Turkey Presidential Circular 2025/10 — Web & Mobile Accessibility: Overview and Scope

Overview

Presidential Circular No. 2025/10, titled "Web Siteleri ve Mobil Uygulamaların Erişilebilirliği" (Accessibility of Websites and Mobile Applications), is a landmark directive issued by the Presidency of the Republic of Türkiye. It establishes a comprehensive legal and technical framework requiring that websites and mobile applications be designed and maintained so that they are fully accessible to persons with disabilities and the elderly — groups that have historically faced significant barriers in engaging with digital services.

The core problem the circular addresses is straightforward but consequential: as government services, commerce, healthcare, education, banking, and transport have migrated online, people who are blind, have low vision, are deaf or hard of hearing, or have motor or cognitive impairments have been systematically excluded from equal participation in digital life. The circular signals a national commitment to reversing this exclusion and aligning Türkiye's digital governance with international human rights standards.

Beyond equal access for users, the circular introduces governance machinery — dedicated monitoring, advisory, and internal review commissions — to ensure ongoing compliance rather than one-time, checkbox-style remediation. It also creates a positive incentive in the form of an official Erişilebilirlik Logosu (Accessibility Logo) that qualifying organizations may display, signalling to the public that their digital services meet the required standards.

The timing of the circular is significant. It coincides with the entry into force of the European Accessibility Act (EAA) in the EU and reflects a broader global trend toward legislatively mandated digital inclusion. For organizations operating in or seeking to enter the Turkish market, understanding the circular's scope, timelines, and technical requirements is now a compliance imperative.

Legal Basis

The circular rests on a layered legal foundation of existing Turkish statutes and international commitments:

• Presidential Circular No. 2025/10 — published in the Resmî Gazete (Official Gazette of the Republic of Türkiye), dated 21 June 2025, Issue No. 32933. The full text is available at: https://www.resmigazete.gov.tr/eskiler/2025/06/20250621-17.pdf. The circular entered into force on its publication date.
• Law No. 5378 — Engelliler Hakkında Kanun (Law on Persons with Disabilities), enacted 1 July 2005, entered into force 7 July 2005. Article 15 of this law establishes that the accessibility of information and communication technologies (ICT), including web-based information services, is a legal obligation for public bodies. Presidential Circular 2025/10 operationalises and extends this obligation to a broader set of private-sector actors.
• Law No. 6563 — Elektronik Ticaretin Düzenlenmesi Hakkında Kanun (Law on the Regulation of Electronic Commerce), enacted 23 October 2014. The circular uses the scope of this law to define which e-commerce service providers are subject to the two-year compliance timeline.
• Law No. 4925 — Karayolu Taşıma Kanunu (Road Transport Law), which defines the category of private road-transport companies brought within scope.
• Türkiye's ratification of the UN Convention on the Rights of Persons with Disabilities (CRPD), which entered into force domestically on 28 September 2009, providing the international human rights anchor for the circular's objectives.

The Ministry of Family and Social Services (Aile ve Sosyal Hizmetler Bakanlığı) is the lead body responsible for publishing the reference checklist, coordinating monitoring activities, and awarding the Accessibility Logo. Compliance standards and working procedures for the commissions established under the circular are to be set by the Ministry and published on its official website at www.aile.gov.tr.

Who Is Obligated?

The circular explicitly lists two tiers of covered entities, distinguished by their compliance deadline:

Tier 1 — 1-Year Compliance Deadline (from 21 June 2025)

The following categories of organizations must bring their websites and mobile applications into conformance within one year of the circular's publication (i.e., by 21 June 2026):

• Public institutions and organizations (kamu kurum ve kuruluşları)
• Universities (üniversiteler)
• Municipalities (belediyeler) and municipality-owned companies, enterprises, and affiliates
• State-owned enterprises (kamu iktisadi teşebbüsleri)
• Professional organizations with public institution status (kamu kurumu niteliğindeki meslek kuruluşları)
• Banks (bankalar)
• Private hospitals (özel hastaneler)
• Private educational institutions authorized by the Ministry of National Education (Millî Eğitim Bakanlığı izniyle açılan özel öğretim kurumları)
• Private organizations providing passenger transport services under the Road Transport Law No. 4925, including road vehicles, passenger ships, railway, and airline operators
• Group A travel agencies holding an operating license from the Ministry of Culture and Tourism (Kültür ve Turizm Bakanlığından işletme belgesi alan A Grubu acenteler)
• Telecommunications operators active in the electronic communications sector with more than 200,000 subscribers

Tier 2 — 2-Year Compliance Deadline (from 21 June 2025)

The following category must comply within two years (i.e., by 21 June 2027):

• E-commerce service providers subject to Law No. 6563 on the Regulation of Electronic Commerce

The broader intent of the circular is universal: all entities delivering digital services in Türkiye should move toward accessibility, even if they are not immediately listed as obligated parties. The Monitoring Commission established under the circular has authority to expand its review activities over time.

Technical Requirements

The circular designates two co-equal technical reference points that obligated organizations must satisfy:

1. Web Siteleri ve Mobil Uygulamaların Erişilebilirliği Kontrol Listesi — A Seviyesi (Websites and Mobile Applications Accessibility Checklist — Level A), developed and published by the Ministry of Family and Social Services. This checklist translates international WCAG criteria into a nationally standardized assessment tool.
2. Web İçeriği Erişilebilirlik Kılavuzu (WCAG) 2.2, published by the World Wide Web Consortium (W3C). WCAG 2.2 is the current internationally recognized standard for digital content accessibility and covers a wide range of disability types including visual, auditory, motor, and cognitive impairments.

Minimum mandatory standard: WCAG 2.2 Level A. Every covered organization must meet at minimum the Level A success criteria. Level A represents the baseline — it targets the most critical barriers that prevent users with disabilities from accessing digital content at all.

Required for the Accessibility Logo: WCAG 2.2 Level AA. Organizations that wish to earn and display the official Accessibility Logo must demonstrate conformance with Level AA, which includes all Level A criteria plus additional criteria that address a wider range of disability scenarios, such as sufficient color contrast, captions for live audio, and accessible navigation landmarks.

Key technical areas covered by WCAG 2.2 Level A and AA include:

• Perceivable: Text alternatives for non-text content; captions and audio descriptions for multimedia; adaptable content presentation; sufficient color contrast (AA).
• Operable: Full keyboard accessibility; no seizure-inducing content; navigable structure with descriptive page titles and focus order; visible focus indicators (AA).
• Understandable: Readable and predictable content; error identification and suggestions in forms.
• Robust: Content that is compatible with current and future assistive technologies, including screen readers and switch controls.

WCAG 2.2, published as an official W3C standard in October 2023, added nine new success criteria compared to WCAG 2.1, with particular improvements for users with cognitive and learning disabilities and mobile device users. Notably, WCAG 2.2 removed the previously controversial Success Criterion 4.1.1 (Parsing), which had been a source of confusion in automated testing.

Covered organizations are expected to conduct technical accessibility testing of both their websites and mobile applications. The circular's governance framework — involving an internal Review Commission within each organization, an external Advisory Commission, and the central Monitoring Commission — anticipates a structured, repeatable audit process rather than a one-time review.

Governance and Monitoring Framework

The circular establishes three distinct bodies to oversee and support implementation:

• İzleme Komisyonu (Monitoring Commission) — Chaired by the Minister of Family and Social Services. Responsible for systematically reviewing the accessibility of covered organizations' digital platforms, producing annual work plans, and publishing outcome reports. Organizations found to be compliant are awarded the Accessibility Logo for a two-year period.
• Danışma Komisyonu (Advisory Commission) — Chaired by a Deputy Minister and composed of relevant public and civil society stakeholders. Provides guidance on implementation, addresses ambiguities, and supports sector-wide capacity building.
• İnceleme Komisyonları (Internal Review Commissions) — Established within each covered organization. Responsible for conducting technical accessibility tests of the organization's own digital platforms using the Ministry's checklist and WCAG 2.2 as the reference framework.

The working procedures of all three commissions are to be determined by the Ministry of Family and Social Services. Monitoring results are announced publicly by the Minister, creating a reputational mechanism alongside the formal logo incentive.

Implementation Steps

1. Determine your deadline. Identify whether your organization falls into Tier 1 (one-year deadline, by 21 June 2026) or Tier 2 (two-year deadline, by 21 June 2027) based on the entity type categories listed in the circular.
2. Download the official reference documents. Obtain the Ministry of Family and Social Services' Accessibility Checklist (Level A) from www.aile.gov.tr, and review the WCAG 2.2 guidelines at https://www.w3.org/TR/WCAG22/. These two documents together define your compliance target.
3. Establish an Internal Review Commission. Designate responsible personnel within your organization to form the İnceleme Komisyonu. This team should include web developers, UX designers, content editors, and ideally someone with lived experience of disability.
4. Conduct a baseline accessibility audit. Run both automated scanning tools and manual testing against WCAG 2.2 Level A (and Level AA if you are targeting the Accessibility Logo) across your website and all mobile applications. Document all failures with severity classifications.
5. Prioritize and remediate. Address critical Level A failures first — these prevent core task completion for users with disabilities. Then work through Level AA failures. Common priority fixes include: adding alt text to images, enabling full keyboard navigation, ensuring sufficient color contrast, providing captions for video content, and making forms accessible with proper labels and error descriptions.
6. Test with real assistive technologies. Verify remediated content using screen readers (such as NVDA, JAWS, or VoiceOver), keyboard-only navigation, and mobile screen reader tools (TalkBack on Android, VoiceOver on iOS). Automated tools catch approximately 30–40% of WCAG failures; manual testing is essential for the rest.
7. Publish an accessibility statement. Although the circular does not explicitly mandate a formal public accessibility statement, best practice — and the spirit of the regulation — calls for publishing a statement on your website declaring your conformance level, known limitations, and a contact channel for users to report accessibility barriers.
8. Integrate an accessibility overlay widget. Tools such as the Accsible widget SDK provide an additional layer of user-facing accessibility controls (text resizing, contrast modes, keyboard navigation aids, screen reader optimizations) that complement code-level remediation and help bridge remaining gaps for diverse users.
9. Submit for Monitoring Commission review. Once your organization has completed internal remediation and testing, engage with the Monitoring Commission process coordinated by the Ministry of Family and Social Services. Successful evaluation results in the official two-year Accessibility Logo grant.
10. Maintain and monitor continuously. Accessibility is not a one-time project. Establish processes so that new content, features, and third-party integrations are reviewed for accessibility before publication. Schedule periodic re-audits and update your internal commission's work plan annually.

Frequently Asked Questions

What is the exact compliance deadline for public sector organizations?

Public institutions, universities, municipalities, state-owned enterprises, banks, private hospitals, private schools (licensed by the Ministry of National Education), private passenger transport operators, Group A travel agencies, and telecom operators with more than 200,000 subscribers must comply within one year of the circular's publication date of 21 June 2025 — that is, by 21 June 2026.

When must e-commerce companies comply?

E-commerce service providers regulated under Law No. 6563 have a two-year compliance window, meaning their deadline is 21 June 2027. This longer timeline reflects the large number and variety of businesses in the e-commerce sector and the potentially higher technical complexity of their digital platforms.

What exactly counts as compliant under the circular?

Compliance means that your website and mobile applications conform to both the Ministry of Family and Social Services' Accessibility Checklist at Level A and the Web Content Accessibility Guidelines (WCAG) 2.2 at a minimum of Level A. To earn the official Accessibility Logo, your platforms must meet WCAG 2.2 Level AA. Compliance is assessed through the monitoring process conducted or overseen by the Monitoring Commission, not by self-declaration alone.

What is the Accessibility Logo and how do we get it?

The Erişilebilirlik Logosu (Accessibility Logo) is an official mark awarded by the Ministry of Family and Social Services to organizations whose websites and mobile applications have been reviewed by the Monitoring Commission and found to meet the required accessibility standards. The logo is granted for a period of two years, after which re-evaluation is required. It serves as a public signal of the organization's commitment to digital inclusion and may become a procurement or reputational differentiator over time. Organizations should monitor the Ministry's website (www.aile.gov.tr) for the formal application and review procedures.

Are there penalties for non-compliance?

The circular itself is a Presidential Circular rather than a statute, and it does not directly prescribe new standalone penalties. However, the underlying Law No. 5378 on Persons with Disabilities already carries enforcement provisions for failures to provide accessible ICT services by public bodies, and the Human Rights and Equality Institution of Türkiye (TİHEK) has authority to address discrimination on grounds of disability under Law No. 6701. As the Monitoring Commission becomes operational and begins publishing compliance results publicly, reputational consequences and the potential invocation of existing administrative enforcement mechanisms under Law No. 5378 will increase. Organizations are strongly advised to treat the deadlines as firm.

Does the circular apply to mobile apps as well as websites?

Yes. The circular explicitly covers both websites and mobile applications. WCAG 2.2 and the Ministry's checklist apply to both platforms. Mobile-specific considerations include touch target sizes, gesture alternatives, screen reader compatibility (VoiceOver on iOS and TalkBack on Android), and proper use of native accessibility APIs. Organizations with both a web presence and a mobile app must ensure both are compliant by their applicable deadline.

Our organization is a small private school — do we have to comply?

Yes. Private educational institutions that have been authorized to operate by the Ministry of National Education (Millî Eğitim Bakanlığı izniyle açılan özel öğretim kurumları) are explicitly listed in the circular's one-year compliance tier. This means their websites and mobile applications must meet the required accessibility standards by 21 June 2026. The size of the institution is not a stated exemption factor under the current circular. Schools should begin their accessibility audits promptly to allow sufficient time for remediation before the deadline.

How does this circular relate to international frameworks like the EU's European Accessibility Act?

Presidential Circular 2025/10 is Türkiye's national equivalent of the wave of digital accessibility legislation now taking effect globally. It references the same underlying international standard — WCAG 2.2 — used in the EU's Web Accessibility Directive and informing the European Accessibility Act. While Türkiye is not an EU Member State and is not bound by the EAA directly, the convergence on WCAG 2.2 as the shared technical benchmark means that organizations that achieve compliance with one framework will have significantly reduced effort needed to comply with the other. For businesses operating in both markets, the circular and the EAA should be addressed together as part of a unified digital accessibility programme.