Türkiye's Accessibility Circular No. 2025/10: who it covers, when and how

What is the Circular, and what does it regulate?

Its full title is "Presidential Circular No. 2025/10 on the Accessibility of Websites and Mobile Applications". It was published in the Official Gazette No. 32933 of 21 June 2025. The Ministry of Family and Social Services coordinates it.

The Circular covers not only websites but also the mobile apps of the same organisations. It names two reference documents: the W3C's WCAG 2.2 and the Ministry's "Accessibility Checklist for Websites and Mobile Applications – Level A".

Source: Lexpera, Ministry of Family and Social Services, Türkiye

Who is in scope, and what is the deadline?

The Circular defines two groups and two deadlines. Both run from the publication date (21 June 2025).

A company's corporate website that isn't in the table (a manufacturer's site that doesn't sell, for example) isn't explicitly listed in the Circular. If the company sells to the EU, though, it may fall under the EAA.

Source: Lexpera

Are e-commerce sites in scope?

Yes, if you sell online under Law No. 6563 on the Regulation of Electronic Commerce. The Circular sets no turnover, headcount or traffic threshold for this group. There is no equivalent of the EAA's microenterprise exemption.

The code of a marketplace seller's store page belongs to the marketplace. If you have a site on your own domain, preparing that site is your responsibility. Ask a lawyer or the marketplace about the position of marketplace sellers.

For an e-commerce priority order and a 12-item list, see our guide to the Circular.

Source: Lexpera

What does the Circular require technically?

The standard is WCAG 2.2 Level A plus the Ministry's checklist. WCAG 2.2 has 31 success criteria at Level A. They cover the most basic barriers:

• Text alternatives for images (1.1.1)
• Every function usable with a keyboard (2.1.1), with no keyboard trap (2.1.2)
• Labels and instructions for form fields (3.3.2), errors identified in text (3.3.1)
• The page language set (3.1.1)
• Accessible names for buttons and links (4.1.2)
• Consistent Help (3.2.6) and Redundant Entry (3.3.7), new in WCAG 2.2

One detail to watch: text contrast (1.4.3) and focus visible (2.4.7) are Level AA, so they are not on the Circular's mandatory Level A list. If you sell to the EU, the EAA requires them as well.

Source: Lexpera, W3C, Ministry of Family and Social Services, Türkiye

How will it be enforced?

The Circular sets up three bodies within the Ministry:

The Minister will announce the monitoring reports. Sites that complete monitoring and are found accessible will get the right to use the Accessibility Logo for 2 years. How monitoring will work, which sites will be sampled and the working rules are left to procedures the Ministry will set.

Source: Lexpera, Ministry of Family and Social Services, Türkiye

What should organisations whose deadline passed in 2026 do now?

For banks, private hospitals, private schools and the other group 1 organisations, the date has passed. That doesn't mean the work is done: monitoring and the logo process are only starting, and a site can break again with every new release.

1. Re-scan your most used flows (appointments, applications, login, payment) against WCAG 2.2 Level A.
2. Work through the Ministry's checklist item by item and keep the evidence (screenshots, test notes).
3. Test the mobile app separately; fixes made for the website don't carry over to the app.
4. Publish an accessibility statement: say what is ready, what is still open and how users can reach you.
5. Set up a routine to re-scan after every release.

Is it the same as the EAA?

No. The EAA covers services offered to consumers in the EU and in practice requires WCAG 2.1 AA; the Circular covers the listed organisations in Türkiye and requires WCAG 2.2 Level A. If you serve both markets, you need to look at both together. More: The EAA: a practical guide for sellers outside the EU.

Source: EUR-Lex