Regulation on the Rental of Motor Vehicles - Compliance Guide

Regulation on the Rental of Motor Land Vehicles – Compliance Guide
Date of preparation: 18 August 2026

Contents

• 1. The Legal Position Before the Regulation
• 2. Scope
• 2.1. Rentals falling within the scope
• 2.2. Scope in terms of vehicle class
• 2.3. Rentals outside the scope
• 2.4. The position of long-term rentals
• 3. The Authorisation Certificate
• 3.1. The certificate requirement
• 3.2. Conditions for obtaining the certificate
• 3.3. Conditions required of the vehicles
• 3.4. Application, amendment and revocation
• 4. The Contract and the Mandatory Documents
• 5. Charges, Security Deposit and Damage
• 5.1. Rental and service charges
• 5.2. Security deposit
• 5.3. Damage and malfunction
• 6. Other Obligations of the Business
• 7. Listing Platforms and Intermediary Platforms
• 8. Information System, Supervision and Sanctions
• 9. Entry into Force and Compliance Timetable
• 10. Steps Required for Compliance
• 10.1. Before the date of entry into force
• 10.2. By 1 July 2027
• 10.3. By 1 January 2028
• 10.4. For listing and intermediary platforms
• 11. Matters Left Open
• Sources

The Regulation on the Rental of Motor Land Vehicles, prepared by the Ministry of Trade, was published in the Official Gazette on 15 August 2026 and will enter into force on 1 January 2027. Vehicle rental is being made subject to an activity-specific authorisation certificate regime for the first time, and businesses are placed under detailed obligations concerning their fleet, their contracts, the charges they levy and the treatment of damage.

This guide sets out, for businesses carrying on vehicle rental activity and for listing and intermediary platforms, the scope of the Regulation, the obligations it introduces and the timetable for compliance. The article numbers given in parentheses are references to the relevant provisions of the Regulation.

1. The Legal Position Before the Regulation

Until 1 January 2027, vehicle rental is not subject to any authorisation certificate specific to the sector. The rules that apply are dispersed across a number of instruments.

• The contractual relationship is governed by the lease provisions of the Turkish Code of Obligations No. 6098. The lessee’s duty to use the leased property with due care is set out in Article 316 and the duty to return it in Article 334.
• Where the lessee is a consumer, the review of unfair terms under the Consumer Protection Law No. 6502 applies.
• Additional Article 3 of the Identity Notification Law No. 1774 requires the details of the person renting and of the vehicle rented to be notified to the general law enforcement authorities through the system at the moment of handover, requires GPS devices to be fitted to rented vehicles and requires location records to be retained for three years.
• As regards the premises, the Regulation on Business Opening and Operating Licences applies.
• The Highway Traffic Law No. 2918 governs the liability of the operator, compulsory motor third-party liability insurance and traffic fines.

Those instruments will remain in force. Since the notification obligation arising under the Identity Notification Law is independent of the Information System to be established by the Ministry of Trade, the two systems will operate side by side and compliance with one will not substitute for the other.

2. Scope

2.1. Rentals falling within the scope

For a rental to be subject to the Regulation, the following conditions must be met cumulatively and the rental must not fall within one of the exceptions (Art. 2, Art. 4).

• The lessor must be a natural or legal person merchant, or a tradesman or craftsman. The Regulation refers to such persons as the business.
• The class of the vehicle to be rented, as stated in its registration certificate, must be M1, M1G, N1 or N1G.
• The rental must be granted to the same lessee for a maximum of twenty-nine days, either at once or in uninterrupted periods.
• The lessee must be a consumer. The Regulation defines a consumer as a natural or legal person acting for purposes which are not commercial or professional.

The Regulation also covers listing platforms and intermediary platforms, the rules applicable to rental listings and the unfair commercial practices of those platforms.

2.2. Scope in terms of vehicle class

The Regulation defines a motor land vehicle as a vehicle defined in Article 3 of Law No. 2918 whose class, as stated in its registration certificate, is M1, M1G, N1 or N1G (Art. 4/1-m). The definition requires both conditions to be satisfied together, so that the object of the rental must be a vehicle within the meaning of the Highway Traffic Law and must also fall within one of the classes listed in the registration certificate.

Construction machinery falls outside the scope on two separate grounds. The Highway Traffic Law defines a work machine as a vehicle that cannot be used to carry persons, animals or goods on the highway, and thereby places it outside the category of vehicles. Moreover, since such machines are registered not by the traffic registration authority but by the chambers of agriculture and the chambers of commerce and industry, they have no registration certificate carrying vehicle class information. The rental of construction machinery therefore remains outside the Regulation and continues to be governed by the lease provisions of the Turkish Code of Obligations.

2.3. Rentals outside the scope

• Rentals of thirty days or more. Operational leasing and fleet leasing models are outside the scope for this reason.
• Short-term rentals in which the lessee does not have the status of a consumer.
• Shared rentals. The Regulation defines these as a service which is commenced and terminated under a membership agreement without the parties meeting in person, which is provided by the minute or by the hour, and in which the vehicle may be freely collected from and returned to a common vehicle pool.
• Rentals of camper vehicles.

2.4. The position of long-term rentals

The Regulation contains no substantive provision on long-term rentals. The definitions article describes such a rental as a service granted to the same lessee for thirty days or more, either at once or in uninterrupted periods, while the scope article excludes it (Art. 4/1-s, Art. 2/2). Accordingly, the authorisation certificate, the contractual requirements, the limits on charges and security deposits and the damage regime will not apply to long-term rentals, which will continue to be governed by the lease provisions of the Turkish Code of Obligations together with the notification and GPS obligations under Additional Article 3 of Law No. 1774. Since the phrase "in uninterrupted periods", which appears in the definitions of both short-term and long-term rental, requires consecutive periods granted to the same lessee to be aggregated, dividing a rental into several contracts does not render it short-term. That criterion operates in the opposite direction as well, so that where an extension brings the uninterrupted period to thirty days, the rental is considered to become long-term and thereby to fall outside the scope.

3. The Authorisation Certificate

3.1. The certificate requirement

No commercial activity may be carried on without an authorisation certificate in respect of rentals falling within the scope. Unless the Ministry establishes otherwise, every rental transaction is deemed to be a commercial activity (Art. 5/1). Only businesses that carry out rentals outside the scope are not subject to this requirement. The certificate is issued by the Provincial Directorate of Trade of the place where the business is located, through the Information System, is issued separately for each business and cannot be transferred (Art. 5/2, Art. 5/4).

3.2. Conditions for obtaining the certificate

The condition relating to the premises is drafted as "otherwise than for activities such as authorised dealership, insurance brokerage, roadside assistance and towing services and the sale of tyres and accessories" (Art. 6/1-ç). Because of the words "such as", the list is illustrative, and similar ancillary activities compatible with rental may likewise be treated as falling within the exception. Since there is room for doubt as regards work with no discernible connection to rental, such as the rental of heavy vehicles and construction machinery or haulage, businesses with mixed activities would do well to confirm the approach of the provincial directorate before applying.

The vocational qualification requirement is not confined to the rental manager, and the employment of persons who do not hold the certificate as rental consultants is likewise prohibited (Art. 17/7). Since a consultant is defined as rental staff engaged by the business under a contract (Art. 4/1-n), what matters is whether the member of staff actually takes part in rental transactions. By contrast, the requirement does not apply to support staff who take no part in rental transactions.

3.3. Conditions required of the vehicles

Vehicles beyond the minimum number may be procured by way of rental, and as regards population data the figures of the Turkish Statistical Institute for the last day of the preceding calendar year are taken as the basis (Art. 6/5). In applications for branches, the conditions relating to tax registration are deemed satisfied for the branch if they have been satisfied by the head office. By contrast, the minimum vehicle requirement must be satisfied separately for each branch (Art. 6/2).

3.4. Application, amendment and revocation

The application is made through the Information System, the certificate is issued in the name of a business found to satisfy the conditions within ten days, and where the application is refused the reasons are recorded in the system (Art. 7). Where the information contained in the authorisation certificate changes, an application for amendment is made within thirty days and is concluded within ten days (Art. 8).

The authorisation certificate is revoked in four situations (Art. 9/1). The first is the loss of one of the conditions and the failure to satisfy it again within a period, of not less than ten days, allowed for that purpose. The second is the failure to apply for amendment within ten days despite a warning. The third is the failure to remedy a breach of the Regulation within the period allowed despite a warning. The fourth is the repetition of a breach within the same calendar year.

Where the certificate is revoked on the third or fourth ground, no authorisation certificate is issued to the business concerned for one year. That prohibition also extends to other businesses owned or represented by the owner of the business or by the persons authorised to represent it (Art. 9/3). No such prohibition is provided for in respect of the other two grounds of revocation.

4. The Contract and the Mandatory Documents

The Regulation prescribes a separate document for each stage of the rental. If those documents are not drawn up or are not delivered in time, the claims of the business in respect of damage and charges are left without foundation.

The preliminary information covers the details of the parties and of any additional driver, the essential characteristics of the service and of the vehicle, the price of each service together with the total rental price, the rights and obligations of the parties, the dates of the rental and the conditions of termination. The minimum content of the contract is separately enumerated (Art. 10/3) and includes the scope of the own-damage insurance cover, the cases falling outside cover and the deductibles, the amount of the security deposit together with the conditions of use and return, the deductible under the own-damage policy and the circumstances in which any sum exceeding that deductible may be claimed from the lessee, the situations in which the lessee is liable for damage and malfunction, and the grounds for unilateral termination.

The business is required to carry out its checks as to the lessee and the rental conditions before the contract is concluded, and once the contract has been concluded it may not withdraw from the rental in the absence of just cause (Art. 10/5). Where consent to an extension has been obtained but no new contract has been made, the rental period is deemed to have been extended on the same terms and conditions (Art. 10/6). Where the contract is concluded through an intermediary platform, the business and the platform are jointly responsible for the delivery of the preliminary information and of the contract, the responsibility of the platform being confined to the complete and accurate transmission of the information and documents provided to it (Art. 10/4).

In reservations subject to advance payment, the lessee must be informed clearly and comprehensibly, immediately before the reservation is confirmed, that confirmation gives rise to an obligation to make an advance payment; if that notification is not given, the lessee is not bound by the reservation and is not obliged to make the advance payment (Art. 11/3). The lessee may also, on the date on which the reservation is made, change the date, time and place of the rental and the segment of the vehicle without giving reasons, or cancel the reservation free of charge (Art. 11/7). Nor may the matters set out in the reservation form be altered unilaterally in the absence of just cause (Art. 11/5, Art. 11/10).

Where no vehicle in the segment stated in the reservation form is available at the time of handover, a vehicle of equivalent or higher segment is handed over without any additional charge. If that too is not possible, a vehicle of a lower segment may be provided with the lessee’s consent, and if consent is not given the reservation may be cancelled free of charge (Art. 12/2). After the vehicle is returned its interior is inspected without delay, any property found to have been left in the vehicle is notified to the lessee the same day and is kept at the premises for at least one month (Art. 12/5). Save in the circumstances expressly set out in the contract, the return of the vehicle before the agreed date may not be demanded (Art. 12/6).

5. Charges, Security Deposit and Damage

The Regulation subjects the charges that may be levied on the lessee, and the periods for repayment, to numerical limits. Those limits are set out together in the table below.

5.1. Rental and service charges

Payment is collected by debit and credit card or prepaid card, by bank transfer or electronic funds transfer, or by such other methods as the Ministry may determine (Art. 13/1). Since cash is not included in that enumeration, it follows that cash payment cannot be accepted unless the Ministry determines a new method, and the same rule applies to the security deposit. Where the vehicle is delivered and returned at an address designated by the lessee, and where an additional driver is named in the contract, an additional service charge may be sought by reference to documented costs and to the risk involved (Art. 13/3, Art. 13/4).

The lessee and any additional driver named in the contract benefit from the vehicle’s own-damage insurance, from the guarantee provided by the business and from the compulsory motor third-party liability insurance simply by paying the rental price. Neither may the benefit of these be made subject to any other condition or charge (Art. 13/5), nor may the rental service be made conditional upon the purchase of goods or services such as additional insurance, own-damage cover or a damage waiver (Art. 17/3). Together, these two provisions bring an end to separately priced damage waiver products in rentals falling within the scope. At the lessee’s request the fast toll pass system is likewise made available without any service charge, and only the toll charges actually incurred are passed on (Art. 13/6).

5.2. Security deposit

The items that may be met out of the security deposit are enumerated (Art. 14/2) and consist of unpaid rental and service charges, late return charges and excess mileage charges, toll charges and rule-breach charges emerging after the return, the cost of replenishing energy, and damage and loss caused by the fault of the lessee and falling outside the own-damage insurance or the guarantee provided by the business. For this purpose the lessee’s consent must be obtained in the contract and information must be given before the deduction is made. No deduction may be made in respect of malfunctions, scratches, dents and similar damage that could not readily be detected at the time of handover, nor in respect of wear and tear arising from ordinary use (Art. 14/5).

5.3. Damage and malfunction

The burden of proof in relation to damage rests with the business. In the case of malfunctions arising during the rental period, the malfunction is presumed not to have been caused by the lessee unless the business proves otherwise (Art. 16/4). In order for damage or malfunction charges to be claimed from the lessee, the damage and its cost must be evidenced by a report of an authorised and independent expert, and reports prepared by the business’s own staff or by persons and organisations directly or indirectly connected with it may not be used as evidence (Art. 16/5). Nor may any charge be claimed from the lessee in respect of rentals for which no handover and return documents were drawn up, or in respect of damage not recorded in the return document (Art. 16/6).

In the case of damage not caused by the lessee, items such as the cost of repair, diminished value and loss of rent may not be claimed (Art. 16/8). Even in the case of damage caused by the lessee, diminished value may not be claimed unless the parties agree or there is an insurance arbitration decision or another decision having the nature of a court judgment (Art. 16/9). The business is required to secure the financial liabilities of the lessee and of the additional driver arising from damage throughout the rental period, and may discharge that obligation by means of own-damage insurance (Art. 16/10).

The losses falling outside the guarantee are enumerated under four headings, the first of which is breaches of traffic rules giving rise to a serious safety risk. Since the Regulation gives concrete form to those breaches by the examples of driving under the influence of alcohol or narcotics, running a red light, improper use of the emergency lane, driving against the flow of traffic and racing or speed trials, breaches of comparable gravity may likewise be covered. The other three headings are losses caused intentionally, use of the vehicle by unauthorised persons owing to the fault of the lessee, and use of the vehicle in unlawful activities. The business is further released from that obligation where the scene of the accident has been left in order to prevent identification or where no official accident report has been drawn up.

The lessee is to notify the business of any damage or malfunction without delay. In the case of damage affecting safety, the business is to bring the vehicle safely to a repair point or provide the necessary support (Art. 16/1) and is to establish a continuously accessible infrastructure for such notifications (Art. 16/3). Where it is plainly apparent that the damage was not caused by the lessee, an equivalent replacement vehicle is allocated, and if that is not possible the charges relating to the remaining period together with the security deposit are repaid within seven days (Art. 16/2).

6. Other Obligations of the Business

• No vehicle may be rented to a person who does not produce a valid driving licence of the class appropriate to the type of vehicle rented (Art. 17/1).
• Where periodic maintenance falls due during the rental period, the maintenance is arranged by the business and the time taken is added to the rental period without any charge (Art. 17/4).
• Winter tyres are to be provided where seasonal conditions so require. Where requested at least two days before handover, a child restraint system of suitable quality and hygiene is to be provided (Art. 17/5).
• Vehicles not registered in the Information System, vehicles not meeting the requirements of the authorisation certificate and vehicles not complying with safety standards may not be rented out (Art. 15/1, Art. 15/2). For existing businesses, the prohibition relating to safety standards does not apply until 1 January 2028 (Provisional Art. 1/3).
• Where the contract is terminated unilaterally by the business, the decision is notified to the lessee without delay (Art. 17/6).
• The business is required to refrain from unfair or unlawful commercial practices that impair the lessee’s capacity to make a reasoned decision, and to comply with the measures taken by the Ministry (Art. 17/8, Art. 21/1).

7. Listing Platforms and Intermediary Platforms

The Regulation lays down a separate set of obligations for listing platforms and intermediary platforms. The obligations set out below apply to both types of platform, and the paragraph in question will not apply in its entirety until 1 January 2028 (Art. 18/1, Provisional Art. 1/4).

• To verify the authorisation certificate through the Information System before a business is admitted or registered as a member and before that membership is renewed, and not to permit the membership of a business that holds no certificate.
• To ensure that the authorisation certificate number of the business and its trade name or registered title are displayed in the listings.
• To verify, through the Information System and before the listing is published, that the business is authorised to list the vehicle concerned.
• To provide customer services by at least one internet-based method and by telephone, and to conclude the requests received.
• To take measures designed to prevent listings that distort the structure of the market or mislead consumers.

In their electronic listings, businesses are to state the make, trade name, type, model, model year and energy type of the vehicle together with its equipment, segment and mileage, and to include detailed images. Where handover at an airport, railway station or bus terminal is indicated but the business has no head office or branch at that location, this must be stated in a visible part of the listing (Art. 18/2).

The prohibition of unfair commercial practices applies to both listing platforms and intermediary platforms (Art. 19/1). Practices deemed unfair in all circumstances are separately enumerated for intermediary platforms alone (Art. 19/2) and include the failure to transmit to the business, in good time and in full, the information required for the rental; the use of data obtained from the business and from the lessee in competition with businesses; the failure to pay the business within five working days from the date on which the price passes into the platform’s control and the vehicle is handed over; the making of retrospective changes to the intermediation agreement to the detriment of the business; and the demotion of the business in the rankings on the ground that it has applied to public authorities or judicial bodies.

8. Information System, Supervision and Sanctions

The Ministry is to establish the Motor Land Vehicle Rental Information System for the purpose of monitoring rental activities and vehicles. The current list of businesses holding an authorisation certificate is accessible through that system. Vehicles acquired are entered in the system before being made the subject of a rental, and the entries relating to vehicles that leave the business’s control are deleted (Art. 20). The power of supervision belongs to the Ministry and may also be exercised through the provincial directorates, while the competent administrations carry out supervision in the nature of a preliminary examination at the Ministry’s request (Art. 22/1, Art. 22/2).

The administrative fines applicable in the event of a breach are determined by reference to Laws No. 6585 and No. 6563 (Art. 22/3). The amounts set out below are those applicable for 2026 and are increased each year at the revaluation rate. Since the Regulation will enter into force in 2027, the amounts for that year will be applied in practice.

The rule on repetition is framed differently in the two Laws. In the case of fines based on Law No. 6585, where a breach is repeated within the same calendar year the fine is doubled for each repetition, whereas in the case of fines based on Law No. 6563 what is required is the failure to remedy the breach within the period allowed by the Ministry or the repetition of the same breach within one year from notification of the fine. Both Laws provide for an upper limit on the aggregate of administrative fines relating to a calendar year.

Where the certificate is revoked because a breach of the Regulation has not been remedied or has been repeated, the further consequence that no new certificate will be issued for one year is independent of any pecuniary sanction and is considerably more severe in its effect. The administrative fines attaching to breaches of the obligations arising under the Identity Notification Law will also continue to apply, and that Law provides for the revocation of the operating licence where the acts it enumerates are committed for the fourth time within the same calendar year.

9. Entry into Force and Compliance Timetable

Businesses which, as at the date of publication, hold a tax or professional chamber registration relating to rental activity, or which can evidence their activity, and which have continued that activity without interruption until the date of application, are not subject to the education, bankruptcy and criminal conviction requirements (Provisional Art. 1/2). The exemption applies to applications made, in the case of businesses of natural persons, by the owner of the business as at that date, and, in the case of businesses of legal persons and branches, by one of the authorised representatives carrying on the activity as at that date. Since the vocational qualification certificate requirement falls outside that exemption, existing businesses must satisfy it as well. The Ministry is empowered to extend all the periods provided for in the transitional provisions by up to one year (Provisional Art. 1/6).

10. Steps Required for Compliance

The timetable below is intended for businesses carrying on activity as at the date of publication of the Regulation. For businesses commencing activity after the date of entry into force, all the conditions will be required at the time of the initial application.

10.1. Before the date of entry into force

• Separate the fleet inventory according to the vehicle class stated in the registration certificates and determine which vehicles fall within the scope.
• Add motor land vehicle rental to the field of activity recorded with the professional chamber and the tax authorities.
• Redraft the templates for the rental contract, the preliminary information form, the reservation form, the vehicle handover document and the vehicle return document.
• Bring security deposit amounts within the upper limits and discontinue the practice of taking cheques, promissory notes and similar debt instruments.
• Discontinue separately priced damage waiver and deductible reduction products and establish a pricing structure that reflects their cost in the rental price.
• Adapt mileage packages to the minimum limits and arrange collection in accordance with non-cash methods.
• Enter into an agreement with an expert appraisal organisation having no connection with the business.
• Establish a continuously accessible communication channel for the notification of damage and malfunctions, together with a roadside assistance service.
• Extend the document retention period to five years.

10.2. By 1 July 2027

• Complete the vocational qualification certificate process for the rental manager and the rental consultants.
• Bring the premises into conformity with subparagraph (ç) of the first paragraph of Article 6 and confirm the approach of the provincial directorate as regards activities with no discernible connection to rental.
• Submit the authorisation certificate application through the Information System and keep the record of uninterrupted activity in a form capable of being evidenced, so as to be able to benefit from the exemption in the transitional provision.
• Bring contracts concluded with platforms into conformity with the Regulation.

10.3. By 1 January 2028

• Remove from the fleet, save for classic vehicles, those vehicles exceeding six years by model year or exceeding the mileage limit.
• Complete the minimum number of vehicles and the hybrid and electric vehicle composition, and confirm that in a branch structure the requirement is satisfied separately for each branch.

10.4. For listing and intermediary platforms

• Make membership and registration processes conditional upon verification of the authorisation certificate through the Information System, and place the verification of listing authority before the publication of the listing.
• Add the authorisation certificate number together with the trade name or registered title of the business to the listing fields.
• Establish customer services by at least one internet-based channel and by telephone.
• Review intermediation agreements against the list of unfair commercial practices and remove the provisions permitting retrospective changes to the detriment of the business and demotion in the rankings.
• Arrange the payment flow so that payment to the business is completed within five working days.

11. Matters Left Open

• The timetable for the establishment of the Information System is not stated in the text, and if the system is not ready on the date of entry into force applications will not in practice be capable of being made.
• The Regulation defines the certificate as a "certificate based on the national qualification of motor land vehicle rental consultant (Level 4)" (Art. 4/1-l). The title of the qualification currently in force before the Vocational Qualifications Authority, however, is "Vehicle Rental Consultant (Level 4)", so that the two designations do not correspond.
• The Ministry is empowered to set upper limits for service charges, to impose a vocational training requirement and to determine the minimum number of hybrid and electric vehicles in provinces without a metropolitan municipality, and secondary legislation is awaited on these matters (Art. 13/9, Art. 6/3, Art. 6/4).
• The period of validity of the authorisation certificate, its renewal and any fee or charge payable on application are not regulated. Nor is the administrative remedy to be pursued against a refusal or revocation of the certificate indicated.
• Since there is no provision on the protection of personal data, a separate assessment is required under Law No. 6698 in respect of the data of lessees and additional drivers, GPS location records and transfers to the Information System.

Sources

• Regulation on the Rental of Motor Land Vehicles (Official Gazette 15/8/2026-33341)
• Law No. 6585 on the Regulation of Retail Trade (Official Gazette 29/1/2015-29251)
• Law No. 6563 on the Regulation of Electronic Commerce (Official Gazette 5/11/2014-29166)
• Identity Notification Law No. 1774, Additional Article 3 (Official Gazette 11/7/1973-14591)
• Highway Traffic Law No. 2918, Articles 3, 22 and 85 (Official Gazette 18/10/1983-18195)
• Turkish Code of Obligations No. 6098, Article 299 et seq.
• Consumer Protection Law No. 6502, Article 5
• Regulation on the Trade in Motor Land Vehicles (Official Gazette 27/8/2024-32645)

This guide has been prepared for general information purposes and does not take the place of legal advice on a specific matter. It is recommended that Nova Hukuk be contacted before applying for an authorisation certificate, putting the contractual and documentary arrangements in place or planning the fleet. All rights reserved.