Setting Up an Internal Accessibility Review Commission in Türkiye: Requirements Under Presidential Circular 2025/10

Overview

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On 21 June 2025, Türkiye took a landmark step toward digital inclusion by publishing Presidential Circular No. 2025/10, titled Web Siteleri ve Mobil Uygulamaların Erişilebilirliği (Accessibility of Websites and Mobile Applications), in Official Gazette No. 32933. The Circular establishes a comprehensive legal framework that mandates accessible websites and mobile applications for a wide range of public and private sector organizations, with the explicit goal of enabling persons with disabilities and elderly individuals to participate equally in digital life.

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At the heart of this framework is a three-tier commission structure. Two commissions operate at the national level — a Monitoring Commission (İzleme Komisyonu) chaired by the Minister of Family and Social Services, and an Advisory Commission (Danışma Komisyonu) chaired by a Deputy Minister. The third and most operationally critical body for any individual organization is the internal Accessibility Review Commission (Web Siteleri ve Mobil Uygulamaların Erişilebilirliği İnceleme Komisyonu — hereinafter "İnceleme Komisyonu"). Every covered institution, organization, university, and legal entity subject to the Circular must form this in-house body, conduct a technical examination of its own websites and mobile applications, and submit a written report to the national Monitoring Commission.

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The requirement solves a long-standing enforcement problem: without a designated internal body accountable for conducting and documenting accessibility audits, regulatory oversight becomes difficult and compliance remains superficial. By requiring each organization to stand up its own İnceleme Komisyonu, the Circular creates distributed accountability and a paper trail that feeds directly into the national monitoring cycle.

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Legal Basis

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The primary legal instrument is Presidential Circular No. 2025/10, signed by President Recep Tayyip Erdoğan and published in the Resmî Gazete (Official Gazette) dated 21 June 2025, Issue No. 32933. The Circular entered into force on the date of publication and is legally binding on all entities named within its scope.

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Two foundational statutes underpin the Circular:

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• Law No. 5378 — Law on Persons with Disabilities (Engelliler Hakkında Kanun), dated 1 July 2005. Article 7(3) of this law expressly requires that information services and information and communication technologies be made accessible. The Circular operationalizes this pre-existing statutory duty by specifying standards, timelines, and institutional mechanisms.
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• Law No. 6563 — Law on the Regulation of Electronic Commerce (Elektronik Ticaretin Düzenlenmesi Hakkında Kanun), dated 23 October 2014. This law brings e-commerce service providers within the accessibility obligation and provides the legal hook for the extended two-year compliance window granted to that sector.
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The Circular also aligns with Law No. 6701 on the Turkey Human Rights and Equality Institution, which designates disability as a ground of discrimination, reinforcing the human-rights dimension of the accessibility obligation.

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The official full text of the Circular is available at the Resmî Gazete electronic archive: https://www.resmigazete.gov.tr/eskiler/2025/06/20250621-17.pdf. The Ministry of Family and Social Services publishes the accompanying Web Accessibility Checklist – Level A and the WCAG 2.2 guidelines at www.aile.gov.tr.

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Who Is Obligated?

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The Circular draws a clear distinction between two compliance tiers based on entity type and compliance deadline.

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One-Year Deadline (by 21 June 2026) — Public and Quasi-Public Entities

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• Public institutions and organizations (kamu kurum ve kuruluşları)
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• Universities
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• Municipalities (belediyeler)
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• State-owned enterprises (kamu iktisadi teşebbüsleri)
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• Municipal companies, enterprises, and subsidiaries
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• Professional organizations with public institution status (kamu kurumu niteliğindeki meslek kuruluşları)
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• Banks (bankalar)
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• Private hospitals (özel hastaneler)
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• Private educational institutions authorized by the Ministry of National Education (MoNE)
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• Private companies providing road, rail, sea (passenger ships), and air passenger transport services under Law No. 4925 (Road Transport Law)
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• Group A travel agencies holding a license from the Ministry of Culture and Tourism
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• Telecommunications operators in the electronic communications sector with 200,000 or more subscribers
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Two-Year Deadline (by 21 June 2027) — E-Commerce Sector

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• E-commerce service providers operating under Law No. 6563 on the Regulation of Electronic Commerce
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Organizations that fall outside the listed categories are not formally obligated under the Circular, though legal experts note that voluntary compliance with accessibility standards is strongly encouraged as a matter of human-rights responsibility and good practice. Certain content is explicitly exempt from the obligation, including archive websites, pages, and mobile applications that have not been updated or edited within the past year.

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Technical Requirements

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The Circular establishes two interlocking technical benchmarks that an organization's İnceleme Komisyonu must evaluate against:

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WCAG 2.2 Level A — Minimum Mandatory Standard

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The Web Content Accessibility Guidelines (WCAG) version 2.2, published by the World Wide Web Consortium (W3C) in October 2023, sets the international baseline. Level A conformance is the minimum mandatory standard under the Circular. Organizations must align their websites and mobile applications with WCAG 2.2 Level A success criteria to satisfy the legal obligation.

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Web Accessibility Checklist – Level A (Kontrol Listesi – A Seviyesi)

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The Ministry of Family and Social Services has published a national Web Siteleri ve Mobil Uygulamaların Erişilebilirliği Kontrol Listesi – A Seviyesi (Accessibility Checklist – Level A), developed with input from relevant institutions and universities. This checklist contains 31 principles and 122 questions structured around WCAG 2.2 Level A criteria. All covered organizations must use this checklist as their primary self-assessment tool. It is published at www.aile.gov.tr.

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Level AA — Required for the Accessibility Logo

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Organizations seeking to obtain the Erişilebilirlik Logosu (Accessibility Logo) must demonstrate a higher standard of conformance. The Monitoring Commission evaluates whether a platform is genuinely accessible, and the resulting logo — awarded for a two-year period — is understood in practice to reflect WCAG 2.2 Level AA alignment, as the Level A checklist alone establishes the minimum compliance floor rather than the recognized mark of excellence.

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Scope of the Technical Audit

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The İnceleme Komisyonu's technical examination must cover all active websites and mobile applications operated by the organization. It must produce a formal written report that identifies which WCAG 2.2 and Checklist criteria are met, which are partially met, and which are not met, along with a remediation plan. This report is submitted to the national Monitoring Commission as part of the oversight process.

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Implementation Steps

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The following steps provide a practical roadmap for any covered organization establishing its İnceleme Komisyonu and achieving compliance.

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1. Determine your compliance deadline. Confirm whether your organization falls under the one-year (public sector and listed private entities) or two-year (e-commerce) category. Calculate your deadline from 21 June 2025 and work backwards to create a realistic project timeline.
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2. Formally establish the İnceleme Komisyonu by official decision. Issue an internal administrative decision (e.g., a board resolution, rector's decree, or general manager's directive) formally constituting the internal Accessibility Review Commission. The decision should name the commission members, designate a chairperson, and specify the commission's mandate: to technically examine the organization's websites and mobile applications for accessibility and to prepare the report for submission to the national Monitoring Commission.
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3. Appoint technically qualified commission members. The İnceleme Komisyonu should include staff with expertise in web development, UX/UI design, and information technology. Consider also including a representative from human resources or legal, and — where feasible — a person with a disability who can provide user perspective. The commission should have a minimum of three members to ensure deliberative credibility.
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4. Inventory all digital assets. Compile a complete list of every website, subdomain, web application, and mobile application (iOS and Android) operated or maintained by the organization. Prioritize those that provide public-facing services, forms, or information.
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5. Obtain and study the official Accessibility Checklist. Download the Web Siteleri ve Mobil Uygulamaların Erişilebilirliği Kontrol Listesi – A Seviyesi from www.aile.gov.tr. Familiarize the commission with all 31 principles and 122 questions. Review the WCAG 2.2 guidelines published by W3C for additional technical context.
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6. Conduct the technical accessibility audit. Apply the Checklist systematically to each digital asset. Use a combination of automated scanning tools (such as Accsible's accessibility overlay and widget SDK) and manual testing — including keyboard-only navigation, screen reader testing, and color contrast analysis. Document the status of each criterion: compliant, partially compliant, or non-compliant.
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7. Identify and prioritize remediation actions. For each non-compliant or partially compliant item, determine the required remediation, the responsible team, and a target completion date. Prioritize issues that affect the broadest number of users or pose the highest barrier to access (e.g., missing alternative text, absent form labels, insufficient color contrast).
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8. Implement remediation and verify fixes. Work with your development and content teams to implement the necessary changes. Re-test after each batch of fixes to verify that the issue is resolved and that no new issues have been introduced. Accessibility overlay solutions — such as the Accsible widget — can provide immediate, client-side improvements while longer-term structural fixes are implemented.
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9. Prepare and submit the formal report. Draft the official İnceleme Komisyonu report detailing the audit methodology, findings for each digital asset, remediation actions taken, outstanding items with timelines, and an overall conformance assessment against the Checklist – Level A. Submit the report to the national Web Siteleri ve Mobil Uygulamaların Erişilebilirliği İzleme Komisyonu through the channel specified by the Ministry of Family and Social Services.
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10. Maintain ongoing monitoring and annual review cycles. Accessibility is not a one-time project. The national Monitoring Commission operates on an annual planning cycle. Your İnceleme Komisyonu should schedule periodic re-audits (at minimum annually), update the report as your digital estate evolves, and ensure that new content, features, or applications are evaluated for accessibility before launch.
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Frequently Asked Questions

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What exactly is the İnceleme Komisyonu and how is it different from the national commissions?

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The İnceleme Komisyonu (Internal Accessibility Review Commission) is an in-house body that each covered organization must create within its own structure. Its role is to technically audit the organization's own websites and mobile applications and produce a report for the national Monitoring Commission (İzleme Komisyonu). The national Monitoring Commission — chaired by the Minister of Family and Social Services — oversees compliance across all covered entities. The Advisory Commission (Danışma Komisyonu), chaired by a Deputy Minister, resolves ambiguities and helps define the annual monitoring plan. The İnceleme Komisyonu is therefore the operational, organization-level body, while the national commissions provide oversight and guidance from above.

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By what date must public institutions set up their İnceleme Komisyonu and achieve compliance?

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Public institutions, universities, municipalities, state-owned enterprises, banks, private hospitals, MoNE-authorized schools, passenger transport companies, Group A travel agencies, and telecom operators with 200,000 or more subscribers must comply within one year of the Circular's publication — that is, by 21 June 2026. E-commerce service providers under Law No. 6563 have until 21 June 2027. There is no separate stated deadline for establishing the İnceleme Komisyonu itself; organizations should form it as early as possible so the audit and remediation work can be completed within the overall compliance window.

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What standard must we meet to be considered compliant?

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