Meta: Facebook and Instagram

Meta (Facebook and Instagram) has fulfilled its primary obligation to appoint a representative by establishing a local capital company to conduct its operations in Türkiye. While its corporate footprint in the country is not new, it has undergone significant transformation to align with the stringent requirements of Law No. 7418.

Meta’s legal entity in Türkiye was originally established on 27 March 2014 by the US-based Madoka LLC under the title “Madoka Turkey Bilişim Hizmetleri Limited Şirketi”. Initially capitalised at TRY 10.000, this figure was gradually increased over the years, reaching TRY 1.776.400 by 2021.⁶⁹

However, the drive for full compliance gained critical momentum in 2023. On 14 April 2023, the company was re-registered as “Meta Platforms İstanbul Bilişim Hizmetleri Limited Şirketi”, and its capital was dramatically raised to TRY 100.000.000, meeting the new legal minimum.⁷⁰

Despite this, a nuance remains: the absence of distinctive, consumer-facing brand names like “Facebook” or “Instagram” in the company’s official title. This arguably falls short of the “distinctive phrase” condition mandated by the legislation. Furthermore, although Meta utilises a single legal entity for both platforms, it continues to publish separate transparency reports for Facebook and Instagram.

Steps have also been taken to clarify the corporate hierarchy. On 2 May 2023, Madoka LLC transferred all its shares to Facebook Global Holdings II LLC; shortly thereafter, on 5 June 2023, these shares were transferred to the ultimate parent company, Meta Platforms Inc. Consequently, Meta Platforms Inc. is now the direct manager and sole shareholder of the Turkish company, with Katherine Reynolds Kelly (resident in the USA) authorised to act on behalf of the legal entity.⁷¹

This evolution demonstrates a clear shift in the sense that Meta, which initially operated in Türkiye under the opaque “Madoka” banner, has assumed direct operational responsibility with its own corporate identity and capital as legal pressures have mounted.

Legal Obligations	Status	Notes
Representative Obligation	Meets	Official representative appointed in Türkiye.
Local Company Establishment	Meets	Istanbul-based capital company established.
Trade Name Condition	Partially Meets	Phrases “Facebook” or “Instagram” are not included in the company title (Meta Platforms İstanbul Bilişim Hizmetleri Limited Şirketi).
Explicit Affiliation & Authorization	Meets	Company is fully authorized and held responsible for Facebook and Instagram services by Meta Platforms Inc.
Turnover & Reporting Obligation	Unknown	No public information regarding report submission to BTK.
Application Form for Users	Meets	A Turkish application page created by Meta exists.
User Application Processes	Meets	Evaluation processes for applications and their relation to “Community Standards” are explained in reports.
Transparency Reports	Partially Meets	Reports are regular but Article 9 and 9/A data is presented generally without disaggregation.
Personal Data Localization	Does Not Meet	Not specified in transparency reports whether user data is hosted on servers in Türkiye.
Hashtag and Content Liability	Unknown	No mention of a procedure specific to hashtags in reports.
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	Meets	Meta Türkiye Ad Library is active and72 cited in reports.
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 9: Facebook and Instagram Platforms Compliance Scorecard

Facebook Transparency Reports Assessment

Facebook has maintained a regular reporting schedule since the commencement of its legal obligations. However, the data provided fails to meet the specific “statistical and categorical” breakdown required by Law No. 5651. Critically, Facebook pools applications under Article 9 (personal rights) and Article 9/A (privacy) into a single dataset, offering no separate statistics for these distinct legal grounds.

Period	Turkish Report	Art. 9 Statistics	Art. 9/A Statistics	Categorical Data	Notes
2021-1	Yes	No	No	No	Only June 2021 data (20 applications) reported.
2021-2	Yes	No	No	No	71 applications reported.
2022-1	Yes	No	No	No	314 applications reported.
2022-2	Yes	No	No	No	251 applications reported.
2023-1	Yes	No	No	No	227 applications reported.
2023-2	Yes	No	No	No	335 applications reported.
2024-1	Yes	No	No	No	203 applications reported.
2024-2	Yes	No	No	No	294 applications reported.
2025-1	Yes	No	No	No	298 applications reported.

Table 10: Summary of Facebook Platform Transparency Reports

Although these reports reveal Facebook’s general approach, the policy of data aggregation obfuscates the reality of legal compliance. By lumping Article 9 and 9/A requests together under the generic banner of “user requests under Law No. 5651”, it becomes impossible to analyse which type of violation is more prevalent or how the platform responds to specific legal claims.

Furthermore, the lack of categorical detail (crime type, content type, etc.) creates the impression that transparency is being treated as a tick-box exercise. While the reports do share detailed qualitative information regarding moderation teams, highlighting support for 80+ languages including Turkish, this text is pasted verbatim into every report, reducing its value.

A Critical Oversight: The Repealed Article 9

Regarding Article 9, which was repealed on 10 October 2024, the aggregated data makes it unclear whether Facebook updated its processes for late 2024 and early 2025. However, a review of Meta’s active corporate pages, specifically the “How do I contact Meta’s local representative in Türkiye?” page⁷³ and the associated removal request form,⁷⁴ reveals that reference is still made to the repealed Article 9 as of the preparation of this study.

Screenshot 1: Meta’s Page for Local Representative in Türkiye

Screenshot 2: Türkiye Legal Content Removal Request Form Under Law No. 5651

Consequently, it cannot be stated that the Facebook platform fully meets its obligations, either formally or in terms of content.

Instagram Transparency Reports Assessment

Unlike its sibling platform, Instagram failed to publish any transparency reports in 2021. Regular reporting commenced only in 2022. Like Facebook, Instagram presents Article 9 and 9/A data as an aggregated set, hindering detailed analysis.

Period	Turkish Report	Art. 9 Statistics	Art. 9/A Statistics	Categorical Data	Notes
2021-1	No	-	-	-	Report not published.
2021-2	No	-	-	-	Report not published.
2022-1	Yes	No	No	No	1.436 applications reported.
2022-2	Yes	No	No	No	1.454 applications reported.
2023-1	Yes	No	No	No	2.898 applications reported.
2023-2	Yes	No	No	No	2.397 applications reported.
2024-1	Yes	No	No	No	943 applications reported.
2024-2	Yes	No	No	No	303 applications reported.
2025-1	Yes	No	No	No	162 applications reported.

Table 11: Summary of Instagram Platform Transparency Reports

A closer look at the data reveals that users in Türkiye primarily utilise the application mechanism for “account/profile complaints”. For instance, in the second half of 2023, approximately 80% of applications (857 out of 1.064) related to profile complaints rather than specific content. This indicates that the legal mechanism intended for rights violations is largely being repurposed by users to report “fake/impersonating accounts”.⁷⁵

Most striking is the dramatic decline in application volume. From a peak of nearly 3.000 in early 2023, numbers collapsed to just 162 by early 2025. While unexplained in the report, this likely reflects users abandoning the channel due to a perceived lack of effectiveness, or the mass filtering of profile complaints.

Legally, Instagram’s 2025-1 report marks a divergence from Facebook. It explicitly acknowledges the Constitutional Court’s annulment of Article 9, stating that the form is now reserved for Article 9/A and other issues. This represents a more compliant stance. However, because the data remains aggregated, it is still impossible to distinguish which actions were taken on what specific grounds.

Meta has established a compliant corporate structure and reporting process. However, the data aggregation policy is a fundamental flaw. By pooling distinctly different legal claims (insult vs privacy), Meta renders its data obscure. This failure to disaggregate weakens the public oversight function of the reports and prevents any meaningful analysis of the platform’s impact on digital rights in Türkiye.

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69. For establishment and capital increases, see Turkish Trade Registry Gazette, No. 8541, 02.04.2014, p. 321; No. 9202, 21.11.2016, p. 341; No. 10290, 18.03.2021, p. 241. ↩

70. Turkish Trade Registry Gazette, No. 10812, 14.04.2023, p. 1290. ↩

71. For share transfers, see Turkish Trade Registry Gazette, No. 10822, 02.05.2023, p. 555; No. 10845, 05.06.2023, p. 571. ↩

72. See https://www.facebook.com/ads/library/. Also see Meta Ad Library Türkiye Report, https://www.facebook.com/ads/library/report/ ↩

73. See https://www.facebook.com/help/118930960130870 ↩

74. See https://www.facebook.com/help/contact/435015304579692 ↩

75. When the Türkiye Legal Content Removal Request Form Under Law No. 5651 is examined, it will be seen that the form is not limited only to Articles 9 and 9/A of Law No. 5651, and options such as “Compromised Account” and “Impersonation” are also included among the choices. See https://www.facebook.com/help/contact/880127516120350 ↩