İYS Consent Rules for AI Phone Calls in Turkey

In Turkey, a phone call made by an AI voice agent is a commercial electronic message under Law No. 6563 if it has a commercial purpose, and as a rule it needs the recipient’s prior consent, recorded in İYS, the national consent register. There are exceptions for calls that answer the person’s own request, for service notifications that contain no promotion and for calls to tradespeople and merchants, but each exception has limits and rules of its own. Whether a person or an AI places the call makes no difference: what matters is the purpose and content of the call.

In this article we look at when a phone call counts as a commercial message, the consent rule and its exceptions, a decision tree you can copy, the content rules that apply during the call, the right to opt out and a checklist to go through before you launch an outbound campaign.

This article is general information, not legal advice. Legislation and practice can change; review your own situation with a lawyer before you start a campaign. Last checked: 2026-10-22.

When does a phone call count as a commercial electronic message?

Article 2 of Law No. 6563 on the Regulation of Electronic Commerce (in Turkish) defines a commercial electronic message as a message with data, voice or image content sent for commercial purposes electronically “by means such as telephone, call centers, fax, automatic dialling machines, smart voice recording systems, e-mail and short message service” (our translation). The list is introduced with “such as”, so the means are examples; nothing in it excludes an AI voice agent that places calls and talks. The real question is not who made the call but whether it has a commercial purpose.

Article 5 of the Regulation on Commercial Communication and Commercial Electronic Messages (in Turkish) lists the purposes that require consent: promoting or marketing goods and services, promoting the business, or “increasing its recognition with content such as celebrations and good wishes”. That last item is easy to miss. Even an automated call wishing customers a happy holiday may be treated as requiring consent, because it aims to raise the business’s profile.

When planning, it helps to sort calls into three groups:

We cover calls that answer a request, especially returning missed calls, in our article on missed calls and automatic callback.

The rule: prior consent recorded in İYS

Under Article 6 of the Law, commercial electronic messages may be sent “only with the prior consent” of recipients. The regulation runs this rule through İYS, the Message Management System:

• Anyone who wants to send commercial electronic messages registers with İYS (Article 5).
• No commercial electronic message may be sent to recipients without consent recorded in İYS (Article 5).
• Consent can be obtained in writing, by electronic means or through İYS; it must be an affirmative statement, and that statement may not be pre-selected in the consent form (Article 7).
• Consents collected outside İYS are registered in İYS within three business days; consents not registered in İYS are deemed invalid (Article 7).
• Giving consent may not be made a precondition for the goods or services you provide (Article 7).

Two details matter in particular for AI calling. First, under Article 7 of the regulation you may not request consent by sending a commercial electronic message to the recipient’s address. Having a voice agent call numbers without consent “to ask for permission” is not a workaround. Second, an opt-out cancels the consent for the channel through which it was made (Article 9); consent and opt-outs work per channel. Before calling, check the number’s consent for calls specifically, and do not rely on consent given for another channel.

Cases that do not require consent, and their limits

Messages about goods or services already supplied

Article 6 of both the Law and the regulation state that, where the recipient has given their contact details so that they can be contacted, no separate consent is needed for messages about changes to, use of and maintenance of the goods or services supplied. Explaining how to use a service someone has bought may fall within this; trying to sell them a new product on the same call goes beyond it.

Service notifications: appointments, deliveries, collections

The second paragraph of Article 6 of the regulation says prior consent is not required for notifications about an ongoing subscription, membership or partnership, collections, payment reminders, updating information, purchases and deliveries “or similar situations”. The same paragraph also sets the limit: in such notifications no goods or services may be encouraged or promoted.

Appointment confirmations and reminders are not named in the text; whether they count as a “similar situation” depends on what the call says. The regulation also states that no İYS check is carried out for messages in this category, and that where an intermediary service provider sends them, it takes a declaration from you to that effect (Articles 6 and 11). In other words, classing a call as a service notification takes it out of the İYS check. Make that classification in writing, and do not add even one promotional sentence such as “we also have a new service this month” to a reminder script. For ready-made flows, see our appointment reminder call scripts.

Tradespeople and merchants

Under Article 6 of the Law, commercial electronic messages may be sent to tradespeople and merchants without prior consent. The regulation attaches two conditions: before sending, their contact addresses are registered in İYS and İYS is checked for whether they have opted out. Messages may not be sent without consent to tradespeople and merchants who have opted out (Article 6). Make sure the number really belongs to the business; in small businesses the business line and a personal phone are not always separate.

Notifications required by law

Article 6 of the regulation also waives prior consent where other legislation obliges the service provider to inform the recipient. Under Article 9, an opt-out does not prevent notifications that must be sent by law.

Decision tree: is this call a commercial message?

Use the flow below when planning a campaign or a one-off call. If you are not sure about an answer, treat the call as one that needs consent.

1. Does the call include promotion, a campaign, a sales offer or a greeting?
   Yes -> go to 4.
   No  -> go to 2.

2. Is the call a response to the person's own request?
   (callback request, form, missed call)
   Yes -> Stay within the request and add no promotion. Ask your lawyer about edge cases.
   No  -> go to 3.

3. Is the call a notification about an ongoing relationship?
   (appointment confirmation, delivery, collection, updating information)
   Yes -> Consent may not be required (Regulation, Art. 6). Keep it informational.
   No or not sure -> go to 4.

4. Does the number belong to a tradesperson or merchant?
   Yes -> No consent required; register the number in İYS and check for an opt-out.
   No  -> go to 5.

5. Does the number have consent for calls in İYS?
   Yes -> You may call. Content must match the consent and offer an opt-out.
   No  -> Do not call. Do not call to ask for consent either.

Content rules during the call

Even with consent, what the call says is regulated. Under Articles 8 and 9 of the regulation:

• Content must match the consent. The call must stay within what the recipient agreed to.
• Say who is calling. Voice calls must include the trade name for merchants and the first and last name for tradespeople; a brand or business name can be added.
• Make the nature clear at the start. If the nature of the message is not obvious from its content, a label such as “promotion”, “campaign” or “information” is stated at the beginning of a voice call.
• State promotions clearly. Discounts, gifts or contests must be stated clearly, with easy access to their terms.
• Offer an opt-out on every call. Opting out must be possible through the same channel, easily and free of charge.

For a voice agent, this means writing the opening line and the opt-out flow into its instructions. A sample opening, to adapt with your lawyer (in practice the call would be in Turkish; the Turkish edition of this article has the Turkish wording):

Hello, I'm calling on behalf of [Trade Name]; I'm the business's AI assistant.
This is a promotional call: I'd like to tell you briefly about [topic].
If you'd rather not receive calls like this, just say "don't call me"
and I'll record your request right away.

Neither Law No. 6563 nor the regulation contains a disclosure rule specific to AI; we still recommend telling callers clearly that they are speaking with an AI assistant. If you record calls, remember the notice obligations under KVKK, Turkey’s data protection law; we cover them in our guide to KVKK for AI phone assistants.

The right to opt out: “Don’t call me again”

Under Article 8 of the Law, recipients may refuse commercial electronic messages at any time without giving a reason. The regulation sets out how opt-outs are handled:

• The service provider stops sending messages within three business days of receiving the request (Article 10).
• It reports opt-outs it receives to İYS within three business days (Article 9).
• Recipients can also opt out directly through İYS (Article 9).

Your voice agent needs to recognise phrases such as “don’t call me”, “take me off the list” or “I’m not interested, don’t call again” as opt-outs, log them and remove the person from the campaign. In the first weeks, read the transcripts to check that the agent does not miss any.

Non-compliance has consequences. Recipients can complain through e-Devlet (Turkey’s e-government portal), İYS or the Ministry of Trade’s website (Article 14 of the regulation). Article 12 of the Law provides for administrative fines and allows the fine to be increased up to tenfold when messages are sent without consent to several people at once. In complaint cases the burden of proof lies with the service provider; consent records are kept for three years from the date the consent ends, and other message records for three years from the date they were created (Article 13 of the regulation).

Pre-campaign checklist

• Have you written down the campaign’s purpose: promotion, answering a request or a service notification?
• Is your business registered with İYS, and is it clear which brand the calls are made for?
• Where did the list come from? Do you know the source and date of consent for each number?
• Have consents collected outside İYS been registered in İYS within three business days?
• Is each number’s call consent checked in İYS before the call starts?
• Have tradesperson and merchant numbers been registered in İYS and checked for opt-outs?
• Is there not a single promotional sentence in calls you classify as service notifications?
• Does the opening line state the trade name and the nature of the call?
• Does the voice agent recognise and log opt-outs and remove people from the list?
• Are opt-outs reported to İYS within three business days?
• Are calling hours limited to a reasonable window?
• If calls are recorded, is the KVKK notice ready?
• Is it clear how consent and call records are retained?
• Has your lawyer reviewed the script and the list before launch?

İYS checks for outbound calls in Speakline

When you turn on the İYS check in Speakline’s campaigns module, each number’s call consent in İYS is checked before the call starts. Without consent, the call is not made; if İYS cannot be reached at that moment, the call is not started either and is retried later. The same check runs on one-off calls marked as promotional. Service calls such as callbacks and support are not checked, so marking the purpose of a call correctly matters. Calls are limited to the hours you set, outcomes are reported and can be sent to your CRM through our API and webhooks.

Our Turkish-speaking voice agents handle reminder, confirmation and callback scripts, and when a person is needed the call is handed to an operator with a summary. Collecting consent, registering it in İYS and the legal classification of each call remain your business’s responsibility. If you would like to plan a campaign together, get in touch.