Türkiye'de konutların turizm amaçlı kısa süreli kiralanması, 1 Ocak 2024 tarihinde yürürlüğe giren 7464 sayılı Konutların Turizm Amaçlı Kiralanmasına ve Bazı Kanunlarda Değişiklik Yapılmasına Dair Kanun (Resmî Gazete: 02.11.2023, sayı 32357) ile permit-first bir modele bağlanmıştır. The implementing regulation (Konutların Turizm Amaçlı Kiralanması Faaliyetlerinin Düzenlenmesine İlişkin Yönetmelik, RG: 28.12.2023, sayı 32413, with subsequent amendments through 33043 of 10 October 2025) operationalises the permit framework administered by the Ministry of Culture and Tourism (Kültür ve Turizm Bakanlığı). Foreign hosts must understand that licensing is not a city hall formality — compliance spans central authorisation under Law 7464, condominium approvals under Law No. 634, platform hygiene under Law No. 6563 on the Regulation of Electronic Commerce, e-invoicing and tax reporting under Law No. 213, and privacy rules for guest data under Law No. 6698 (KVKK). This guide walks through the permit applicant's journey from eligibility check to operational compliance, with the specific procedural sequence the Ministry expects and the practical traps that catch foreign hosts most often. Where ministries and municipalities update secondary guidance, practice may vary by ministry/municipality and year. ER&GUN&ER Law Firm advises foreign owners on the entire chain — eligibility, unanimous condominium consent, permit application, platform onboarding, safety fit-out, identity reporting, tax configuration, inspection response, and fine appeals — so that the listing and the file tell the same coherent story.
The 2024–2025 Permit-First Model: What Changed for Foreign Hosts
Before Law 7464, short-term rental in Türkiye operated under a patchwork of municipal practice and tax-side reporting, with no central permit framework specific to tourism-purpose dwellings. The Law changed the architecture by creating a single ministerial permit (izin belgesi) as the precondition for any rental of 100 days or less for tourism purposes (Article 2 of Law 7464). The permit issuer is the Ministry of Culture and Tourism through its central application portal and provincial directorates of culture and tourism. The permit binds the unit, not just the host, which is why building-level consent is required at the application stage rather than imposed afterwards.
The model rests on three pillars. The first pillar is the unanimous condominium owners' resolution under Article 3 of Law 7464, which gives every co-owner in a multi-unit building a veto over tourism-purpose rental from any unit in the building. The second pillar is the permit itself, which carries unit-specific scope (capacity, address, host identity) and forms the documentary basis for everything that follows. The third pillar is the platform-level enforcement mechanism under Article 5 in conjunction with Law 6563: intermediary service providers (Airbnb, Booking.com, and equivalent platforms) face administrative fines of TRY 100,000 per dwelling for failing to remove unpermitted listings within 24 hours of ministerial notice, which has produced active permit-verification programmes by the platforms themselves.
For foreign hosts, the practical consequences are: the permit application is procedurally rigorous and document-heavy; the unanimous consent requirement is often the binding constraint, not the application itself; the platform will not list a unit indefinitely without the permit number; and the administrative fine structure under Article 5 makes operating without a permit substantially more expensive than the permit-acquisition cost. Practice may vary by ministry/municipality and year on specific procedural details; the Ministry has refined the application portal and the document checklist multiple times since the regulation came into force.
Eligibility Pre-Filing: Zoning, Iskan, and Building Bylaws
The first step is determining whether the unit is eligible at all. Under the implementing regulation, only units with residential title classification (tapu sicilinde konut amaçlı kayıtlı) are eligible — commercial-classification units, mixed-use spaces classified outside residential, and units in buildings without an occupancy permit (iskan ruhsatı) generally cannot obtain the permit. A frequent surprise for foreign owners is that a commercially-marketed apartment turns out to be classified under a different use category in the title register, which forecloses the application before the consent stage even begins.
The next eligibility filter is the building's management plan (yönetim planı) and bylaws (tüzük) under Law No. 634 on Condominium Property. Many older Istanbul buildings have management plans that restrict the use of units to residential occupation only, with hospitality and tourism activities expressly prohibited. A management plan ban on tourism-purpose use is generally treated by inspectors as dispositive — even unanimous consent of current owners cannot override a recorded prohibition without amending the management plan first, which itself requires unanimous consent under Law 634. We review the management plan as the first document on every short-term rental file because it determines whether the entire exercise is feasible.
Local zoning overlays add a further filter. Tourism-zone designations, heritage area protections, and specific district-level restrictions can preclude or condition the permit even where building-level eligibility is satisfied. Confirm zoning status with the relevant municipality before investing in fit-out or marketing assets, particularly in historical neighborhoods of Istanbul (Sultanahmet, Galata, Beyoğlu, Cihangir) where additional restrictions on commercial signage and arrival logistics may apply. Practice may vary by ministry/municipality and year on the specific zoning overlay; the Ministry of Culture and Tourism has published guidance on tourism-priority districts that signals where additional scrutiny is likely.
The Unanimous HOA Consent Requirement and How to Obtain It
Article 3 of Law 7464 requires the applicant to submit, where the dwelling is in a building with multiple independent units, a resolution of the condominium owners' meeting (kat malikleri kurulu) adopted unanimously approving the use of the specific unit for tourism-purpose rental. The unanimity requirement is operationally significant: a single objecting co-owner blocks the application. There is no quorum-based or majority-based path to consent under the Law as currently drafted; the Ministry will not accept resolutions that proceed on a majority vote even if the management plan otherwise permits majority decisions.
The path to a unanimous resolution begins with individual engagement. Identify each co-owner from the management's records, understand their concerns (noise, security, building wear, neighbor relations), and address the substantive concerns through commitments embedded in the resolution: capacity caps, quiet hours, designated check-in windows, security deposit arrangements, supplementary cleaning fees to the building, and a defined complaint-resolution channel. We have seen unanimous resolutions obtained with the host committing to capacity limits below the unit's physical capacity, to staff presence at the building during peak arrival hours, and to additional contributions to common-area maintenance — all of which translate co-owner concerns into operational conditions the host can actually deliver.
The meeting itself must follow the procedural requirements of Law 634: written notice to all owners with the agenda items specified, conducted at the time and place noticed, with minutes signed by the chairman and the building manager. The Ministry's regulation prescribes the documentary form for the resolution attachment to the permit application; deviations from the prescribed form trigger procedural rejection and re-filing. For "high-quality residences" (yüksek nitelikli konut) operated by licensed building management companies — typically modern serviced-apartment buildings with onsite reception, security, and housekeeping — the implementing regulation provides a streamlined regime where the management company holds the permit on behalf of the building, simplifying the consent dynamic for that specific category.
Permit Application: Portal, Documents, and Address String Discipline
The permit application is filed through the Ministry's electronic portal, with documentary uploads of the unanimous owners' resolution, the title register extract, the host's identity documentation (Turkish ID for citizens, passport plus tax number for foreign nationals), the building manager's confirmation, floor plans showing unit configuration, safety attestations, and contact details for inspections. The portal validates the standardized municipal address against central address registers; mismatches between the title register address, the permit address, the platform listing address, and the utilities address account for a high proportion of application returns.
Address string discipline is operationally important. Turkish addresses follow a specific format (mahalle, sokak, no, kat, daire) and the Ministry's portal performs automated reconciliation against the National Address Database. Standardise the address across all documents before filing — title, tax registration, utilities, building registration, and the platform listing — using the format the National Address Database recognises. Where the platform stores the address differently from the Turkish standard format, manually align the platform listing with the standardised string at the point of permit acquisition. Foreign hosts often miss this step because their home-jurisdiction address conventions do not map cleanly to the Turkish format.
Upload discipline matters at the portal stage. The Ministry expects PDF/A documents, signed where signature is required, with consistent file naming and version control. Maintain a parallel local folder mirroring the portal upload set, with screenshots of each successful upload and the portal-generated confirmation receipts. If an agent files on your behalf under a power of attorney, require the agent to provide receipt numbers, screenshots, and the document list; the absence of these creates audit gaps if the application later requires supplementation. Practice may vary by ministry/municipality and year on portal interface details; periodic updates to the upload templates and document categories require version-checking before each filing.
Safety Fit-Out and Signage Requirements
The implementing regulation specifies safety equipment requirements that must be in place at the time of inspection and maintained throughout the operation. Standard items include smoke detectors and (where gas appliances are present) carbon monoxide detectors in working order, portable fire extinguishers serviced within acceptable periods, visible evacuation maps in Turkish and English, emergency lighting in hallways, and a clearly posted internal house-rules sheet covering quiet hours, waste disposal, elevator etiquette, and emergency contacts. Treat each safety item as a line in your evidence pack: invoices, service slips, device serial numbers, dated photos of installation points, and a signed checklist verifying the unit's compliance status on the morning of first listing.
Signage and door-plate requirements are prescribed by the implementing regulation and supplemented by ministerial guidance. The permit code must be displayed on a designated plate at the unit entrance, in a format prescribed by the Ministry, with QR code where required for inspector verification. Improvising the plate format is a common reason for re-visits and corrective findings. Coordinate the plate placement with the building manager to respect any management plan restrictions on hallway signage; some buildings prohibit commercial advertising in common areas, which requires the plate to be placed inside the unit door rather than externally.
Inside the unit, guest-facing information should be readable and enforceable. Provide a laminated sheet near the entrance with the building's standardized address (matching emergency services databases), Wi-Fi details, the universal emergency number 112, the nearest hospital and pharmacy names, and clear instructions on what to do in a fire or earthquake. The earthquake section is particularly important in seismically active areas and sits alongside the host's compulsory earthquake insurance (DASK) — see DASK guidance. Maintain a "pre-inspection reset" routine between stays: test alarms, photograph fire-safety items, confirm evacuation maps and rule sheets are still on the wall. This fifteen-minute rhythm reduces the probability that a surprise visit finds something out of place.
Platform Onboarding: Permit Upload and Listing Hygiene
Major platforms (Airbnb, Booking.com, Vrbo) operate active permit-verification programmes for Turkish listings driven by their exposure to the Article 5 administrative fines of TRY 100,000 per dwelling for non-removal within 24 hours of ministerial notice. Upload the permit document and the permit number through the platform's verification flow; the platform will display a verified-host indicator and unblock listing publication for verified units. Mismatches between the permit address and the listing address trigger automated removal even if the permit is itself valid; align the address strings before the platform's automated check runs.
Listing copy should reflect the actual scope of the permit and avoid hospitality language that could trigger broader regulatory obligations. Avoid promises of "concierge service," "daily housekeeping in common areas," "breakfast service," or other amenities that suggest hotel-class hospitality — these are inconsistent with the residential-permit scope and can attract findings from both the Ministry of Culture and Tourism and from municipal hospitality enforcement teams. Capacity stated in the listing must match the permit's authorised capacity; over-stated capacity invites both regulatory attention and neighbor complaints.
Identity and check-in discipline protects both guests and hosts. Capture guest details in line with Law No. 1774 on the Notification of Identity (which requires accommodation providers to notify the local police or gendarmerie of guest identity through the designated electronic system) and platform policies. If you use self-check-in, smart locks with audit logs are operationally preferable to keyboxes that attract attention in lobbies; access codes should rotate after each stay. Maintain a guest communications log with timestamped pre-arrival, arrival, and departure messages including house-rules reminders, so that complaint investigations can be answered with the exact message and time.
Tax Registration and E-Document Configuration
Revenue from short-stay rentals sits inside the Turkish tax and e-document perimeter. The host's tax position depends on the host's structure (individual or company), volume of activity, and Turkish tax residency status. Individual hosts above defined activity thresholds and all corporate hosts typically fall under e-archive or e-invoice obligations under Tax Procedure Law (Law No. 213) and the implementing General Communiqués on Electronic Document Application issued by the Revenue Administration. Configure the e-document infrastructure before the first booking is accepted, not retrofitted after the fact.
The reconciliation discipline matters more than the specific document type. Each booking should generate an e-document that ties to the platform reservation reference, the guest identity (per Law 1774 reporting), the stay dates, and the payment received. Maintain a monthly export of e-documents with the platform payout reports and bank statements; the reconciliation memo demonstrates how the ledger ties together for the period. When a Revenue Administration inspector requests reconciliation, the dated folder for each period typically resolves the inquiry without further investigation.
VAT (KDV), withholding, and income-tax intersections depend on the host's structure and the rental activity profile. Engage an accountant who understands the short-stay sector; align the rental reporting with personal tax residency planning where the host is mobile (see tax residency for foreigners). Avoid mixing platform receipts with off-platform cash transactions; mismatches between reported revenue and platform-payout records produce the most common Revenue Administration audit triggers in this sector. Practice may vary by ministry/municipality and year on the specific e-document thresholds and the application of VAT rules; the Revenue Administration has refined the rules multiple times since 2020.
Identity Reporting Operations Under Law 1774
Law No. 1774 on the Notification of Identity (Kimlik Bildirme Kanunu) requires accommodation providers — including short-term rental hosts under Law 7464 — to notify guest identity information to the local police or gendarmerie through the designated electronic system. The notification must occur within the prescribed window (typically at check-in) and must include the guest's identity document data (passport for foreign guests, Turkish ID for Turkish guests), the stay dates, and the host's identifier. Configure the reporting account before accepting bookings and train any operational staff or representatives on the field requirements.
The data minimisation principle from KVKK applies in parallel: collect only what Law 1774 requires for the report, store only for the period required by the retention rules, and avoid additional collection that lacks a legal basis. Aligning the booking flow with the Law 1774 reporting fields prevents ad-hoc data collection through chat messages or non-auditable channels — both of which create KVKK exposure without any compliance benefit. Spot-check the reporting weekly; discrepancies between the reported data and the actual booking data should be corrected through the reporting system rather than accumulated for later cleanup.
For foreign hosts, the operational risk is missing the reporting window because of time zone or unfamiliarity with the system. Where the host is abroad, the reporting can be delegated to a local representative or a property management company under a clear scope-of-authority arrangement. The delegation should be documented in writing and include access controls to the reporting account; the Law 1774 reporting account is host-specific and the host remains legally responsible for accurate and timely reporting regardless of who operationally performs the task.
Inspection Day: Documents, Behavior, and Findings
Unannounced visits by the provincial directorate of culture and tourism, by the Ministry's central inspectors, by the local zabıta (municipal enforcement), or by joint teams covering multiple regulatory mandates have become the operational norm in tourism-priority districts. The standard inspection covers the permit and its current validity, the unanimous owners' consent and its alignment with the operational reality, the safety equipment and signage, the identity reporting status, sample e-documents for recent stays, and physical inspection of the unit's condition.
The first principle of inspection response is documentary rather than narrative. A single bound or digital file with the permit, owners' resolution, building manager confirmation, safety equipment evidence with dated photos, identity reporting confirmations for recent stays, e-document samples, insurance certificates (DASK and liability), and an indexed table of contents enables the inspector to verify each item by reference to a page rather than by interrogation. The inspection that takes thirty minutes with a clean file would otherwise take two hours of conversation and produce findings that the file would have prevented.
If the inspector identifies a deficiency, ask for the specific legal basis and the specific factual finding, and record both in your follow-up log. Acknowledge findings that are valid; contest findings that are not, with documentary evidence rather than verbal protest. The inspection minutes (tutanak) should be reviewed before signing; sign with reservations where the minutes mischaracterise the facts, and submit a separate written statement attaching exhibits within the prescribed window. The Administrative Procedure Law (Law No. 2577) governs the appeal route for any administrative fine that follows from the inspection; the appeal must be filed within the statutory window from notification, with documentary evidence supporting the contestation.
The Article 5 Administrative Fine Ladder
Article 5 of Law 7464 establishes a structured set of administrative fines for non-compliance. Operating a tourism-purpose rental without an izin belgesi attracts the base fine for unpermitted operation. Allowing a permitted dwelling to be used outside the permit scope (capacity exceeded, sub-letting in violation of Article 3(7), use category drift) attracts proportionate fines. Intermediating an unpermitted rental — typically applicable to property management agencies operating without proper authorisation — attracts a fine of TRY 100,000 per contract. Enabling unpermitted listings on an electronic commerce platform without removing the listing within 24 hours of ministerial notice attracts a fine of TRY 100,000 per dwelling. Entering into more than four rental contracts of more than 100 days for the same dwelling within a single year attracts a fine of TRY 1,000,000. Failure to provide information requested by the Ministry within 30 days, or providing incomplete or misleading information, attracts a fine of TRY 50,000.
Specific monetary amounts are subject to revaluation under standard administrative-fine indexation (the revaluation rate published annually by the Ministry of Treasury and Finance), so the absolute figures change each year while the ratios between fine categories remain stable. Practice may vary by ministry/municipality and year on the specific fine levels in effect at the time of any given enforcement action; check the current revalued figures before relying on the prior-year amounts.
The escalation philosophy is progressive: first findings often produce warnings or initial penalties with cure deadlines, while repeated or willful non-compliance triggers higher fines, temporary suspension of the permit, and platform-side delisting. The defence strategy is preventive — coherent evidence pack, accurate listing, current safety equipment, working identity reporting, reconciled e-documents — but where a notice issues, read the notice carefully (many provide cure windows), respond in the format and channel specified, and treat factual errors in the notice as opportunities to present corrective documentation. Where the substantive finding is contested, the appeal under Law 2577 is the formal route; informal appeals through email or platform chat have no procedural effect and risk missing the appeal window.
Tenants vs Guests: Contracting Boundaries
The 100-day boundary in Article 2 of Law 7464 is the formal divider between tourism-purpose rental (within the Law's scope) and standard tenancy (governed by the Code of Obligations, Law No. 6098, leases). Rentals up to 100 days require the permit and follow the Law 7464 architecture; rentals exceeding 100 days fall outside Law 7464 and are governed by the standard residential lease rules. The duration triggers the regime classification, not the labels the parties choose to apply. Repeated 100+ day contracts for the same dwelling in the same year attract the TRY 1,000,000 administrative fine under Article 5 — the Ministry has been clear that the rule prevents using long-stay contracts as a route around the permit requirement.
For stays squarely within the short-stay range, the contracting documentation should reflect the hospitality character: clear arrival and departure times, house-rules incorporated by reference and acknowledged digitally before arrival, deposit mechanics through escrow or platform-managed payment rails, and condition documentation through dated photographs at check-in and check-out. The Code of Obligations consumer-protection provisions apply alongside the tourism-rental framework, particularly for cancellation rights and refund obligations under Law No. 6502 on Consumer Protection where the platform classifies the booking as a consumer transaction.
Article 3(7) of Law 7464 expressly prohibits the tenant of a residential lease from sub-letting that dwelling for tourism purposes on the tenant's own account. The provision closes the most common workaround attempted by hosts who do not own the unit — leasing a dwelling and then sub-letting on Airbnb. Property management arrangements where the management company holds permits on behalf of multiple owners are structurally different and operate within the Law's framework, but informal sub-letting by tenants is unambiguously prohibited and triggers fine exposure for both the tenant and the landlord (where the landlord is found to have known or should have known).
KVKK Data Compliance for Guest Information
Short-term rental operations process personal data — passport copies, contact details, payment information, booking history, and (through Law 1774 reporting) identity information transmitted to law enforcement. All of this is subject to Law No. 6698 on the Protection of Personal Data (KVKK), which requires a lawful basis for processing, data minimisation, retention discipline, and security measures. Publish a concise privacy notice at booking and at check-in explaining what is collected, the legal basis (Law 1774 reporting and contract performance for the rental), where it is stored, and when it is deleted.
Controller and processor roles must be documented. The host is the controller of the data the host decides to collect; the platform is the controller of its booking and account data flows; vendors (cleaning service, smart-lock provider, security service) are processors requiring written data processing agreements (DPAs) and access limits. Maintain a data map listing the systems involved, the data they process, the locations of storage, and the retention periods. If the KVKK Board (Kişisel Verileri Koruma Kurulu) requests this information during a sectoral inquiry, presenting the documented map is materially faster than reconstructing the flows under inquiry pressure.
Cross-border data transfers — common where the platform's servers, the property management software, or the host's own systems are outside Türkiye — require lawful transfer mechanisms under KVKK Articles 9. The standard mechanisms are explicit consent (limited utility for ongoing operational transfers), adequacy decision (limited country list), or undertakings approved by the KVKK Board. Where the platform itself is the data controller for the booking flow, the cross-border transfer occurs at the platform level rather than through the host; documenting this in the privacy notice manages the host's exposure. For the broader posture, see KVKK compliance.
Cross-Border Operations: POA, Bilingual Files, and Bank Rails
Foreign owners frequently manage Turkish short-term rental operations from abroad and need a reliable local representative for permit filings, inspection attendance, and urgent neighbor or building-manager interactions. Issue a narrow power of attorney that authorises the specific acts needed — filing the permit application, attending inspections, receiving notices from the Ministry and the building manager, and limited banking operations for tax filings — and complete the apostille or consular legalisation chain before relying on the instrument operationally. Mechanics and scope patterns are at power of attorney for property.
The local file should mirror the host's home-jurisdiction file with bilingual versions where relevant. Maintain a Turkish authoritative version for filings before the Ministry and the building, and a faithful English summary for the host's reference and platform interactions. The representative should hold a complete digital mirror of the file in a secure cloud folder, with read-only links that can be shared with inspectors during visits. When a formal notice issues, the response must be filed in Turkish through the official channel; informal English communications through email or chat have no procedural effect.
Banking and payment rails should follow the names and tax registrations on the permit. Use named accounts that match the host's permit and tax profile; avoid third-party remitters whose names do not appear on the permit. Where the platform pays through an intermediary account or a payment service provider, document the hop and retain the provider's statements alongside the bank statements for tax reconciliation purposes. For deposits and damage claims, escrow-like solutions described in escrow accounts manage the funds in a documentable way that supports both consumer-law positions and tax reconciliation. For broader cross-border ownership considerations, see top pitfalls for foreign buyers.
Municipal Variations and Local Tourism Zones
While Law 7464 establishes the central permit framework administered by the Ministry of Culture and Tourism, municipal overlays apply specific requirements based on local tourism priorities, heritage protections, and building-stock characteristics. Coastal municipalities (Antalya, Muğla, Izmir districts) emphasise crowding management and exterior signage discipline; dense urban districts of Istanbul (Beyoğlu, Şişli, Beşiktaş) focus on building access control and resident impact; historical neighborhoods (Sultanahmet, Galata, Cihangir, Kadıköy historic core) test visual impact and arrival logistics in narrow streets. Each overlay can affect the permit conditions imposed and the inspection emphasis applied to operational compliance.
Tourism-heavy neighborhoods often see coordinated inspection visits combining provincial Ministry inspectors, municipal zabıta, and (where applicable) tax inspectors in a single visit. Prepare for these visits by rehearsing the file with the local representative and confirming that the listing accurately reflects arrival instructions designed to minimise neighbor disruption. Self-check-in at late hours is discouraged on narrow residential streets and in buildings with strict quiet-hours rules; published arrival windows that respect these constraints reduce the friction that drives complaints and inspections.
Multi-building gated complexes and serviced-apartment buildings often have internal management plans more restrictive than the city-wide rules. Obtain a signed copy of the management plan, retain the meeting minutes for the unanimous owners' resolution that authorised tourism-purpose use, and refresh consent when boards change or when material amendments to the management plan are proposed. Internal governance often determines the operational outcome faster than external regulation; align the listing copy and guest messaging with the building's expectations so that house-rules live where guests will actually see them — on the booking page and inside the unit.
Frequently Asked Questions
- What is the legal basis for short-term rental permits in Türkiye? Law No. 7464 (Konutların Turizm Amaçlı Kiralanmasına ve Bazı Kanunlarda Değişiklik Yapılmasına Dair Kanun) of 25 October 2023, published in the Official Gazette of 2 November 2023 (No. 32357), with the implementing regulation of 28 December 2023 (No. 32413). Both entered into force on 1 January 2024.
- Which Ministry administers the permit? The Ministry of Culture and Tourism (Kültür ve Turizm Bakanlığı), through its central application portal and provincial directorates of culture and tourism.
- What is the 100-day rule? Article 2 of Law 7464 defines "tourism-purpose rental" as rental for a single period of 100 days or less. Rentals exceeding 100 days fall outside Law 7464 and are governed by the tenancy provisions of the Code of Obligations.
- What HOA consent is required? Article 3 of Law 7464 requires a unanimous resolution of all condominium owners (kat malikleri kurulu) for buildings with multiple independent units, approving the use of the specific unit for tourism-purpose rental. A single objecting co-owner blocks the application.
- Can a building's management plan ban short-term rentals? Yes. A management plan ban is generally treated by inspectors as dispositive. Amending the management plan to remove the ban itself requires unanimous consent under Law 634 on Condominium Property.
- Can a tenant sub-let for tourism purposes? No. Article 3(7) of Law 7464 expressly prohibits the tenant of a residential lease from sub-letting that dwelling for tourism purposes on the tenant's own account.
- What identity reporting applies to guests? Law No. 1774 on the Notification of Identity requires accommodation providers (including short-term rental hosts under Law 7464) to notify guest identity information to the local police or gendarmerie through the designated electronic system, typically at check-in.
- What are the platform obligations? Under Article 5 of Law 7464 in conjunction with Law No. 6563 on Electronic Commerce, intermediary service providers (Airbnb, Booking.com, equivalents) face administrative fines of TRY 100,000 per dwelling for failing to remove unpermitted listings within 24 hours of ministerial notice, plus access-blocking measures.
- What are the headline administrative fines under Article 5? Intermediating unpermitted rentals: TRY 100,000 per contract. Platform non-compliance with takedown notice: TRY 100,000 per dwelling. Repeated 100+ day contracts in same year: TRY 1,000,000. Information non-provision: TRY 50,000. Amounts subject to annual revaluation.
- Are e-invoices required? Depending on host structure and activity volumes set by the Revenue Administration under Law No. 213 (Tax Procedure Law) and General Communiqués, e-archive or e-invoice obligations apply. Configure infrastructure before first booking; reconcile monthly with platform payouts and bank statements.
- What insurance is expected? Compulsory earthquake insurance (DASK) for the dwelling. Liability insurance is advisable given the hospitality character of the activity. Align policy use descriptions with the actual permitted activity.
- Can a foreign owner operate while abroad? Yes, with proper representation under a narrow apostilled power of attorney, sworn translation where required, a local address for service, and a trained representative for inspection visits.
- What happens if a listing is paused by the platform? Provide the permit document, the unanimous owners' resolution, safety photos, identity reporting confirmation, and the listing-permit address alignment. The platform's verification team typically reinstates within 24-72 hours of complete documentation.
- How are administrative fines appealed? Through the formal route under the Administrative Procedure Law (Law No. 2577), filed within the statutory window from notification with documentary evidence supporting the contestation. Informal channels have no procedural effect.
- Where does ER&GUN&ER Law Firm support short-term rental matters? Eligibility analysis (zoning, iskan, management plan); HOA consent strategy and resolution drafting; permit application under Law 7464; platform onboarding alignment; safety and signage compliance; identity reporting configuration under Law 1774; KVKK data flow design; e-invoicing reconciliation; inspection response and administrative-fine appeals; tenant-guest classification disputes; and POA mechanics for absentee foreign hosts.
Author: Mirkan Topcu is an attorney registered with the Istanbul Bar Association (Istanbul 1st Bar), Bar Registration No: 67874. His practice focuses on cross-border and high-stakes matters where evidence discipline, procedural accuracy, and risk control are decisive.
He advises foreign and Turkish hosts, building managers, property management companies, and investors operating in the Turkish short-term rental market across Law 7464 Permit Compliance, Condominium Consent Strategy, KVKK Data Compliance, Identity Reporting under Law 1774, E-Invoicing, Administrative Fines and Appeals, Tenant-Guest Classification, and cross-border documentation matters where procedural accuracy and evidence discipline are decisive.
Education: Istanbul University Faculty of Law (2018); Galatasaray University, LL.M. (2022). LinkedIn: Profile. Istanbul Bar Association: Official website.