Turkey Accessibility Logo — Application Process and Criteria Under Presidential Circular 2025/10

Overview

Turkey's digital accessibility landscape underwent a landmark transformation on June 21, 2025, when Presidential Circular No. 2025/10 on "Web Accessibility and Mobile Applications" was published in the Official Gazette. The circular establishes a nationwide framework requiring websites and mobile applications to be accessible to all users — with a specific focus on persons with disabilities and the elderly. At the heart of this framework is the Erişilebilirlik Logosu (Accessibility Logo): a formal, government-issued mark that organisations can display once their digital services are verified as accessible by the Ministry of Family and Social Services (Aile ve Sosyal Hizmetler Bakanlığı).

The need for this regulation stems from a documented gap between the rapid digitalisation of public and commercial services and the practical ability of disabled and elderly users to access those services. As more critical services — from tax filings and health records to banking and e-commerce — moved exclusively online, users with visual, auditory, motor, or cognitive impairments were systematically excluded. The circular addresses this by mandating compliance with internationally recognised accessibility standards and creating a transparent, monitored pathway to recognition through the Accessibility Logo.

The logo serves two strategic purposes: it incentivises organisations to invest in accessibility by providing a publicly visible reward, and it enables users with disabilities to identify and trust digital platforms that have been formally verified. Organisations that fail to meet the required standards within the prescribed timelines will have that non-compliance made public, creating both reputational and legal pressure to comply.

Legal Basis

The primary instrument governing Turkey's digital accessibility obligations is Presidential Circular No. 2025/10, published in the Official Gazette (Resmî Gazete) dated June 21, 2025, issue number 32933. The circular entered into force on the date of publication. Its full text is publicly available at resmigazete.gov.tr.

The circular derives its authority from two foundational statutes:

• Law No. 5378 — Engelliler Hakkında Kanun (Law on Persons with Disabilities), enacted July 1, 2005 (Official Gazette: July 7, 2005, No. 25868). Article 7(3) of this law explicitly mandates that information services and information and communication technologies must be made accessible for persons with disabilities. This provision is the direct legal anchor for all digital accessibility obligations in Turkey. The full consolidated text is available at mevzuat.gov.tr.
• Law No. 6563 — Elektronik Ticaretin Düzenlenmesi Hakkında Kanun (Law on the Regulation of Electronic Commerce), enacted October 23, 2014. This law governs e-commerce service providers and is used by the circular to extend digital accessibility obligations to the private commercial sector with a two-year compliance window.

Supporting institutional authority is also derived from Law No. 6701 — Turkey Human Rights and Equality Institution (TİHEK) Law, which classifies disability as a prohibited basis for discrimination, giving regulatory bodies grounds to act on accessibility failures as rights violations.

The procedural rules governing the three monitoring commissions — the Monitoring Commission (İzleme Komisyonu), Advisory Commission (Danışma Komisyonu), and internal Review Commission (İnceleme Komisyonu) — are to be determined by the Ministry of Family and Social Services. Monitoring results and accessibility reports will be announced by the Minister of Family and Social Services and published at www.aile.gov.tr.

Who Is Obligated?

The circular draws a clear distinction between two groups of obligated entities, each subject to different compliance timelines.

Group 1 — Must comply within 1 year of the circular's publication (by June 21, 2026):

• Public institutions and government bodies (kamu kurum ve kuruluşları)
• Universities
• Municipalities (belediyeler)
• State economic enterprises (kamu iktisadi teşebbüsleri) and their affiliated companies, businesses, and subsidiaries
• Professional organisations with public institution status (kamu kurumu niteliğindeki meslek kuruluşları)
• Banks
• Private hospitals
• Private educational institutions authorised by the Ministry of National Education (MoNE)
• Private organisations providing road, passenger ship, railway, and airline passenger transport services under Law No. 4925 (Road Transport Law, dated July 10, 2003)
• Group A travel agencies holding an operating licence from the Ministry of Culture and Tourism
• Telecommunications operators in the electronic communications sector with more than 200,000 subscribers

Group 2 — Must comply within 2 years of the circular's publication (by June 21, 2027):

• E-commerce service providers operating under Law No. 6563 (Law on the Regulation of Electronic Commerce, dated October 23, 2014)

It is important to note that the circular also specifies certain exemptions. Content that has not been updated or edited within the past year (archive content), content used solely for internal administrative processes, and certain dynamically added content may be excluded from the accessibility requirement. Organisations should review the specific exemption criteria published on the Ministry's website.

Technical Requirements

The technical standard mandated by Presidential Circular 2025/10 is the Web Content Accessibility Guidelines (WCAG) version 2.2, developed by the World Wide Web Consortium (W3C). All in-scope organisations must bring their websites and mobile applications into conformance with WCAG 2.2.

The circular specifies a two-tier technical framework:

• Minimum mandatory standard — WCAG 2.2 Level A: All obligated organisations must achieve at least Level A conformance within their respective deadlines. The Ministry of Family and Social Services has published a national Web Sitesi ve Mobil Uygulamaların Erişilebilirliği Kontrol Listesi – A Seviyesi (Website and Mobile Application Accessibility Checklist – Level A) that operationalises the WCAG 2.2 Level A criteria in the Turkish context. This checklist is the primary reference for the Monitoring Commission's assessments and is available at www.aile.gov.tr.
• Accessibility Logo qualification standard — WCAG 2.2 Level AA: To be awarded the Accessibility Logo, a digital platform must demonstrably meet the higher WCAG 2.2 Level AA standard. Level AA builds on all Level A criteria and adds requirements such as minimum colour contrast ratios, captions for live audio, multiple ways to navigate content, and visible focus indicators. Meeting Level AA represents a significantly broader commitment to inclusion, covering users with a wider range of visual, auditory, motor, and cognitive disabilities.

WCAG 2.2 is organised around four core principles — content must be Perceivable, Operable, Understandable, and Robust (the POUR principles). Under these principles, practical requirements include: text alternatives for all non-text content, captions and audio descriptions for multimedia, keyboard-accessible navigation, sufficient time for users to read and use content, avoidance of content that could trigger seizures, logical reading order, predictable page behaviour, input assistance, and compatibility with current and future assistive technologies.

The checklist and the full WCAG 2.2 guidelines are published on the Ministry of Family and Social Services' official website. Organisations are encouraged to conduct gap analyses against both instruments before initiating remediation work.

Implementation Steps

1. Determine whether your organisation is in scope. Review the entity categories listed in the circular. Confirm your organisation's sector, legal status, and — for telecoms — subscriber count. If you fall within Group 1 or Group 2, note your applicable deadline (June 21, 2026, or June 21, 2027, respectively).
2. Download the official checklist and WCAG 2.2 guidelines. Access the Web Sitesi ve Mobil Uygulamaların Erişilebilirliği Kontrol Listesi – A Seviyesi from www.aile.gov.tr. Download WCAG 2.2 from www.w3.org/TR/WCAG22/. These two documents define the assessment criteria the Monitoring Commission will use.
3. Establish an internal Review Commission (İnceleme Komisyonu). The circular requires each in-scope organisation to set up its own internal commission responsible for technically examining its websites and mobile applications and reporting on accessibility status. This body should include web developers, UX/UI designers, and ideally a representative with knowledge of assistive technologies.
4. Conduct a baseline accessibility audit. Use a combination of automated scanning tools (which can efficiently detect a broad range of Level A and AA issues) and manual testing (which is essential for detecting issues that automated tools miss, such as logical reading order, form labels, and keyboard trap failures). Also conduct user testing with people with disabilities where possible.
5. Remediate identified accessibility issues. Prioritise critical barriers that completely block access for users with disabilities (Level A failures), then address Level AA criteria needed for logo eligibility. Apply fixes across all digital platforms — desktop websites, mobile-responsive sites, and native mobile applications — ensuring accessibility is embedded in new content and design from the start.
6. Publish an accessibility statement. While not explicitly mandated in the text of the circular, best practice aligned with international standards calls for publishing a clear accessibility statement on your website describing your conformance level, known limitations, and a contact mechanism for users to report accessibility issues.
7. Submit to the Monitoring Commission's review process. The Monitoring Commission, chaired by the Minister of Family and Social Services, conducts its assessments according to an annual monitoring plan (Web Siteleri ve Mobil Uygulamaların Erişilebilirliği İzleme Planı). Monitor the Ministry's announcements at www.aile.gov.tr for information on when your sector or organisation type will be scheduled for review.
8. Receive and display the Accessibility Logo. Following a successful monitoring assessment, the Ministry of Family and Social Services grants the right to use the Accessibility Logo for a period of two years. Display the logo prominently on your website and mobile applications as a signal of your verified commitment to digital inclusion.
9. Maintain and renew compliance. Accessibility is not a one-time project. Content changes, new features, and platform updates can introduce new barriers. Establish an ongoing accessibility maintenance programme, conduct periodic re-audits, and ensure that all new content is produced accessibly. Initiate the renewal process before your two-year logo period expires.

Frequently Asked Questions

When exactly is the compliance deadline for public institutions?

Public institutions and all other entities in Group 1 (including universities, municipalities, banks, private hospitals, private schools, major transport providers, and large telecoms operators) must comply within one year of the circular's publication date of June 21, 2025 — meaning by June 21, 2026. E-commerce service providers under Law No. 6563 have a two-year window, making their deadline June 21, 2027.

What is the minimum WCAG level required, and what level is needed for the Accessibility Logo?

The minimum legal requirement for all in-scope organisations is WCAG 2.2 Level A conformance, aligned with the Ministry's official Accessibility Checklist – Level A. However, to qualify for the Accessibility Logo, a digital platform must meet the higher WCAG 2.2 Level AA standard. Level AA includes all Level A criteria plus additional requirements covering a broader range of disabilities. Organisations should target Level AA from the outset if they wish to earn the logo.

How does an organisation actually receive the Accessibility Logo?

The Accessibility Logo is not self-awarded. It is granted by the Ministry of Family and Social Services following a successful review by the Monitoring Commission (İzleme Komisyonu). The Monitoring Commission carries out assessments according to an annual monitoring plan. Organisations do not apply directly — rather, they must ensure their platforms meet the required standards so that when the commission assesses them, they pass. Results are reported and announced by the Minister of Family and Social Services. Successful organisations are then granted the right to use the logo for a period of two years.

What happens if an organisation does not comply within its deadline?

The circular specifies that information about websites and mobile applications that fail to meet the required accessibility conditions within the prescribed timeframe will be made public. This public disclosure mechanism serves as a significant reputational deterrent. Additionally, under the broader framework of Law No. 5378, the Ministry of Family and Social Services has authority to impose administrative fines on public bodies that fail to meet accessibility obligations. Non-compliance may also expose organisations to complaints before the Turkey Human Rights and Equality Institution (TİHEK), which treats disability-based inaccessibility as discrimination.

Does the Accessibility Logo cover both websites and mobile applications?

Yes. The circular explicitly covers both websites (web siteleri) and mobile applications (mobil uygulamalar). The Accessibility Logo can be granted for a specific web page or mobile application that has been assessed and found to meet the required standards. Organisations with multiple digital platforms may need each platform assessed separately. The Ministry's Accessibility Checklist – Level A and the WCAG 2.2 guidelines apply to both web and mobile contexts.

Are there any content types or organisations exempt from the requirements?

Yes, the circular includes specific exemptions. Archive content that has not been updated or edited within the past year, content used solely for internal administrative processes, and certain dynamically added content types may be excluded from mandatory accessibility requirements. Organisations outside the explicitly listed categories in the circular — for example, small businesses that are not e-commerce providers under Law No. 6563 — are not formally obligated under this circular, although legal and ethical best practice strongly encourages universal adoption of accessibility standards.

How long is the Accessibility Logo valid, and how is it renewed?

The Accessibility Logo is valid for two years from the date of its grant by the Ministry of Family and Social Services. After two years, the organisation must undergo a new monitoring assessment to confirm that its digital platforms remain compliant and have not regressed due to content updates or design changes. Organisations should treat accessibility as a continuous programme rather than a one-time project to ensure smooth renewal. The Ministry will announce renewed monitoring plans annually, and organisations should proactively maintain their compliance status to remain eligible.