Expansion of RTÜK’s Licensing, Oversight and Censorship Mechanisms

Articles 5 and 7 of the Regulation on the Provision of Radio, Television and On-Demand Broadcasts via the Internet vest RTÜK with comprehensive licensing and oversight authority over media service providers and platform operators broadcasting on the Internet. With the amendments made in 2024 in particular, this regime has assumed a stricter and more interventionist character.

Article 5 of the Regulation expressly provides for a licensing requirement both for organisations holding a traditional broadcasting right and for media service providers broadcasting solely in the digital environment. Licensed broadcasters in terrestrial, satellite or cable media may make the same content available on the Internet, but those broadcasts are also brought within the scope of licensing.196 Organisations wishing to broadcast solely via the Internet must, for their part, obtain a separate licence from RTÜK.197 In this context, three types of Internet broadcasting licence are defined: INTERNET-RD (internet radio), INTERNET-TV (internet television), and INTERNET-İBYH (internet on-demand broadcasting service).198 It is also provided that each media service provider may offer only one radio, one television and one on-demand broadcasting service, and that a separate licence must be obtained for each.199 In its present form, this arrangement leads to the technical narrowing of content production and weakens pluralism. Similarly, platform operators that carry broadcasts over the Internet are required to obtain a broadcast transmission authorisation from RTÜK.200 Article 5/8 of the Regulation also makes it possible to bring all organisations broadcasting from outside Türkiye in Turkish, or directed at Türkiye, within the scope of this obligation, thereby subjecting international digital broadcasters to oversight as well. Accordingly, this licensing system establishes a freedom-restrictive regime that seeks to register and oversee digital broadcasting in a multifaceted way, on technical, geographical and content-based axes.

The Licensing Process as a Bureaucratic Barrier and Sanction Mechanism

Article 7 of the Regulation imposes strict institutional conditions on organisations wishing to obtain a licence to broadcast via the Internet. Accordingly, a licence is granted only to joint-stock companies established under the Turkish Commercial Code.201 This in effect prevents individual initiatives and alternative legal structures from entering media activities. The application process, supported by extensive documentation such as articles of association, financial declarations, management information, logo and trademark certificates, has been turned into a bureaucratic barrier.202 Moreover, organisations broadcasting under licence via terrestrial or satellite means are also required to obtain a separate licence for the Internet environment.203

The most striking amendment introduced in 2024 is the obligation, for organisations that declare at the time of application that they have already commenced broadcasting, to pay the three-month licensing fee in advance and to submit an undertaking.204 Otherwise, RTÜK may request the criminal judgeship of peace, under Article 29/A of Law No. 6112, to order the removal of content and/or the blocking of access, and may further file a criminal complaint against the relevant managers. This arrangement creates a serious chilling effect, particularly for independent and small-scale broadcasters, and makes it possible to bring freedom of expression under control through administrative and criminal sanctions. The licensing process ceases to be merely a tool of registration and regulation, and at the same time acquires the function of a censorship and political-pressure mechanism that directly threatens pluralism.

Articles 5 and 8 of the Regulation have introduced a two-sided licensing regime that covers not only the media service providers producing content but also the digital platform operators that transmit that content. Organisations holding broadcasting rights in traditional media such as terrestrial, satellite or cable can continue their broadcasts on the Internet. However, that does not remove the need for a separate licence. Organisations wishing to broadcast solely via the Internet must obtain a radio (INTERNET-RD), television (INTERNET-TV) or on-demand broadcasting (INTERNET-IBYH) licence from RTÜK. Likewise, platform operators that carry the transmission of broadcasts on the Internet are required to obtain a broadcast transmission authorisation from RTÜK. Platforms such as BluTV/Max, Exxen, PuhuTV, Gain, S Sport Plus, Netflix and Spotify all fall within the scope of this regime. The obligation to obtain a licence has also been imposed on platforms supplying Turkish-language content from abroad directed at Türkiye. RTÜK thus exercises regulatory and punitive authority not only over content, but also over transmission infrastructures.

Articles 10 and 11 of the Regulation operate a three-month “licensing-under-threat” procedure against content providers and platforms that broadcast without a licence, after which they activate direct censorship and criminal sanctions.205 Under Article 10, RTÜK identifies, either ex officio or upon complaint, the media service providers broadcasting without a licence, and notifies them that they may broadcast under a “provisional permit” for up to three months by applying for a broadcasting licence. This practice is, however, not the granting of a right, but plainly the practice of “allowing time accompanied by a threat to obtain a licence”. Applicants must submit an undertaking and pay the three-month licensing fee in advance. If the licensing process is not completed, an additional three months may be granted on the same conditions. If a licence is not obtained at the end of these periods, or no application is made at all, RTÜK requests, under Article 29/A of Law No. 6112, a content-removal and access-blocking decision from the criminal judgeship of peace, and at the same time files a criminal complaint against the relevant natural and legal persons. These decisions operate not merely as a technical regulation, but as an administrative and criminal threat against freedom of expression.

These provisions form the principal pillar of an authoritarian control system operating on the logic of “licence first, freedom of expression later” in the field of Internet broadcasting. RTÜK treats unlicensed broadcasts not only from a regulatory but also from a punitive perspective, and systematises access blocking as a censorship tool.

RTÜK’s Economic Censorship Mechanism: Licensing Fees and the 2025 Tariff

RTÜK’s licensing regime is not confined to content regulation; it also involves significant financial obligations and economic barriers. As of 2025 the applicable licensing and authorisation fees impose considerable costs of entry into the digital broadcasting field: INTERNET-RD licence (radio): TRY 92.622 (10-year); INTERNET-TV and INTERNET-İBYH licence (television and on-demand): TRY 926.214 (10-year); broadcast transmission authorisation (for platforms): TRY 926.214 (annual).

The requirement to submit a bank guarantee letter for instalment payments creates an additional deterrent burden for small-scale broadcasters, while the yearly increase in fees in line with the revaluation rate further undermines sustainability. Through these arrangements, RTÜK turns licensing into an economic censorship mechanism. This regime places broadcasters under financial obligations while at the same time creating a one-sided collection mechanism by restricting their right to a refund.206 In particular, the fact that licensing fees are in no circumstances refunded when licences are cancelled by RTÜK ex officio amounts to a deterrent punitive practice for broadcasters. An exceptional refund is possible only on grounds falling within RTÜK’s discretion.

Internet broadcasting licences are granted for a period of ten years,207 but the provision that, at the end of that period, the licence may only be renewed in accordance with a schedule and content-compliance assessment determined by RTÜK turns the regime into a control mechanism that subjects freedom of expression to a temporal limit and to administrative approval. Moreover, the fact that RTÜK imposes financial obligations not only on content providers but also on technical platforms208 undermines independence at the infrastructure level of digital broadcasting as well. As of 2025 the annual broadcast transmission authorisation fee has been raised to TRY 926.214, and for instalment payments a one-year bank guarantee letter is required. These conditions in effect close off entry into the digital sphere, particularly for small and new initiatives. Furthermore, RTÜK continues to collect fees even where the authorisation is cancelled, and refunds are made only on a pro rata basis after a written application and approval.

These structures, beyond their technical and content-production dimensions, also bring the field of digital transmission directly under surveillance and oversight, generating an environment of economic and structural censorship in the digital media ecosystem. With Article 15/A, which entered into force in 2024, RTÜK has also established a direct economic intervention mechanism over digital broadcasting services provided through conditional access systems. Under that provision, all media service providers and digital platforms that offer content on a subscription or pay-per-use basis are now obliged to transfer 1,5% of their net sales to RTÜK. This is not merely a “levy” but a direct revenue-sharing regime. Moreover, RTÜK retains the power to verify the accuracy of revenue declarations and to examine financial documents. Earnings in the digital media sector are thus tied to the economic partnership of the public authority. This significantly heightens the sustainability risk, particularly for low-income, independent media initiatives.

Article 16, on parallel terms, builds an extensive surveillance regime directed at media service providers. Broadcasters are confronted with multilayered obligations ranging from the sharing of technical equipment to the archiving of broadcast recordings and making them available to RTÜK inspection. In particular, RTÜK’s requirement that programmes that have been the subject of content infringements be removed from the catalogue, and that broadcast-suspension or licence-cancellation decisions be extended to all of the broadcaster’s transmission channels, subjects freedom of expression to extensive administrative oversight.

Considered together, these two provisions make clear that RTÜK has brought directly under its control not only broadcast content but also the economic resources and technical infrastructure of broadcasting, building a multi-axis pressure regime through content, economy and technology.

In addition to content producers, RTÜK has also brought platforms that transmit digital content within the scope of direct regulation, surrounding the communications infrastructure with a multi-faceted intervention regime.209 Article 17 regulates the obligations of Internet broadcasting platform operators along three principal axes:

  • Administrative and technical oversight: Platforms are required to provide continuous information to RTÜK, to report the numbers of users of their encrypted content, and to enable RTÜK’s remote access to broadcasts. This makes it imperative that even the technical infrastructure be opened up to regulation, and carries content oversight to a technical level.

  • Indirect censorship mechanism: Platforms may not transmit content that RTÜK deems to be unlicensed. They are also required to intervene against broadcasts originating from abroad that RTÜK deems to be objectionable. This creates an indirect power of censorship over content and turns platforms into regulatory actors in their own right.

  • Financial oversight: Platforms holding a conditional access system are required to transfer 1,5% of their net sales to RTÜK and to submit for approval the fee tariffs they will charge media service providers. Not only technical but also economic independence is thus seriously constrained.

All these obligations compel digital platforms to act as extensions of RTÜK rather than as independent commercial actors, structurally weakening the principles of freedom, competition and pluralism in the digital field.

In parallel, Article 18 elaborates RTÜK’s licence-cancellation power, one of its most severe oversight tools, and grants the authority a wide margin of discretion. This structure operationalises media licensing not only as a regulatory but also as a direct censorship tool. It institutionalises the continuous surveillance of broadcasters and the practice of self-censorship. Through these provisions, the field of digital broadcasting has been brought under technical, economic and political control, and freedom of expression has been made conditional on administrative approval.

The strictest and most punitive dimension of RTÜK’s oversight authority in the field of digital broadcasting takes shape, as noted above, in Article 19 of the Regulation alongside Article 29/A of Law No. 6112. This provision turns the processes of direct content removal and access blocking into a multilayered sanction system reaching as far as criminal investigation, rather than merely an administrative arrangement:

  • First stage, detection of breach and the warning process (Article 19(1)): When RTÜK determines (either ex officio or upon complaint) that a broadcasting service is contrary to the provisions of the Regulation, the provisions of Article 10 are first applied to offer the organisation the opportunity to apply for and complete the licensing process.

  • Second stage, direct access blocking and criminal complaint in cases of unlicensed broadcasting (Article 19(2)): If an organisation whose licence has previously been cancelled continues to broadcast, RTÜK now bypasses the warning process and directly requests the criminal judgeship of peace for the removal of content and/or the blocking of access. At the same time, it lodges a criminal complaint against the legal person and its managers with the Chief Public Prosecutor’s Office under Article 33 of Law No. 6112.

  • Third stage, site-wide access blocking (Article 19(3)): Where possible, access blocking is to be applied only to a specific URL, section or broadcast. In cases of technical impossibility or insufficiency, however, an access-blocking decision covering the entire website may be issued.

  • Fourth stage, administrative fines for non-compliance (Article 19(4)): Where court decisions are not implemented, administrative fines are imposed on access providers and content/hosting providers under Article 8/A of Law No. 5651.

This process transforms RTÜK’s administrative oversight in the field of digital broadcasting into a closed-circuit censorship system that combines direct criminal investigation, access blocking and economic sanction. In particular, for broadcasters that continue to produce content after their licences have been cancelled, “complete silencing” is pursued through both digital and criminal means. The application of Article 19 clearly shows that the right of access to digital content is bound by mechanisms of administrative compliance and political discretion. In other words, it brings about the systematic suppression of freedom of expression not only at the content level but also at the level of access. In sum, RTÜK’s licensing policy seeks to subjugate freedom of expression in Internet broadcasting through a combination of bureaucratic restriction and criminal threat.

RTÜK Access Blocking Practices: Annual Practice

After the provisions of the Regulation entered into force on 01.09.2019, RTÜK began, in March 2020, sending warnings and notices to sites it had identified as broadcasting radio and television via the Internet. Accordingly, RTÜK warned, in batches that the websites and platforms in question would be blocked from access if they continued to act in breach of Article 29/A: 5 different websites and platforms, including the Amazon Prime video-sharing platform, on 31.03.2020;210 8 different websites and platforms on 20.04.2020;211 5 different websites and platforms on 22.06.2020;212 2 different radio sites on 28.09.2020;213 6 different websites and platforms, including the globally renowned music platforms Tidal and Deezer, on 09.11.2020;214 and 4 different radio sites on 23.12.2020,215 amounting in total to 30 different websites or platforms. The Tidal platform, which did not comply with this warning, was blocked from access on 24.11.2020 upon RTÜK’s request by the Ankara 7th Criminal Judgeship of Peace.216 The Judgeship’s decision merely stated that “it being understood that unlicensed broadcasts have been made contrary to Article 29/A of Law No. 6112, the request is granted.” Upon Tidal’s notification that it would apply for a licence to RTÜK and its declaration that it had paid the three-month licensing fee, RTÜK objected to the decision of the Ankara 7th Criminal Judgeship of Peace; the objection was upheld by the Ankara 8th Criminal Judgeship of Peace.217 In this process the Tidal platform remained blocked from access until 19.12.2020. The ozguruz20.org website was also blocked from access upon RTÜK’s request by the Ankara 4th Criminal Judgeship of Peace on 12.06.2020.218

In 2021, upon requests from RTÜK, access was blocked under Article 29/A of Law No. 6112 to 29 different websites by decisions of the Ankara 1st, 2nd, 3rd, 4th, 7th and 8th Criminal Judgeships of Peace. The websites blocked were generally sites broadcasting live radio and/or television without a licence from RTÜK. As in 2020, no well-known platforms were blocked from access.

In 2022, upon requests from RTÜK, access was blocked under Article 29/A of Law No. 6112 to 29 different websites by decisions of the Ankara 1st, 2nd, 4th, 5th, 6th, 7th, 8th, 9th and 10th Criminal Judgeships of Peace. The websites blocked were generally sites broadcasting live radio and/or television without a licence from RTÜK. On 30.06.2022, however, access was also blocked under Article 29/A to the Voice of America and Deutsche Welle (“DW”) news websites upon RTÜK’s request. Whereas RTÜK had previously refrained from exercising its authority in relation to news websites, on 21.02.2022 it announced that Voice of America, DW and EuroNews Türkiye (tr.euronews.com) could apply, under Article 10 of the Regulation, for an INTERNET-IBYH licence in respect of their broadcasting activities via the Internet. It further announced that, if this call were not complied with, RTÜK would, within 72 hours, request the criminal judgeship of peace, under Article 29/A, to order the removal of content and/or the blocking of access.

Voice of America and DW Blocked from Access
Screenshot 51: Voice of America and DW Blocked from Access

EuroNews Türkiye brought its website into line with RTÜK’s demands, while the Voice of America and DW news websites were not interfered with from the expiry of the 72-hour period on 24.02.2022 until 30.06.2022. The whole of the Voice of America Turkish news site and of the DW news site219 was, however, blocked en bloc by decisions of the Ankara 1st Criminal Judgeship of Peace.220 In its public announcement of 01.07.2022,221 RTÜK stated that, because the Voice of America and DW news websites contained “audio” and “video” tabs under their “all media content” tabs, and because those contents were categorised programme-by-programme under the “programmes” tab and presented in catalogue form, those sites were conducting an on-demand broadcasting service activity, and that they were required to obtain an Internet IBYH licence.

The objections lodged on 07.07.2022 separately by two users of the new websites against each decision were rejected by decisions of the Ankara 2nd Criminal Judgeship of Peace, 2022/9721, 30.06.2022, and 2022/9557, 29.07.2022; both unreasoned, template decisions stated that there was “no impropriety” in the decisions of the Ankara 1st Criminal Judgeship of Peace. Individual applications were then lodged with the Constitutional Court against these final decisions; both applications were declared inadmissible ratione personae.222 Applications were accordingly lodged with the ECtHR, and they remain pending before that Court.

In 2023, upon requests from RTÜK, access was blocked under Article 29/A of Law No. 6112 to 56 different websites by decisions of the Ankara 1st, 2nd, 3rd, 5th, 6th, 7th, 8th, 9th and 10th Criminal Judgeships of Peace. The websites blocked were generally sites broadcasting live radio and/or television without a licence from RTÜK. The websites blocked at RTÜK’s request in 2023, however, also included alternative domain names of the Voice of America and Deutsche Welle (“DW”) news websites. Accordingly, access to the voaturkce.com domain belonging to the Voice of America news website was blocked on 08.09.2023 by the Ankara 9th Criminal Judgeship of Peace at RTÜK’s request.223 Similarly, access to the inspiredminds.de and dwturkce.com domains belonging to Deutsche Welle was blocked on 17.11.2023 by the Ankara 9th Criminal Judgeship of Peace at RTÜK’s request.224

In 2024, upon requests from RTÜK, access was blocked under Article 29/A of Law No. 6112 to 57 different websites by decisions of the Ankara 1st, 2nd, 3rd, 4th, 5th, 6th, 7th, 8th, 9th and 10th Criminal Judgeships of Peace. The websites blocked were generally sites broadcasting live radio and/or television without a licence from RTÜK. In addition to domain blockings, access was blocked by criminal judgeship of peace decisions to 12 different mobile applications. This shows that the scope of RTÜK’s oversight has expanded beyond websites to reach application stores.

The year 2025 yields comprehensive data showing that RTÜK has passed into a new phase in both its warning and its access-blocking activities. In 2025 RTÜK applied access-blocking measures under Article 29/A of Law No. 6112 to 37 different domain names by decisions of the Ankara Criminal Judgeships of Peace. The domains blocked range from small-scale sites broadcasting radio and television to radio-listening platforms. In addition to domain blockings, access was blocked by criminal judgeship of peace decisions to 14 different mobile applications.

In 2025 RTÜK sent warnings in respect of a total of 132 different addresses. The breakdown of these warnings clearly reflects the structural transformation in RTÜK’s scope of oversight: warnings were issued in respect of 93 domains, 30 mobile applications, 7 YouTube channels and 2 URLs. Warnings directed at YouTube channels in particular constitute a new category that appeared for the first time in 2025 and that demonstrates a paradigm shift in RTÜK’s oversight strategy. Whereas in the 2020–2024 period no YouTube channel had been the subject of a warning, in 2025 7 YouTube channels were brought within the scope of a warning. These channels include Cumhuriyet TV (06.01.2025), Flu TV (09.04.2025), Fatih Altaylı (23.06.2025), Basın Kulübü (29.09.2025), BirGün TV (24.10.2025), Balıkesir Posta (06.11.2025) and taffpics (06.11.2025).

YouTube Channels Brought Within the Scope of an RTÜK Warning
Screenshot 52: YouTube Channels Brought Within the Scope of an RTÜK Warning

A further notable development in 2025 was the reassessment of the domain names belonging to the Deutsche Welle news website that had previously been blocked en bloc following RTÜK’s assessment of non-compliance with the licensing obligation. In a fresh assessment by the RTÜK Monitoring and Evaluation Department, it was determined that the DW domains contained only audio-visual news content within the scope of journalistic activity, and that the content previously found to be objectionable had been removed. As a result of this assessment, the access blockings on dw.com, inspiredminds.de and dwturkce.com were lifted in June 2025.225

The Cumhuriyet TV YouTube Channel: A Precedent-Setting Decision and Internal Dissent

The Cumhuriyet TV case is a precedent-setting decision that exposes most comprehensively the legal and political dimensions of the process by which RTÜK has brought YouTube channels within the scope of licensing. By Decision No 9 taken at its Meeting No 2024/50 of 27.12.2024, RTÜK determined that a broadcasting service was being provided at the address youtube.com/@CumhuriyetTVtr, and announced that an application for a licence had to be submitted within 72 hours. This was the first decision in which RTÜK imposed a licensing obligation on a content producer hosted on a social media platform.

Following this decision, Mayıs 1924 Haber Ajansı ve Yayıncılık A.Ş., the owner of the Cumhuriyet daily, applied for an Internet-IBYH broadcasting licence on 09.01.2025, submitted an undertaking, and paid the three-month licensing fee on 08.01.2025. By Decision No 1 taken at its Meeting No 2025/04 of 22.01.2025, RTÜK notified the organisation that it could continue its broadcasts for three months from the date of application, but warned that if the licensing process were not completed at the end of that period, legal proceedings would be initiated under Articles 29/A and 33 of Law No. 6112. This process is a concrete application of the “licensing-under-threat” mechanism in Article 10 of the Regulation.

The most striking dimension of the decision is the dissenting opinion authored by Supreme Council member Dr Necdet İpekyüz.226 Dr İpekyüz systematically demonstrated that the decision violates multiple principles of law. First, he emphasised that the decision was “the first decision making it obligatory for broadcasters publicly known as ‘content creators’, present on social media sharing platforms, to obtain a licence”. He stated that this precedent decision paved the way for all social media platforms beyond YouTube, including Facebook, X, Instagram and TikTok, to come under RTÜK oversight, that it could “turn millions of social media users into broadcasters licensed by the Council itself”, and that “such a development would lead to the Internet being placed entirely under the Council’s oversight”. Secondly, he stated that the decision was contrary to the principle of equality, and that targeting Cumhuriyet TV (a channel with 553.000 subscribers that does not even rank among the top 100 most-followed channels in Türkiye) revealed “that the real aim of the decision is not to regulate broadcasts, but to increase censorship directed at press organisations”. Thirdly, he stated that the Cumhuriyet TV YouTube channel consisted “of videos of the news items shared by the newspaper”, that it was “not part of a regular broadcasting flow and pursued no broadcasting purpose”, and that RTÜK was thereby “bringing under its supervision an institution whose principal purpose is ‘press and journalism’”, and that the Council was without jurisdiction in respect of the matter to which the decision related. Finally, he stressed that it was clear that the law conferred no power to oversee social media platforms, and argued that imposing a licensing obligation on YouTube would be “unlawful in terms of jurisdiction”.

The decision was adopted by a majority of 6 to 3, with the dissenting votes of Supreme Council members Dr Necdet İpekyüz, Tuncay Keser and İlhan Taşcı. That three of RTÜK’s own members recorded dissents shows that the decision is considered contested even within the institution and that its legal legitimacy is being questioned. Dr İpekyüz’s use, in his dissent, of the expression that with this step RTÜK would “openly turn into a censorship board” constitutes a strong voice of internal dissent rising from within the institution itself. Moreover, this decision and other similar decisions taken in 2025 are not published on the RTÜK website and are kept from public view.

In the continuation of this process, by Decision No 1 taken at its Meeting No 2025/29 of 24.07.2025, RTÜK, following the prior notice and provisional-period mechanism, completed the licensing process and decided to grant Mayıs 1924 Haber Ajansı ve Yayıncılık A.Ş. an Internet-IBYH broadcasting licence.227 In the decision, reached after examination of letter no 113659 dated 16.07.2025 of the Department of Permits and Allocations and its annexes, it was established that the organisation had submitted the information and documents required under Article 29/A of Law No. 6112 and the relevant provisions of the Regulation, had paid the first instalment of the licensing fee, and had submitted a definitive bank guarantee letter for the remaining amount. On that basis, it was decided to grant a 10-year broadcasting licence to the organisation, identified by the “CTV” logo, with effect from the application date of 09.01.2025. The decision was, however, adopted by a majority vote with the dissents of Supreme Council members Dr Necdet İpekyüz, Tuncay Keser and İlhan Taşcı. Legal and principled objections continued, accordingly, even at the licence-granting stage. This shows that the dispute, at the level of internal institutional opposition, is not only over the licensing process itself but also over RTÜK’s expanding interpretation of its authority in relation to Internet broadcasting.

These developments demonstrate that RTÜK’s licensing regime now targets not only digital platforms and small radio/TV sites but also the digital broadcasting extensions of newspapers and the YouTube channels of individual journalists. The targeting of digital channels of organisations on the opposition press line, such as the Cumhuriyet and BirGün dailies, raises the question whether RTÜK is applying the licensing regime selectively. The notice directed at the personal YouTube channel of journalist Fatih Altaylı, for its part, shows that the field of RTÜK’s oversight extends as far as individual journalistic activity.

In terms of mobile-application blockings, 2025 has also shown a marked increase. Application warnings, which numbered 19 in 2023 and 12 in 2024, rose in 2025 to 30; 14 of these applications were in fact blocked from access by decisions of the criminal judgeships of peace. The blocked applications also include the mobile applications of international radio platforms such as TuneIn and myTuner Radio. RTÜK’s grant on 16.06.2025 of a further 72-hour period to the TuneIn and KeepOne platforms, which were already blocked from access via their websites, is a Kafkaesque practice showing that the licensing process has been wholly severed from its function as a regulatory tool: as of the date of notification, TuneIn had already been blocked from access in Türkiye for 2.784 days, and KeepOne for 425 days.

Platforms Brought Within the Scope of an RTÜK Warning
Screenshot 53: Platforms Brought Within the Scope of an RTÜK Warning

As to the overall figures for the entire 2020–2025 period:

2020 2021 2022 2023 2024 2025 Total
Warnings 26 60 71 143 87 132 519
Domain blockings 4 26 29 60 57 38 214
Application warnings 0 0 0 19 12 30 61
Application blockings 0 0 0 0 12 14 26
YouTube channel warnings 0 0 0 0 0 7 7
YouTube channel blockings 0 0 0 0 0 0 0
Table 1: RTÜK Broadcasting Licence Warnings and Blockings of Domains, Applications and YouTube Channels (2020–2025)

The most striking finding of this table is that the scope of RTÜK’s sanctions has expanded over the years both quantitatively and categorically. While in 2020 only domain names were targeted, in 2023 mobile applications, and in 2025 YouTube channels were added to the scope of oversight. In the 2020–2025 period RTÜK warned in total 519 different broadcast organisations, platforms, applications and YouTube channels; 214 websites and domain names, and 26 mobile applications were blocked from access. These data show that RTÜK’s oversight and censorship mechanism in the digital field has expanded each year by adding new categories, and that the concept of “unlicensed broadcasting” is in practice being interpreted to cover all forms of digital audio-visual content production.

RTÜK’s Content Sanctions Against Digital Platforms: General Assessment and 2025 Analysis

General Assessment: The Systematic Structure of Content Oversight (2020–2025)

RTÜK’s content sanctions directed at digital platforms have followed a curve of systematic intensification since 2020. The Supreme Council, instrumentalising the broadcasting-principles provisions of Law No. 6112 and the oversight framework of the Internet Regulation, has subjected digital platforms to a growing pressure regime. According to the data gathered by İFÖD, a total of 35 distinct content sanction decisions were identified from 2020 through January 2026. These decisions cover 11 different digital platforms, and the sanctions have observably grown heavier over the years in scope, intensity and character alike.

The yearly distribution of sanctions clearly reveals the gradual escalation in RTÜK’s digital content oversight. In 2020 and 2021, two sanction decisions were issued in each year, all of them in the form of removal from the catalogue. In this period RTÜK kept its interference with digital platforms at a relatively low profile, and had not yet activated the administrative fine mechanism. In 2022 the number of sanctions again remained at 2, but the decisions concerning Netflix and Spotify deepened the intervention in the platforms’ content catalogues. The true turning point came in 2023, when the number of sanctions rose to 8, and the practice of imposing administrative fines began for the first time. In that year, fines were imposed on different platforms such as Amazon Prime Video, Bein Movies Stars, BluTV, Disney+, MUBI and Netflix; LGBTIQ+ content and the discourse of “the moral values of society” formed the dominant motif of the grounds for these sanctions.

In 2024, five sanction decisions were issued, but the character of the sanctions sharpened markedly. In 4 of these decisions a fine was applied alongside removal from the catalogue, and RTÜK thereby institutionalised the policy of “dual sanction”. Of note in this period is the “pre-meeting” practice in relation to Netflix’s Famagusta series; before adopting a formal sanction decision, the Supreme Council exerted direct pressure on the platform to secure the voluntary removal of the content, and this should be regarded as a concrete indicator of RTÜK’s capacity to generate self-censorship.

The year 2025, for its part, has broken records both in number and in intensity. 12 separate sanction decisions were taken during the year, 11 of which were dual sanctions combining a fine with removal from the catalogue. The fact that 4 sanction decisions were taken in January 2026 alone signals that this trend will continue at an even faster pace.

Year Total Decisions Catalogue Removal Fine Only Dual Sanction
2020 2 2 0 0
2021 2 2 0 0
2022 2 1 0 1
2023 8 0 8 0
2024 5 0 1 4
2025 12 0 1 11
2026 (January) 4 0 1 3
Total 35 5 11 19
Table 2: Yearly Distribution of RTÜK Sanctions Against Digital Platforms

Platform-Based Distribution of Sanctions

Examined by platform, the distribution of sanction decisions shows that Netflix is by far the most-sanctioned platform. With a total of 13 sanction decisions, Netflix occupies the primary target position in RTÜK’s digital content oversight. Netflix is followed by Amazon Prime Video (4 decisions), MUBI (4 decisions), Spotify (3 decisions), Disney+ (3 decisions) and HBO Max (3 decisions). Bein Movies Stars, BluTV, TV+, Exxen and a combined MUBI & BluTV decision each appear in the table with a single sanction.

This distribution shows that RTÜK’s sanction policy is not confined to small and local platforms but is directly directed at globally-scaled digital broadcasters. The systematic sanctions targeting platforms such as Netflix, Amazon Prime Video and Disney+ in particular show that the international actors operating in Türkiye’s digital content market are being subjected to a content oversight framed by RTÜK’s discourse of “national and moral values”.

Platform Number of Sanctions Share of Total
Netflix 13 37,1%
Amazon Prime Video 4 11,4%
MUBI 4 11,4%
Spotify 3 8,6%
Disney+ 3 8,6%
HBO Max 3 8,6%
Others (5 platforms) 5 14,3%
Table 3: Platform-Based Distribution of RTÜK’s Content Sanctions Against Digital Platforms

Thematic Analysis of Sanction Grounds

Examined as to their grounds, RTÜK’s sanction decisions show that the Supreme Council applies a particular ideological framework systematically in its digital content oversight. An analysis of the grounds of 35 sanction decisions reveals the following thematic distribution:

  • The ground of breach of “general morality” and “the moral values of society” was used as the dominant ground in approximately 80% of the sanctions. Although these concepts appear in the broadcasting principles of Law No. 6112, their definitions are vague and open to RTÜK’s discretion. Determining the substance of the concepts of “general morality” and “moral values” is left wholly to the Supreme Council’s political and cultural preferences, which removes content oversight from an objective legal framework and turns it into an ideological filtering mechanism.

  • LGBTIQ+ themed content was the most intense target of RTÜK’s sanctions. In 10 of the 35 decisions (≈29%) homosexuality, LGBTIQ+ themed scenes, or the “non-recognition of the boundaries of gender” were expressly stated as direct grounds for the sanction. Among these are Netflix’s Elite, Anne+ and Cobalt Blue; Disney+’s Love, Victor and All of Us Strangers; HBO Max’s Looking: The Movie; MUBI’s Benedetta and Passages; Amazon Prime Video’s Those About To Die; and BluTV’s The Book of Queer. The sanctions directed at this type of content show that RTÜK systematically characterises LGBTIQ+ representation as “harmful to society” and forces digital platforms to remove such representations from their catalogues in Türkiye.

  • The ground of “obscenity” was used in 9 decisions (26%) and frequently overlaps with the LGBTIQ+ themed sanctions. Although RTÜK assesses heterosexual and same-sex relationship scenes under the same heading of “obscenity”, it is notable that LGBTIQ+ themed scenes are punished more heavily with additional characterisations such as “undermining gender roles” and “discrediting the institution of the family”.

  • The ground of violence was used in only 4 decisions (11%). The ground of political content was identified in only one decision (Netflix, Designated Survivor, 2020). This proportional distribution shows that RTÜK’s sanction priorities are focused on “social morality” and sexuality, while violent and political content is kept at a relatively low priority.

  • Another notable finding is the fines imposed in 2025 on the Konuşanlar programme on the Exxen platform and on the Aşkın Gücü competition programme on Amazon Prime Video. The Konuşanlar programme was sanctioned on the ground of “expressions exceeding the bounds of humour”; the Aşkın Gücü programme was sanctioned on the ground of “content that confines gender roles to rigid stereotypes and ensures the exclusion of women from decision-making processes”. The latter ground is one of the rare instances in which RTÜK has imposed a sanction by invoking gender-based discrimination. However, ironically, when considered alongside the Supreme Council’s decisions targeting LGBTIQ+ representation, it lays bare RTÜK’s inconsistency in its approach to “gender”.

2025 Detailed Analysis: The Concentration and Systematisation of Sanctions

The year 2025 has been the period in which RTÜK’s content sanctions against digital platforms peaked in both quantitative and qualitative terms. The 12 sanction decisions taken during the year surpass the totals of all preceding periods combined, and represent a 50% increase compared with the previous record of 8 decisions in 2023. Moreover, 11 of these 12 decisions are dual sanctions combining a fine with removal from the catalogue. This shows that in 2025 RTÜK has openly toughened its sanction policy and is applying pressure on platforms through a strategy of gradual escalation.

Date Platform Content Sanction Ground
June Netflix Barda Fine Violence and moral values
June Spotify Song lyrics Fine + removal Moral values, general morality
July TV+ Film (unidentified) Fine + removal Obscenity, general values
September Amazon Prime Video Those About To Die Fine + removal Violence, homosexuality
September Disney+ All of Us Strangers Fine + removal Homosexuality, family values
September HBO Max Looking: The Movie Fine + removal Homosexuality, obscenity
September MUBI Benedetta Fine + removal Obscenity, general morality
September Netflix Cobalt Blue Fine + removal Homosexuality, moral values
December HBO Max Jasmine S01E01 Fine + removal Moral values, general morality
December Netflix Too Hot to Handle: Italy Fine + removal Obscenity, distorted relationships
December Exxen Konuşanlar (Episode 44) Fine + removal Expressions exceeding the bounds of humour
December Amazon Prime Video Aşkın Gücü Fine + removal Gender discrimination
Table 4: Sanctions Imposed by RTÜK on Digital Platforms in 2025

The chronology of the 2025 sanctions can be examined in three waves. The first wave (June–July) targeted Netflix, Spotify and TV+, and made use of relatively traditional grounds such as violence, obscenity and “general morality”. The second wave (September), for its part, constituted RTÜK’s most comprehensive and coordinated intervention: at a single meeting, sanctions were imposed simultaneously on 5 different platforms (Amazon Prime Video, Disney+, HBO Max, MUBI, Netflix), in all of which LGBTIQ+ themed content was directly targeted. The third wave (December) closed the year with four further sanction decisions, in which the targets were diversified and humour programmes and competition formats also entered RTÜK’s oversight radar.

The September 2025 wave deserves particular analysis. RTÜK’s simultaneous imposition of sanctions on five different international platforms at the same meeting shows that content oversight has evolved from isolated reactions into a systematic coordinated pressure operation. The productions targeted in this wave are all cinematic films or series engaging LGBTIQ+ themes: Those About To Die (Amazon), All of Us Strangers (Disney+), Looking: The Movie (HBO Max), Benedetta (MUBI) and Cobalt Blue (Netflix). RTÜK used grounds such as “encouraging homosexuality”, “disregarding family values” and “undermining gender roles” in these decisions. This coordinated intervention openly demonstrates RTÜK’s will to suppress LGBTIQ+ representation systematically in the digital environment.

Also notable is the distribution of the eight different platforms sanctioned in 2025: Netflix continued to be the most-sanctioned platform with 3 decisions, followed by Amazon Prime Video and HBO Max with 2 decisions each. Disney+, MUBI, Spotify, TV+ and Exxen each appear in the picture with one decision. This wide range shows that RTÜK has not confined the scope of its sanctions to particular platforms, but is aiming to establish hegemonic oversight across the whole of the digital broadcasting field.

Content Sanctioned by RTÜK
Screenshot 54: Content Sanctioned by RTÜK

Legal Assessment: The Freedom of Expression Dimension of Content Sanctions

RTÜK’s content sanctions against digital platforms raise serious concerns under freedom of expression as guaranteed by Article 10 of the European Convention on Human Rights. According to the ECtHR’s case law, interferences with freedom of expression must meet the conditions of being “prescribed by law”, of pursuing a “legitimate aim” and of being “necessary in a democratic society”. The concepts to which RTÜK frequently resorts in its sanction grounds, such as “the moral values of society”, “general morality” and “the protection of the family”, although they appear in Law No. 6112, are not sufficiently definite in their content. This places in doubt whether the condition of being “prescribed by law” is satisfied.

The systematic sanctions directed at LGBTIQ+ themed content in particular conflict directly with the principles set out by the ECtHR in Bayev and Others v Russia.228 In that judgment the Court held that Russia’s “gay propaganda” law violated freedom of expression, and expressly determined that the characterisation by States of the expression of particular sexual orientations as “harmful to society” is incompatible with Articles 10 and 14 of the Convention. RTÜK’s simultaneous targeting of LGBTIQ+ themed content on five different platforms in the September 2025 wave amounts to a direct violation of that case law.

In addition, the indeterminacy of the grounds used by RTÜK in its sanction decisions also impairs the principle of foreseeability. The ground of “contravention of the national and moral values of society”, presenting no concrete content criterion, in effect creates an unlimited field of oversight. This leaves digital platforms in a permanent environment of uncertainty and triggers a self-censorship mechanism. Platforms are unable to foresee which content will be subjected to sanction and accordingly tend to remove proactively, from their catalogues in Türkiye, any content they consider potentially controversial.

In sum, RTÜK’s content sanctions in the 2020–2025 period have built a multilayered pressure system over digital platforms. By combining the mechanisms of economic sanction (fines), content intervention (removal from the catalogue) and institutional deterrence (the pressure of self-censorship), this system structurally restricts freedom of expression in the digital media ecosystem in Türkiye. The record number of sanctions in 2025, and especially the coordinated intervention in September, openly demonstrate that RTÜK is now aiming not at isolated content infringements but at the systematic suppression of particular forms of representation.

  1. Regulation on the Provision of Radio, Television and On-Demand Broadcasts via the Internet, art 5/1. ↩

  2. Ibid, art 5/2. ↩

  3. Ibid, art 5/3. ↩

  4. Ibid, art 5/4-5. ↩

  5. Ibid, art 5/6-7. ↩

  6. Ibid, art 7/1. ↩

  7. Ibid, art 7/2-3. ↩

  8. Ibid, art 7/5. ↩

  9. Ibid, art 7/6. ↩

  10. Relevant persons or entities may continue their broadcasts within this period by submitting an undertaking and paying the three-month licensing fee in advance (Article 10(1)(a)). If the licensing process is not completed at the end of that period, an additional three months may be granted (Article 10(1)(b)). If at the end of these periods no licence is obtained or no application has been made, RTÜK requests from the criminal judgeship of peace, under Article 29/A of Law No. 6112, a content-removal and access-blocking decision; it also initiates criminal proceedings under Article 33 (Article 10(1)(c)). ↩

  11. Regulation on the Provision of Radio, Television and On-Demand Broadcasts via the Internet, art 13. ↩

  12. Ibid, art 14. ↩

  13. Ibid, art 15. ↩

  14. Ibid, art 17. ↩

  15. https://biattv.com/canli-tv-izle, https://canlitv.com/biattv, https://slowkaradeniztv.com, https://www.primevideo.com, https://www.dsmartgo.com.tr. ↩

  16. Eight sites including https://canlitv.com, https://canlitv.com/berk-tv, http://www.berktv.com, http://www.fuartv.net/, https://canlitv.com/fuar-tv, http://www.guneydogutv.com, https://canlitv.com/guneydogu-tv, https://broadcasttr.com/gtv. ↩

  17. Five sites including https://cine5tv.com, http://sinopyildiz.tv/, http://www.arastv.net/v1/, http://www.kanal58.com.tr, https://mubi.com/tr. ↩

  18. https://www.radyosfer.com and https://www.radyogram.com. ↩

  19. Six sites including https://serikajanstv.com/, https://www.enbursa.com/, https://www.kent19.tv/, https://www.tidal.com, https://www.deezer.com, https://www.radiokent.net. ↩

  20. https://canliradyodinle.gen.tr, https://www.canli-radyo.biz, https://onlineradiobox.com/tr and https://canliradyodinle.fm. ↩

  21. Ankara 7th Criminal Judgeship of Peace, 2020/8108, 24.11.2020. ↩

  22. Ankara 8th Criminal Judgeship of Peace, 2020/9654, 18.12.2020. ↩

  23. Ankara 4th Criminal Judgeship of Peace, 2020/3757, 12.06.2020. ↩

  24. Access was blocked not only to the Turkish-language pages of the DW website, but to the entirety of its news pages in 30 different languages. ↩

  25. Ankara 1st Criminal Judgeship of Peace, 2022/7982, 30.06.2022, blocked access to the Voice of America website (amerikaninsesi.com); Ankara 1st Criminal Judgeship of Peace, 2022/7978, 30.06.2022, blocked access to the Deutsche Welle website (dw.com). ↩

  26. See https://www.rtuk.gov.tr/kamuoyunun-dikkatine-/4346 ↩

  27. Constitutional Court, App No 2023/90100, 26.07.2024; Constitutional Court, App No 2022/87409, 24.12.2025. ↩

  28. Ankara 9th Criminal Judgeship of Peace, 2023/7546, 08.09.2023. ↩

  29. Ankara 9th Criminal Judgeship of Peace, 2023/9903 and 2023/9904, both 17.11.2023. ↩

  30. “RTÜK, DW Türkçe’nin sansürünü kaldırdı” (Bianet, 27 June 2025) https://bianet.org/haber/rtuk-dw-turkcenin-sansurunu-kaldirdi-308881 ↩

  31. Dissenting opinion of Dr Necdet İpekyüz, Member of the Supreme Council, dated 20.01.2025 (Meeting No 2024/50, Decision No 9). ↩

  32. RTÜK Supreme Council Decision (Meeting No 2025/29, Decision No 1) https://rtuk.gov.tr/UstKurulKarar/Detay/20543 ↩

  33. Bayev and Others v Russia App no 67667/09 (ECtHR, 20 June 2017). See also Klimova and Others v Russia App no 33421/16 (ECtHR, 4 February 2025). ↩