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VERBIS Registration Obligation: Who Should Register?

15 Mart 2026 IT Law 2 dk okuma 59 görüntülenme

VERBİS is the online system used for data controllers within the scope of KVKK to register with the Data Controllers Registry.

Who Must Register?

  • Annual number of employees is more than 50 or annual financial balance sheet total is above a certain amount
  • Data controllers located abroad and performing data processing activities in Türkiye
  • Public institutions
  • All data controllers in certain sectors (can be expanded by KVKK Board Decisions)

Things Excluded

  • Those whose annual number of employees is less than 50 and whose annual financial balance sheet total is below the threshold (except for some exceptions due to service activities)
  • Notaries (special arrangement)
  • Lawyers (limited scope)
  • Those who process personal data only for their own internal processes (limited)

What is Included in the VERBIS Record?

  • Data controller representative information
  • Categories of personal data processed
  • Purposes of processing
  • Legal reason
  • Third parties transferred
  • Destination country if transfer is made abroad
  • Storage periods
  • Data security measures

Sanctions (KVKK article 18)

  • Failure to register with VERBIS: Administrative fine from 20,000 TL to 1,000,000 TL
  • Missing/incorrect information entry: same scope

KVKK Board Approach

The Board emphasizes that VERBIS registration is not a mere formality and that the declared information is used as an audit base. Incomplete declarations result in additional penalties.

VERBIS registration and maintenance requires active monitoring; It is recommended to get KVKK compliance consultancy.

Telif bildirimi This content and all related Q&A texts are protected under Turkish Copyright Law No. 5846. Unauthorized copying, reproduction, publication, adaptation, bulk extraction, or commercial use is prohibited; legal and criminal remedies are reserved in case of infringement.

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