Turkey's Presidential Circular 2025/10: What Every Website Owner Needs to Know

<p>On June 21, 2025, a sweeping new legal framework quietly took effect in Türkiye that will touch virtually every organization operating a website or mobile application in the country. Presidential Circular No. 2025/10, published in Official Gazette No. 32933, mandates that digital properties be made accessible to all users — particularly persons with disabilities and the elderly. With over 77 million internet users in Turkey at the start of 2025 and compliance deadlines already ticking, the window for organizations to act is narrower than many realize.</p> <h2>Background: Why Turkey Acted Now</h2> <p>Turkey's relationship with disability rights law goes back two decades. Law No. 5378, the foundational legislation on the rights of persons with disabilities, was enacted in 2005 and has been amended multiple times since. For years, however, digital accessibility remained a grey area in Turkish law — referenced in spirit but rarely enforced in practice. The 2025 Presidential Circular changes that dramatically, giving the country's digital accessibility obligations clear legal teeth for the first time.</p> <p>The timing is no accident. Turkey has been accelerating its digital transformation agenda while simultaneously harmonizing its legal landscape with international and European norms. The European Accessibility Act, which fully came into force across the EU in June 2025, set the backdrop. Turkey — a candidate country with deep economic and regulatory ties to the EU — has mirrored the direction of travel, anchoring its domestic framework to the same international standard: WCAG 2.2. The circular also draws legal force from Law No. 6563 on the Regulation of Electronic Commerce, meaning e-commerce platforms face explicit statutory obligations, not just administrative guidance.</p> <p>This is not the first time Turkey has used a Presidential Circular as a vehicle for sweeping digital policy. The 2019/12 Circular on Information and Communication Security set similar precedent for data localization and cybersecurity obligations. But Circular 2025/10 is arguably broader in scope: it reaches into the private sector far more directly than its predecessors, and it is backed by a structured monitoring and enforcement apparatus that earlier instruments lacked.</p> <p>The human scale of this regulation matters. Turkey's population includes millions of people living with visual, hearing, motor, and cognitive impairments, alongside a rapidly growing elderly demographic. Digital inclusion is not an abstract compliance checkbox — it is a prerequisite for equal participation in modern Turkish civic and commercial life.</p> <h2>What Circular 2025/10 Actually Requires</h2> <p>At its core, the circular mandates compliance with two interlocking benchmarks. The first is the Web Accessibility Checklist – Level A, developed by Turkey's Ministry of Family and Social Services specifically for the Turkish regulatory context. The second is WCAG 2.2, the internationally recognized guideline published by the World Wide Web Consortium (W3C). These two benchmarks work in tandem: the Ministry's checklist operationalizes the international standard for the Turkish administrative environment, while WCAG 2.2 provides the underlying technical framework.</p> <p>WCAG 2.2 organizes its requirements around four core principles, often summarized by the acronym POUR: content must be <strong>Perceivable</strong> (users can see or hear it in some form), <strong>Operable</strong> (users can navigate and interact with it), <strong>Understandable</strong> (content and UI behavior are clear), and <strong>Robust</strong> (content is compatible with current and future assistive technologies). Within these principles, there are 13 guidelines and a set of testable success criteria rated at three levels — A, AA, and AAA — with Level A representing the minimum baseline and Level AA being the target for most regulatory frameworks worldwide.</p> <p>The circular explicitly requires compliance with at least Level A, which covers foundational issues such as providing text alternatives for non-text content, ensuring all functionality is keyboard-accessible, giving users enough time to read and use content, and avoiding content known to cause seizures. Many organizations that wish to demonstrate genuine commitment to accessibility — and position themselves for future regulatory tightening — should treat WCAG 2.2 Level AA as the practical target, not just the minimum floor.</p> <blockquote><p>Under WCAG 2.2, the Level A checklist defines basic accessibility criteria, and all websites must comply with at least this level. The checklist enhances usability for users with visual, hearing, and motor skill limitations.</p></blockquote> <p>Mobile applications are covered on equal footing with websites. The circular does not distinguish between native mobile apps and mobile-optimized web experiences — if your organization has a presence on iOS or Android, those platforms are subject to the same requirements as your desktop web properties.</p> <h2>Who Must Comply — and When</h2> <p>The circular draws a clear distinction between public sector and private sector obligations, with two separate compliance windows.</p> <p><strong>Within one year of the circular's publication (i.e., by June 21, 2026)</strong>, the following organizations must have achieved compliance:</p> <ul> <li>All public institutions and their affiliated organizations</li> <li>Universities (both state and private)</li> <li>Municipalities and municipal-owned companies</li> <li>Private hospitals</li> <li>Banks and financial institutions</li> <li>Major transport providers</li> <li>Telecom operators with more than 200,000 subscribers</li> </ul> <p><strong>Within two years (i.e., by June 21, 2027)</strong>, private sector entities must reach full compliance. This second wave covers:</p> <ul> <li>E-commerce platforms regulated under Law No. 6563</li> <li>Private sector service providers more broadly</li> <li>Group A travel agencies operating under a Ministry of Tourism license</li> <li>Professional organizations and affiliated bodies</li> </ul> <p>In practice, if your organization operates a commercial website targeting Turkish users — whether you are a domestic retailer, a foreign brand with Turkish customers, or a SaaS platform serving Turkish businesses — you almost certainly fall within scope. The regulation's reach extends to any private legal entity providing digital services, not just the explicitly named sectors. Organizations should err on the side of assuming they are covered rather than assuming they are exempt.</p> <blockquote><p>The regulations have been broadened to cover both public institutions and private sector organizations. In particular, service providers in the field of digital commerce are now required to comply with accessibility standards.</p></blockquote> <h2>The Monitoring and Enforcement Architecture</h2> <p>One of the most significant aspects of Circular 2025/10 is that it does not simply issue requirements and leave enforcement to chance. The Ministry of Family and Social Services has established a dedicated institutional structure to monitor and enforce compliance, comprised of multiple specialized commissions.</p> <p>The <strong>Accessibility Monitoring Commission</strong> is responsible for regularly inspecting digital services and websites against accessibility standards. The <strong>Advisory Commission</strong> provides policy guidance and facilitates stakeholder engagement, helping organizations understand their obligations. On the mobile side, a parallel structure exists: the <strong>Mobile Application Accessibility Monitoring Commission</strong> oversees compliance for apps, while the <strong>Mobile Application Accessibility Review Commission</strong> conducts granular technical reviews.</p> <p>Critically, the circular does not leave compliance determination entirely to the government. Each covered organization — whether a public body, university, or private entity — is required to form its own internal <strong>Accessibility Review Commission</strong>. This internal body is responsible for evaluating the technical accessibility of the organization's own digital properties, preparing a compliance report based on its findings, and submitting that report to the national Monitoring Commission. In other words, the regime has a self-reporting component with external oversight — a structure familiar to anyone who has navigated GDPR accountability frameworks.</p> <p>Organizations that successfully achieve compliance and pass the monitoring process gain the right to display an official <strong>Accessibility Logo</strong> issued by the Ministry of Family and Social Services. This logo signals verified compliance to users and is valid for a period of two years, after which the evaluation process must be repeated to maintain the designation. Think of it as a quality mark — visible proof that your digital property meets Turkey's accessibility standard and has been verified as such.</p> <h2>Key Technical Requirements: What Your Website and App Actually Need</h2> <p>Compliance with WCAG 2.2 Level A (the minimum required) involves a specific set of technical implementations. Below are the most impactful areas where organizations typically find gaps during accessibility audits.</p> <ul> <li><strong>Alternative text for images:</strong> Every meaningful image on your site needs a descriptive <code>alt</code> attribute so screen readers can convey the image's purpose to visually impaired users. Decorative images should use an empty <code>alt=''</code> to signal they can be ignored.</li> <li><strong>Keyboard navigability:</strong> All interactive elements — forms, buttons, dropdown menus, modal dialogs — must be operable using only a keyboard. Many sites rely on mouse-only hover interactions that completely exclude keyboard and switch-access users.</li> <li><strong>No reliance on color alone:</strong> Information must never be conveyed by color alone. Error states, required fields, and status indicators need secondary visual cues (labels, icons, or patterns) so that users with color blindness or low vision can perceive them.</li> <li><strong>Captions for pre-recorded audio and video:</strong> Any audio content, including video with a soundtrack, must have synchronized captions. This benefits users who are deaf or hard of hearing, as well as users in noisy environments.</li> <li><strong>Logical heading structure:</strong> Pages should use heading tags (<code>&lt;h1&gt;</code> through <code>&lt;h6&gt;</code>) in a meaningful hierarchy. Screen reader users often navigate by headings to understand a page's structure; a document full of <code>&lt;h1&gt;</code> tags or skipped heading levels makes this impossible.</li> <li><strong>Form labels:</strong> Every input field in a form must have a programmatically associated label, either using the <code>&lt;label&gt;</code> element or ARIA attributes. Placeholder text alone does not satisfy this requirement.</li> <li><strong>Sufficient time limits:</strong> If your site has session timeouts or time-limited actions, users must be warned and given the ability to extend or turn off the time limit where possible.</li> <li><strong>No content that flashes more than three times per second:</strong> Flashing or strobing animations can trigger photosensitive epileptic seizures and are prohibited without a mechanism to disable them.</li> </ul> <p>Organizations aiming for Level AA — which represents international best practice and is likely to be the target as the regulatory framework matures — will also need to address color contrast ratios (a minimum of 4.5:1 for normal text), text resizing up to 200% without loss of content or functionality, and consistent navigation across the site.</p> <h2>How This Compares to Global Accessibility Regulations</h2> <p>Turkey's Circular 2025/10 places the country firmly within a growing global consensus that web accessibility is not optional. The European Accessibility Act, which completed its transition into force in June 2025 across EU member states, takes a broadly similar approach — mandating WCAG-based compliance for both public and private sector digital services. The United States has long had the Americans with Disabilities Act and Section 508 anchoring accessibility requirements, with WCAG 2.2 now the technical standard of record in US federal rulemaking.</p> <p>What makes Turkey's approach distinctive is the combination of its Ministerial Accessibility Checklist alongside WCAG 2.2, which gives Turkish regulators a domestically developed, locally contextualized compliance instrument that can be tailored as needs evolve. The Accessibility Logo program is also a notable addition — it creates a positive market signal for compliance, not just a penalty for non-compliance.</p> <p>For multinational organizations already compliant with the EU's Web Accessibility Directive or the EAA, the good news is that WCAG 2.2 compliance achieved for European purposes will largely satisfy Turkey's technical requirements. Regulatory harmonization between Turkey and the EU on accessibility standards means that investment made for one market carries over substantially to the other, reducing the incremental cost of Turkey-specific compliance.</p> <h2>Practical Steps to Achieve Compliance</h2> <p>With deadlines already in motion, organizations need a structured approach. Here is a roadmap built around the circular's own requirements and accessibility best practices.</p> <ol> <li><strong>Commission an accessibility audit.</strong> Before you can fix what is broken, you need to know what is broken. Automated scanning tools can identify a significant portion of WCAG violations quickly, but they cannot catch everything — user testing with people who have disabilities and manual expert review are essential for comprehensive coverage. Aim for both automated and manual assessment.</li> <li><strong>Establish your internal Accessibility Review Commission.</strong> The circular requires covered organizations to form one. Assign clear ownership — this should not be a committee in name only. Involve your web development team, UX designers, content managers, and legal or compliance counsel.</li> <li><strong>Prioritize your highest-traffic, highest-risk pages first.</strong> If you cannot remediate your entire digital estate immediately, focus on your homepage, core user journeys (checkout, registration, account management), and any government-facing or public-service pages. High-traffic pages have the greatest impact on users and the greatest exposure in any monitoring exercise.</li> <li><strong>Implement an accessibility overlay or widget as a short-term layer.</strong> Tools like the Accsible SDK can provide immediate user-facing accessibility features — adjustable contrast, font scaling, keyboard navigation aids, text-to-speech — while longer-term code remediation is underway. An overlay is not a substitute for structural accessibility work, but it meaningfully improves the experience for users with disabilities right away and demonstrates good faith effort during the compliance transition period.</li> <li><strong>Publish an accessibility statement.</strong> While the circular does not explicitly mandate a public accessibility statement in the same terms as the EU Web Accessibility Directive, publishing one is considered best practice and signals transparency to both regulators and users. Your statement should describe your current compliance status, known limitations, and how users can request alternative access to content.</li> <li><strong>Build accessibility into your development workflow.</strong> One-time remediation is not enough. Integrate accessibility checks into your CI/CD pipeline, establish design review processes that include accessibility criteria, and train content creators on accessible writing and media practices.</li> <li><strong>Prepare for the Accessibility Logo evaluation.</strong> Begin documenting your compliance efforts now so that when you submit to the Monitoring Commission, you have a clear paper trail. The evaluation process will be smoother — and the result more positive — if compliance is well-evidenced from the start.</li> </ol> <h2>What Happens If You Don't Comply</h2> <p>The circular itself is a Presidential directive rather than a statute with enumerated penalties, but this does not mean non-compliance carries no consequences. The existing legislative underpinnings — particularly Law No. 5378 and Law No. 6563 — provide the enforcement basis, and the newly established monitoring commissions have both oversight and reporting functions. Organizations found non-compliant during a monitoring review will not receive the Accessibility Logo, which in itself creates reputational and competitive disadvantage in markets where accessibility certification is increasingly expected by procurement and regulatory bodies.</p> <p>For private sector organizations, the broader trend in Turkish digital regulation is clear: non-compliance in regulated sectors invites escalating administrative action. Turkey's Cybersecurity Law No. 7545, passed in March 2025, illustrated the willingness of Turkish regulators to impose significant sanctions on digital compliance failures. While accessibility enforcement may begin in a monitoring-and-guidance mode, organizations that ignore the framework entirely — particularly those in the first-wave, one-year compliance category — are taking a material regulatory risk.</p> <p>There is also a reputational dimension. The Accessibility Logo is designed to be a public-facing signal of compliance. As awareness of the regime grows among Turkish consumers and business customers, its absence may become a visible differentiator — not in the organization's favor. For international brands operating in Turkey, the reputational stakes extend beyond domestic markets.</p> <h2>Key Takeaways</h2> <ul> <li><strong>The clock is already ticking.</strong> Presidential Circular 2025/10 entered into force on June 21, 2025. Public institutions, universities, banks, hospitals, and major telecoms have until June 21, 2026 — private sector and e-commerce players have until June 21, 2027. Neither deadline is far away given the work involved.</li> <li><strong>WCAG 2.2 Level A is the minimum; Level AA should be your target.</strong> The circular mandates the Ministry's Level A checklist and WCAG 2.2 alignment. Organizations serious about durable compliance — and about genuinely serving users with disabilities — should treat Level AA as the practical bar.</li> <li><strong>You need to form an internal Accessibility Review Commission.</strong> This is an explicit organizational requirement under the circular, not optional guidance. Assign ownership, build a cross-functional team, and document your compliance journey.</li> <li><strong>Automated tools plus expert review plus user testing equals real compliance.</strong> No automated scanner catches everything. Combining technology with human expertise and lived-experience testing is the only way to achieve genuine, defensible accessibility.</li> <li><strong>An accessibility overlay SDK can bridge the gap while structural work continues.</strong> Solutions like Accsible give organizations immediate accessibility features that benefit users now, while deeper remediation work proceeds — demonstrating commitment and improving usability in parallel with longer-term code fixes.</li> </ul>