"Can we use AI-generated visuals or characters in our ads and social media content, and if we do, what must we disclose?" Marketing and communications teams now have a concrete reason to ask this question. The amendment that Ticaret Bakanlığı (the Ministry of Trade) made to the Ticari Reklam ve Haksız Ticari Uygulamalar Yönetmeliği (the Regulation on Commercial Advertising and Unfair Commercial Practices) was published in Resmî Gazete (Türkiye's Official Gazette) No. 33297 of July 1, 2026 and entered into force on August 1, 2026.
In this article, we read the two new AI-related provisions from the text of the regulation, summarize the targeted-advertising rules that came with the same amendment and closely concern AI-assisted marketing, and draw up a practical checklist for companies.
What does the regulation say? Two new provisions
1. Disclosure obligation (Regulation Art. 18/8). The amendment added a new paragraph to Article 18 of the regulation. Under it, if an ad uses AI or other software in a way that materially affects a consumer's economic behavior regarding a good or service, or if it features AI-generated digital characters that cannot be told apart from humans, that circumstance must be disclosed in a clear, understandable and distinguishable manner.
It is important to note that there are two separate triggers here. The first is the appearance in an ad of a digital character that cannot be told apart from a human. The second is the use of AI or software in a way that materially affects the consumer's decision, even when no character is involved. In other words, the rule should not be read as limited to visible examples such as a "virtual presenter" or an "AI-generated model."
2. Ban on digital replicas (Regulation Art. 27/12). The paragraph added to Article 27 of the regulation prohibits ads in which an AI-generated digital replica of a real person is shown, contrary to the truth, as having personally experienced or used a product or service, or as recommending it. In its announcement, the Ministry of Trade likewise summarizes these two provisions under the heading "ads created with artificial intelligence," as a disclosure requirement for digital characters and a ban on recommendations by digital replicas.
The key phrase in the ban is "contrary to the truth." The text targets cases in which a person's digital replica is presented as having experienced a product, or as recommending it, although the person has not actually experienced it. Even where the real person has given consent, whether that impression is truthful is a separate question that must be assessed; it is advisable to obtain a legal opinion at this point.
Related rules that came with the same amendment
The amendment is not limited to AI. Two more topics directly concern teams that run AI-assisted campaigns:
- Targeted advertising (Art. 25/A). Serving ads tailored to specific individuals or groups by analyzing consumers' online behavior, location information, demographic data or similar personal data is now defined in the regulation. Such ads can be run, provided that consumers are given direct and easily accessible information on the criteria by which an ad is shown and how those criteria can be changed. Where it is known, or should reasonably be known, that the consumer is a child, targeted advertising based on profiling with personal data is not permitted.
- Social media influencers (Art. 23/A). In ads run through influencers, using one of the terms "Reklam" (Advertisement) or "Tanıtım" (Promotion) is mandatory. The label is also required to appear in a form and position that can be seen at first glance, without scrolling the screen. In content that a company runs through its own digital character or an influencer collaboration, these two obligations can arise together in the same post.
Who is responsible?
Law No. 6502 on the Protection of Consumers (Tüketicinin Korunması Hakkında Kanun), which sets the basic framework for commercial advertising, states that advertisers are obliged to prove the accuracy of the claims in their commercial ads. The same article says that advertisers, advertising agencies and media organizations are obliged to comply with these provisions. Under the Law, the Reklam Kurulu (the Advertisement Board) can issue, following its review and inspection, decisions such as cessation, correction, an administrative fine, suspension as a precautionary measure for up to three months, or removal of the content and blocking of access.
The practical upshot: even if an agency or an external provider produces the content, the company running the ad does not fall outside the chain of responsibility. That is why the issue should be part not only of the agency's work but also of the company's own internal processes.
A checklist for companies
The steps below are a general framework derived from the text of the regulation; they should be adapted to your sector and the channels you use.
- Compile a content inventory. Among the ad, social media and campaign content that went live after August 1, 2026, list which items contain AI-generated human images, voices or characters. Also review content that was prepared before the effective date but is still live.
- Define the "indistinguishable from a human" test. Put in writing who will decide, and by what criteria, which content crosses this threshold. A cautious default that opts for disclosure in unclear cases reduces the need for corrections later.
- Standardize the form of disclosure. Set a single template per channel for the label's wording, position and size. The regulation sets a standard of "clear, understandable and distinguishable"; a note in small print, or one buried at the end of a caption, may not meet it.
- Make the use of a real person's image subject to a separate approval step. If the image or voice of an employee, a spokesperson or a well-known person is processed with AI, assess with your legal team before publication whether the content gives the impression that the person genuinely used or recommended the product.
- Review your targeted-advertising settings. Document how the targeting criteria used on ad platforms are explained to consumers and how profiling aimed at children is excluded.
- Update agency and influencer contracts. Turn the reporting of AI use, compliance with the labeling rules, and prior approval of any use of digital replicas into contract clauses.
- Keep an evidence file. Because the Law places the burden of proof on the advertiser, keep a record, content item by content item, of which tool was used in which content, who approved it, and how the label was placed.
For the security side of the topic, you may also want to look at the articles on deepfake executive impersonation and approval processes, and, for internal use, on governance of employees' AI use.
Conclusion
Since August 1, 2026, the use of AI in advertising in Türkiye has been tied to concrete rules through the disclosure obligation and the ban on digital replicas. The essence of the regulation is that consumers should be able to know whether the figure in front of them is a real human or a product of AI, and whether a recommendation rests on a real experience. For companies, the soundest course is to turn AI-generated content into a process managed through an inventory, a labeling standard and an approval step, rather than leaving it to the individual decisions of the marketing team.
Why logistics experience matters here. The checklist above borrows from supply-chain practice: count what you hold (the inventory), put a standard label on every unit, document each handover to an agency or influencer, and keep proof on file for every item, much like a proof of delivery. Outsourcing production does not outsource accountability, just as a company that hands its freight to a third-party operator still answers to its own customer for the delivery. One of Orient Global's consultants brings more than 30 years in operations, logistics and supply chain: at a technology distribution company of roughly one billion dollars in scale, he ran logistics, warehousing, technical service and administrative operations end-to-end, building and leading teams of 100+ people and delivering lasting gains in operational performance through KPI-driven programs. He has also designed and directed large-scale logistics and distribution networks, including nationwide warehouse and transport operations, at leading retail, logistics and distribution organizations. An industrial engineer, he now brings that supply-chain discipline to SMEs through AI and automation. Meet our consultants.
This article is for general information purposes only and is not a substitute for legal advice.
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