TikTok¶
An evaluation of TikTok’s compliance with Law No. 5651 and its secondary legislation reveals a platform that has meticulously ticked the structural boxes. TikTok has fully satisfied the requirements to appoint a representative, establish a local company, and meet the necessary capital conditions. Furthermore, the company’s direct affiliation and authorisation status align perfectly with the legislative standards.
The platform’s corporate structuring in Türkiye evolved in tandem with the legal process initiated in 2021. Initially, “TikTok Turkey Dijital Medya ve Reklam Limited Şirketi” was established on 29 March 2021 by the Singapore-based TikTok Pte. Ltd. At this inception stage, the company held a modest capital of TRY 100.000, with the parent company acting as manager alongside Cormac Patrick Keenan (resident in Ireland), who was authorised to act on behalf of the entity.85
Following the aggravation of legal conditions for social media platforms, radical changes were executed via a General Assembly decision registered on 14 April 2023. To comply with the mandate for a “distinctive title containing the province of establishment”, the company was renamed “TikTok İstanbul Dijital Medya ve Reklam Limited Şirketi”. Simultaneously, the capital was injected with a massive cash increase of TRY 99.900.000, raising the total to TRY 100.000.000, the legal minimum.86
The most notable compliance step was the addition of Article 15, titled “Representation and Liability”, to the company’s articles of association. This explicitly records that the company is the legal representative in Türkiye of TikTok Pte. Ltd., operates as an affiliate, and is “fully authorised and held responsible in technical, administrative, legal, and financial terms”.87 This provision confirms that TikTok has met the most critical liability condition introduced by Law No. 7418.
In 2024, management leadership shifted from Ireland to Singapore. Cormac Patrick Keenan’s tenure ended on 3 April 2024, with Eep Jiagen appointed in his position.88 These moves confirm that TikTok’s Turkish operations are now tightly integrated with its central management structure in Singapore.
The extent to which the TikTok platform complies with obligations under Law No. 5651 and relevant secondary legislation is evaluated in the table below.
| 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 authorized by TikTok. |
| Turnover & Reporting Obligation | Unknown | No public information regarding report submission to BTK. |
| Application Form for Users | Meets | A Turkish application page created by TikTok exists. |
| User Application Processes | Partially Meets | The hierarchy of examining applications is explained in reports. |
| Transparency Reports | Partially Meets | Reports are regular, but Article 9 and 9/A data are not numerically disaggregated. |
| 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 | 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. |
A Mixed Picture¶
While TikTok excels in structural compliance, the picture regarding user rights and transparency is mixed. A Turkish application form exists, yet the systematic details of the process remain obscure to the public. More critically, while transparency reports are published regularly, they fail to report data for Article 9 and Article 9/A separately. Instead, these are lumped into grand totals or expressed as percentages, obscuring the true nature of the complaints.
A startling qualitative gap exists between TikTok’s local and global reporting. While local reports are sparse on detail, global reports reveal an extraordinarily high compliance rate, exceeding 90%, with administrative and judicial requests in Türkiye.
Transparency Reports Assessment¶
A deep chasm separates TikTok’s local (Law No. 5651) reporting from its global transparency standards.
As mentioned above, local reports fail to meet the specific breakdown envisaged by the law. Separate statistics for Article 9 (personal rights) and Article 9/A (privacy) are notably absent. Applications are broadly categorised as requests “under Law No. 5651” versus those “based on other legal grounds”, with no sub-categories for insult or privacy violations. Although some percentage data appeared in 2024 and 2025 (e.g., 74.4% in the 2025-1 period), precise numbers remain elusive.
Furthermore, while the outcomes (access blocked/not blocked) are reported, the grounds for these decisions are not detailed. It is also noteworthy that request volumes doubled from roughly 600 in 2023 to 1.243 in the second half of 2024, yet the report offers no explanation for this surge.
| 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 | Partially Exists |
| 2024-2 | Yes | No | No | Partially Exists |
| 2025-1 | Yes | No | No | Partially Exists |
Global Data Reveals the Truth¶
When TikTok’s global transparency reports89 are examined, the reality of its operations in Türkiye becomes starkly visible. The data confirms that TikTok complies with content removal requests at an extraordinarily high rate.
| Period | Total Requests |
Total Content Count |
Actioned (Local Law) |
Actioned (Community Guidelines) |
Removal Rate (%) |
|---|---|---|---|---|---|
| 2024-2 | 253 | 1,392 | 419 | 883 | 95% |
| 2024-1 | 295 | 839 | 346 | 437 | 91.8% |
| 2023-2 | 244 | 616 | 194 | 349 | 81.1% |
| 2023-1 | 107 | 3.958 | 3.796 | 71 | 97.7% |
| 2022-2 | 92 | 181 | 125 | 44 | 93.6% |
| 2022-1 | 64 | 84 | 76 | 1 | 91% |
| 2021-2 | 98 | 222 | 170 | 44 | 93% |
| 2021-1 | 113 | 270 | 250 | 16 | 98% |
Between 2021 and 2024, the average removal rate was 92.65%. During the pivotal 2023 General Elections (Jan-June), the removal rate spiked to 97.7%. By late 2024, it remained sky-high at 95%.
The Tale of Two Reports¶
The contrast is striking. While local reports obscure the distinction between legal violations and community guideline breaches, the global reports clearly separate “Local Law Violation” from “Community Guidelines Violation”. Moreover, the global reports capture a much wider pool of “Government Requests” (police, prosecution, BTK), showing volumes in the thousands (e.g., 3.000+ items in 2023). This exposes the true scale of censorship, which the sanitised local reports effectively conceal.
No publicly available information could be accessed regarding other areas such as the ad library, crisis plan, and the obligation to provide information to judicial authorities. Uncertainties in these areas make it difficult to evaluate whether TikTok has fulfilled these obligations.
TikTok has successfully navigated the structural requirements of Turkish law but remains opaque regarding transparency and user rights. However, TikTok’s global reports lay bare the scale of censorship and the platform’s level of “high obedience” (92.65% compliance) much more nakedly compared to local reports in Türkiye. Local reports, conversely, are bureaucratic texts devoid of categorical distinction that conceal this picture.
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Turkish Trade Registry Gazette, No. 10297, 29.03.2021, p. 821. ↩
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Turkish Trade Registry Gazette, No. 10812, 14.04.2023, p. 1520. ↩
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For title change, capital increase, and amendment to articles of association (Article 15), see Turkish Trade Registry Gazette, No. 10812, 14.04.2023, p. 1520. ↩
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Turkish Trade Registry Gazette, No. 11057, 03.04.2024, p. 575. ↩
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See TikTok, Government Removal Requests Report, https://www.tiktok.com/transparency/tr-tr/government-removal-requests-2024-2 ↩