X: Platform Compliance with Legal Obligations¶

An examination of X’s (formerly Twitter) compliance journey reveals a gradual, albeit eventually complete, alignment with the structural mandates of Law No. 5651 and its secondary legislation. Regarding the fundamental pillars of compliance, specifically the appointment of a representative, the establishment of a resident capital company in Türkiye, and the satisfaction of capital requirements, X now exhibits the outward appearance of full adherence to the law.

The platform’s corporate evolution in Türkiye has mirrored the legislative tightening that began with Law No. 7253 in 2020 and intensified with Law No. 7418 in 2022. Initially, the local entity “Twitter İnternet İçerik Hizmetleri Limited Şirketi” was established on 22 April 2021 by the US-based T.I. Redwing LLC, with a modest capital of TRY 10.000, designating the founding company as the manager.⁶⁶

Following the platform’s global acquisition and rebranding to “X”, its legal structure in Türkiye underwent a radical transformation towards the end of 2023. T.I. Redwing LLC transferred its entire shareholding to X Corp., making the latter the sole direct shareholder and manager. Barry Murphy, a resident of Ireland, was individually authorised to act on behalf of the legal entity.⁶⁷

The final piece of the puzzle fell into place on 25 April 2024. To fully satisfy the stringent conditions regarding social media platforms, particularly regarding capital and trade names, the company title was amended to “X İstanbul İnternet İçerik Hizmetleri Limited Şirketi”. This change incorporated both the platform’s name and its province of operation. Simultaneously, the company’s capital was injected with funds to reach TRY 100.000.000, the legal minimum.⁶⁸ With these moves, X brought its Turkish representative office up to the final administrative and financial standards required by Law.

The Compliance Scorecard¶

While X has ticked the boxes for corporate structure, a deeper audit reveals significant voids. As illustrated in Table 7, serious deficiencies persist regarding user rights and transparency obligations.

The platform lacks a publicly available application form for Turkish users, and offers no information on how applications are processed. Furthermore, while transparency reports are published, their content falls woefully short of the statutory details. Critical areas remain entirely opaque: there is no public information regarding crisis plans, the ad library, hashtags liability, or processes for sharing information with judicial authorities. Similarly, it remains unknown whether obligations regarding data hosting and differentiated services for children have been met.

Consequently, X presents a weak profile in terms of accountability and legal oversight, complying with only a fraction of its substantive obligations.

Legal Obligations	Status	Notes
Representative Obligation	Meets	Official representative appointed in Türkiye.
Local Company Establishment	Meets	Istanbul-based capital company established.
Trade Name Condition	Meets	Trade name includes platform name and province.
Explicit Affiliation & Authorization	Meets	Company is directly affiliated with and authorised by X.
Turnover & Reporting Obligation	Unknown	No public information regarding report submission to BTK.
Application Form for Users	Does Not Meet	No Turkish application page established by X.
User Application Processes	Unknown	No public information regarding the application process.
Transparency Reports	Partially Meets	Reports are published but content is incomplete.
Personal Data Localisation	Does Not Meet	Not specified in transparency reports whether user data is hosted on servers in Türkiye.
Hashtag and Content Liability	Unknown	Unclear whether the notification system meets legal conditions.
Creating a Crisis Plan	Unknown	No public information regarding a crisis plan.
Providing Information to Judicial Authorities	Unknown	No statistics regarding data sharing with judicial authorities.
Ad Library	Does Not Meet	Ad library is not visible.
Bandwidth Throttling Sanctions	Not Applied	Not applied to date under Law No. 5651.
Administrative Fines	Unknown	No information regarding whether applied.
Other Obligations	Unknown	No publicly available information.

Table 7: X Platform Compliance Scorecard

Transparency Reports Assessment¶

X has maintained a schedule of regular publication for its transparency reports since the first half of 2021. A Turkish-language report is available for all nine periods examined.

Period	Turkish Report	Art. 9 Statistics	Art. 9/A Statistics	Categorical Data
2021-1	Yes	No	No	No
2021-2	Yes	No	No	No
2022-1	Yes	No	No	No
2022-2	Yes	No	No	No
2023-1	Yes	No	No	No
2023-2	Yes	No	No	No
2024-1	Yes	No	No	No
2024-2	Yes	No	No	No
2025-1	Yes	No	No	No

Table 8: Summary of X Platform Transparency Reports

However, in terms of substance, these reports are hollow. They fail to fulfil the specific obligations required under Supplemental Article 4/3 of Law No. 5651 and the relevant Procedures and Principles:

Article 9 Statistics: Data regarding applications made for violations of personal rights is absent.
Article 9/A Statistics: Data regarding applications made for violations of privacy is absent.
Categorical Data: There is a total lack of qualitative analysis, such as types of applications, conclusion times, and positive/negative response rates.

This indicates that X treats transparency reporting as a mere formality. By stripping the reports of meaningful data, the platform fails to be accountable or to inform the public, rendering the exercise largely performative.

Turkish Trade Registry Gazette, No. 10315, 22.04.2021, p. 967. ↩
For share transfer and authorization processes, see Turkish Trade Registry Gazette, No. 10950, 03.11.2023, p. 111; No. 10965, 24.11.2023, p. 271; No. 10968, 29.11.2023, p. 1029. ↩
Turkish Trade Registry Gazette, No. 11069, 25.04.2024, p. 1248. ↩