Planned Reforms to Türkiye’s Legal Framework for Trade and Investment

The Medium-Term Programme for 2027–2029, published in the Official Gazette on 6 September 2026, envisages a range of legal reforms affecting trade and investment. The principal areas covered include personal data protection, dispute resolution, enforcement and insolvency law, investment procedures and public procurement.

For companies with operations or commercial interests in Türkiye, the Programme provides an overview of forthcoming legislative and regulatory priorities. Implementation of the proposed reforms remains subject to the adoption of the relevant legislation and administrative measures.

Data Protection and Artificial Intelligence

The Programme envisages completing the alignment of Türkiye’s Personal Data Protection Law No. 6698 with the EU General Data Protection Regulation in the third quarter of 2027. It also provides for the development of a national legal framework for artificial intelligence, taking account of alignment with the EU, in the first quarter of 2027.

These proposals are relevant to European companies with subsidiaries, employees, customers or technology partners in Türkiye. The substance of the amendments will determine their implications for data governance, compliance arrangements and cross-border operations. The Programme itself does not specify the proposed changes to data transfer rules.

Dispute Resolution and Judicial Procedures

The Programme seeks to expand the use of arbitration and strengthen alternative dispute resolution. It also envisages developing online dispute resolution platforms and electronic hearings, establishing specialised courts in areas identified through impact assessments, and extending electronic notification practices.

The timetable places measures concerning judicial efficiency, digital proceedings and the establishment of specialised courts in the second quarter of 2027. Their practical significance for commercial parties will depend on the scope of the implementing measures and their effect on the duration and predictability of proceedings.

Enforcement, Insolvency and Concordat Proceedings

An update to enforcement and insolvency legislation is planned, with preparatory work for legislation scheduled for the second quarter of 2027. The Programme separately calls for legislative work to prevent abuse of concordat proceedings and address difficulties arising from their operation in commercial practice.

These proposals warrant attention from suppliers, lenders and investors with exposure to Turkish counterparties. Changes in this area may affect debt recovery and the treatment of claims where a counterparty encounters financial difficulties. The Programme does not yet set out the proposed amendments to creditor rights or restructuring procedures.

Investment Procedures and Administrative Coordination

The Programme aims to reduce administrative burdens associated with company formation, business operations, investment, foreign trade and liquidation. A One-Stop Office intended to simplify business and investment procedures is scheduled for the second quarter of 2027.

It also envisages establishing an Investment Coordination and Conciliation Board to address administrative and implementation issues between investors and public authorities through coordination and agreement before they reach litigation or arbitration. The Board’s powers, procedures and relationship with existing remedies remain to be defined.

Emissions Trading and Trade with the EU

The Programme provides for strengthening the alignment of Türkiye’s Emissions Trading System with the EU Carbon Border Adjustment Mechanism in the first quarter of 2027. Measures concerning participation in international carbon markets and the use of carbon credits are scheduled for the following quarter.

For European businesses sourcing from emissions-intensive industries in Türkiye, these developments are relevant to supply costs, emissions information and supplier compliance.

The Programme also envisages continued engagement with EU institutions and Member States on modernising the EU–Türkiye Customs Union. It does not announce an agreed revision or a timetable for completing negotiations.

Public Procurement and Market Surveillance

Preparatory work for public procurement legislation is scheduled for the first quarter of 2027. The proposed revision would support digitalisation, innovation and sustainability, with reference to international norms and standards, and introduce rules for sectoral public procurement.

The establishment of a Market Surveillance and Inspection Authority is envisaged for the second quarter of 2027. Its stated purpose is to consolidate activities currently undertaken by different authorities, improve consistency and avoid duplication. These proposals are relevant to companies participating in Turkish public tenders or placing products on the Turkish market.

Implementation Timetable

The timetable requires particular care. For measures identified as requiring legislation, Annex 3 refers to completion of the technical and administrative work for submission to the Turkish Grand National Assembly. The dates should therefore not be read as deadlines for parliamentary adoption or entry into force.

The Programme provides a basis for identifying forthcoming areas of legal change. Assessment of their effect on contracts, investments and compliance obligations will require review of the subsequent proposals and implementing rules, including any transitional provisions.

Author

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Ömer Faruk Çıkın