Which Gaming Platforms Must Appoint a Local Representative in Turkey?

Originally published by Evren Özmen, CPA

Turkey is moving toward a mandatory local representative regime for foreign digital gaming platforms—an approach that mirrors the enforcement model previously applied to global social media companies. Under the upcoming regulatory framework, gaming platforms with significant user access from Turkey may be required to appoint a local representative in Turkey to remain compliant and avoid sanctions.

For global game stores, publishers, and launcher-based ecosystems, the key question is no longer if but who is in scope—and how to structure compliance without creating tax or operational risk.

What Triggers the Local Representative Requirement in Turkey?

Based on draft regulations and the authorities’ enforcement posture, the obligation is expected to apply to foreign-based gaming platforms that meet one or more of the following criteria:

• High daily or sustained user traffic from Turkey

• Digital distribution, sale, update, or access to games for Turkish users

• Platform-level control over content availability, updates, or access

• Operation as a digital game store, launcher, or subscription service

Platforms meeting these criteria must maintain a locally reachable, legally accountable representative in Turkey.

Gaming Platforms Likely Required to Appoint a Local Representative

1) PC Game Stores & Launchers

• Steam
  The dominant PC game store in Turkey with a large active user base. Given scale and access, Steam is a primary in-scope platform.

• Epic Games Store
  Widely used due to free-game campaigns and major titles; high Turkish user engagement places Epic squarely within scope.

• EA App
  Publisher-operated launcher required to play EA titles. Even when games are purchased via other stores, launcher dependency creates separate compliance exposure.

• Ubisoft Connect
  Mandatory launcher for Ubisoft titles; Turkish access volume and platform control make it a likely candidate.

• Rockstar Games Launcher
  Required for GTA and other titles. High Turkey usage means launcher-level compliance is critical.

2) Console Digital Stores

• PlayStation Store
  The most widely used console store in Turkey. Digital sales and account-based access strongly indicate representative obligations.

• Xbox Store
  Growing rapidly through Game Pass; cross-platform (PC + console) presence increases regulatory attention.

• Nintendo eShop
  Smaller but still relevant; if user thresholds are met, eShop may also be subject to the requirement.

Why Launcher-Based Platforms Face Additional Risk

Even if a major store appoints a local representative, launcher-dependent platforms may still be non-compliant if they do not appoint one themselves.

In practice, this means:

• A game purchased on a compliant store could still be inaccessible if its required launcher lacks a local representative.

• This creates consumer protection, contractual, and reputational risks for publishers and platform operators.

Accordingly, both stores and launchers must assess their standalone compliance obligations.

What Does a Local Representative Do for Gaming Platforms?

A local representative in Turkey is not a distributor or reseller. The role is compliance-only, typically including:

• Acting as the official point of contact for Turkish authorities

• Managing correspondence with the Information and Communication Technologies Authority (BTK)

• Coordinating content, age-rating, and platform compliance requests

• Supporting responses to enforcement actions (e.g., fines or bandwidth restrictions)

⚠️ Critical: If the representative is improperly structured (e.g., granted commercial authority), it may create permanent establishment and corporate tax exposure.

Sanctions for Non-Compliance

Draft enforcement mechanisms indicate graduated sanctions, including:

• Administrative monetary fines

• Progressive bandwidth throttling (up to severe access reduction)

• Restoration of access once a compliant local representative is appointed

This makes early appointment and proper structuring the most effective risk-mitigation strategy.

How Gaming Platforms Should Prepare Now

Platforms serving Turkish users should proactively:

1. Assess Turkey user traffic and platform control indicators

2. Determine whether store- or launcher-level obligations apply

3. Design a tax-safe, compliance-only representative model

4. Prepare internal workflows for BTK communications

5. Align publisher–store–launcher contracts with the new regime

Need a Local Representative in Turkey for Your Gaming Platform?

We advise global gaming platforms, digital game stores, publishers, and launcher operators on:

• Local representative structuring in Turkey

• Regulatory and BTK liaison

• Tax-safe compliance models (no permanent establishment risk)

• Ongoing authority communication and crisis response

If your platform serves users in Turkey and needs a compliant local representative, contact us to assess scope, structure, and timing before enforcement escalates.

info@ozmconsultancy.com