AI law comparison · Data verified 2026-08-22
GDPR Article 22 vs Turkey KVKK
GDPR Article 22 and Turkey KVKK are two of the 169 AI and data regulations Aegis Firma tracks. They have different scopes, effective dates, and penalties — and many businesses fall under both. Here is the side-by-side, drawn directly from the regulatory registry.
Find which laws apply to my businessSide by side
Summary of publicly available regulatory text. Verify against current official sources before relying on this for compliance decisions. Not legal advice.
The key difference
Turkey KVKK takes effect first, so it is usually the more urgent of the two. GDPR Article 22 tracks 5 compliance requirements and Turkey KVKK tracks 4. They are not interchangeable — meeting one does not discharge the other. The practical question is not which law is “stricter,” but which of them — or both — actually applies to your business.
EU GDPR Article 22 — Automated Decision-Making & AI Profiling
GDPR Article 22 (in force since May 25, 2018) gives EU and EEA residents the right not to be subject to decisions based solely on automated processing — including AI profiling — that produces legal or similarly significant effects (credit scores, hiring, insurance pricing, content moderation). Organizations must inform individuals of automated processing, provide meaningful explanations of logic, implement human revi…
Full GDPR Article 22 requirementsTurkey Personal Data Protection Law (KVKK No. 6698) + AI Strategy 2021-2025
Turkey's KVKK (Kişisel Verileri Koruma Kanunu, Law No. 6698) is Turkey's GDPR-equivalent, administered by the Personal Data Protection Authority (KVKK Board). While Turkey is not in the EU, KVKK aligns closely with GDPR principles and is a prerequisite for Turkish market access. Turkey's National AI Strategy 2021-2025 adds sector-specific AI obligations across finance (BRSA/BDDK), healthcare, and transportation. CYCL…
Full Turkey KVKK requirementsCommon questions
Could both GDPR Article 22 and Turkey KVKK apply to my business?
Yes. GDPR Article 22 and Turkey KVKK are separate regulations with separate scopes — a business can fall under both at once. GDPR Article 22 covers GDPR Art. Turkey KVKK covers Applies to any organisation — established in Turkey or outside it — that processes the personal data of individuals in Turkey, including via AI profiling and au… If your operations meet both scopes, you must comply with both. Aegis Firma's free scan checks all 169 tracked regulations against your business profile so you do not have to read each law to find out.
Which has the higher maximum penalty — GDPR Article 22 or Turkey KVKK?
GDPR Article 22: €20,000,000 or 4% of global annual turnover — whichever is higher (GDPR Art. 83(5)) Turkey KVKK: KVKK fine band, revalued ANNUALLY (2026 figures, effective 2026-01-01): disclosure-obligation failures TRY 85,437-1,709,200; data-security-obligation failures TRY 256,357-17,092,242; failure to comply with Board decisions TRY 427,263-17,092,242; VERBİS registration/notification violations TRY 341,809-17,092,242. Top of band ≈ $356,000 USD at 2026-08-22's ~48 TRY/USD rate — NOT a fixed figure; re-check annually. Plus criminal sanctions under Turkish Penal Code (TPC Art. 135-140); KVKK Board can suspend processing. Penalty structures differ by regulator and violation type — read each law's full page for the cure periods and per-violation detail.
When does each law take effect?
GDPR Article 22 — effective 2018-05-25. Turkey KVKK — effective 2016-04-07, enforcement from 2018-10-01. Dates last verified against official sources on 2026-08-22 and 2026-08-22 respectively.
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