With the regulation published in the Official Gazette on 31 December 2025, a significant amendment has entered into force concerning digital advertising and electronic promotional activities within the tourism sector.

Pursuant to the updated Article 33 of the Tourism Promotion Law, entities that enable the electronic commerce and promotion of accommodation businesses are legally obliged to verify the validity of the relevant Tourism Operation Certificate Numbers through the Ministry’s official database and to display these certificate numbers in all digital advertising and promotional activities.

This requirement does not constitute a recommendation; it is a binding legal obligation.

Based on legal analysis, the following implications are clear:

– The digital promotion of unlicensed accommodation businesses is strictly prohibited.
– An administrative fine of 25,000 Turkish Lira shall be imposed for each individual advertisement in which a valid certificate number is not displayed.
– Authorities will initially issue a warning; if the content is not corrected within 24 hours, the administrative sanction will be enforced.
– Decisions regarding content removal and/or access restriction may be issued.
– Administrative fines shall be increased annually in accordance with the officially announced revaluation rate.

Importantly, the scope of this regulation extends beyond accommodation providers themselves.

Digital marketing agencies, media planning companies, performance marketing teams, technology providers, and all platforms facilitating electronic commerce or promotional visibility fall within the scope of responsibility.

Accordingly, any Meta advertisement, Google Ads campaign, sponsored social media content, banner placement, landing page, or video advertisement that promotes an accommodation business must visibly include the valid certificate number.

From a sectoral perspective, it is necessary to acknowledge that digital marketing can no longer be understood solely as a function of creativity and performance optimization. It must also be managed as a matter of regulatory compliance.

Process Management Considerations

This regulatory development should be addressed proactively rather than reactively. Waiting for an official warning does not constitute effective risk management.

1. Certificate Verification Procedure

Prior to the launch of any digital campaign, the Tourism Operation Certificate Number should be formally requested in writing.
The number must be verified through the Ministry’s official database.
Verification records should be properly archived.

2. Creative and Technical Standardization

The placement of the certificate number must be standardized to ensure:

– Clear visibility and readability in visual materials
– Adequate display across mobile devices
– Sufficient on-screen duration in video advertisements
– Inclusion on landing pages and reservation interfaces

This is not a matter of design preference but a regulatory necessity.

3. Pre-Publication Control Mechanism

Before publication, a structured compliance checklist should confirm:

– The presence of the certificate number
– Its accuracy and association with the correct business
– Its validity and currency
– Its inclusion across all advertisement variations

This control should be formally integrated into media approval workflows.

4. Contractual Clarification

Agency–client agreements should explicitly define:

– Responsibility for the accuracy of the certificate number
– Procedures for updates and notifications
– Allocation of liability in the event of administrative sanctions

5. Archiving and Audit Preparedness

Copies of all published digital advertisements and corresponding verification records should be systematically retained for potential regulatory review.

Conclusion

As of the effective date of the amendment, the inclusion of a valid Tourism Operation Certificate Number in all digital advertising and promotional activities within the tourism sector is legally mandatory.

If corrective action is not taken within 24 hours following an official warning, an administrative fine of 25,000 Turkish Lira per advertisement shall be imposed.

Accordingly, accommodation groups, travel agencies, and digital marketing teams should conduct an immediate audit of active campaigns to ensure compliance.

What may appear to be a minor technical detail in digital communication may, in fact, constitute a significant financial and legal risk.

Digital advertising in tourism must now be understood not only as a performance-driven discipline, but as an integrated compliance framework.