MCCM
RESILIENCE
OUR MEDIA
Digital governance and media freedom in Türkiye are under severe and sustained strain, shaped by a long-term shift toward state control over the digital space rather than a human rights-based regulatory framework. Despite its formal EU candidate status, there is no meaningful progress toward alignment with the EU acquis, core instruments such as the Digital Services Act, or international human rights standards.
The digital platform regulation system reinforces deterioration of human rights by an interplay of ongoing political uncertainty, restrictive legislative developments that expand state discretion over digital space, weaken safeguards for rights, and increase pressure on journalists, civil society, and marginalised groups, and weakened institutional capacity or willingness to reverse course.
These are key messages of the publication Türkiye: Risk Assessment of the Regulation of Digital Platforms and Media in the Digital Environment [in Turkish] by SEENPM, produced within a UNESCO project “Building Trust in Media in South East Europe: Support to Journalism as a Public Good”, financed by the EU.
The Risk Assessment is based on an analysis of legislative and policy monitoring processes conducted from December 2024 to May 2025.
The publication is part of a broader series of studies in local languages covering Albania, Bosnia and Herzegovina, Montenegro, North Macedonia, Serbia, and Türkiye.
Read the integral – regional collection publication [in English]: Regulating Digital Platforms and Media in the Digital Environment: Risk Assessments
Core Reform Priorities
To reverse the downward trend and shift the country’s trajectory, several urgent issues must be addressed as a matter of priority:
- Reestablish institutional independence. Ensure separation of powers and independent regulators to design and implement human rights-aligned, abuse-resistant policies addressing harms at both individual and societal levels.
- Create inclusive civil society mechanisms. Meaningfully involve all civil society actors—NGOs, academia, journalists, businesses, and independent experts, including government critics—in policy development, as already required by law.
- Ensure genuine multistakeholder engagement. The government must demonstrate a genuine willingness to engage civil society actors as partners, rather than treating them as adversaries through intimidation and imprisonment, and take concrete, lasting steps to secure meaningful multistakeholder participation through trust-restoring, transparent, inclusive, and open channels.
Systemic Risks to Digital Governance
Given the scale and frequency of human rights violations, systemic risks to digital governance in Türkiye can be grouped into three categories:
1. Significant concentration of broad and unchecked powers to restrict digital content in key government bodies – with more than 20 institutions currently empowered to block online content at their discretion.
2. The lack of transparency in regulatory processes and the absence of effective mechanisms to ensure institutional accountability.
3. Weak or absent redress mechanisms and systemic institutional failure to deliver justice in digital rights cases.
Together, these conditions entrench a regulatory environment in which restrictions are expansive, oversight is limited, and violations rarely receive effective remedy, as restrictive laws, political volatility, and weak accountability mechanisms mutually reinforce a deteriorating digital rights landscape.
This course is shaped by heightened political unpredictability that directly influences regulatory direction. The fragile and contested peace process involving Kurdish actors and the polarised aftermath of the March 2025 arrest of the İstanbul mayor have opened competing scenarios ranging from further authoritarian consolidation to potential – but uncertain – democratic opening. In both cases, digital governance is a central instrument of political power and contestation.
Recent legal developments further intensify structural risks. The Cybersecurity Law grants broad powers that could be used to suppress dissent and target journalists. At the same time, it may weaken cybersecurity resilience by reducing transparency and limiting institutional cooperation and innovation.
The draft Anti-LGBTQI+ Law would further escalate restrictions, potentially criminalising gender non-conforming expression [gender expression that does not conform to rigid, socially imposed gender norms] and extending punitive impact beyond LGBTQI+ individuals to broader forms of artistic and public expression.
Critical Actions Required for Reform
Addressing these linked risks – and safeguarding media freedom, digital rights, and democratic governance in Türkiye – requires the following key actions:
- Ensure human rights-based alignment with the DSA and EU acquis. Türkiye must fundamentally shift its digital platform regulation model away from policing speech and rights-restrictive control toward full alignment with the EU acquis’ human rights-based approach, including the Digital Services Act (DSA) and UNESCO Platform Guidelines. The EU and international actors, including UNESCO, should actively monitor developments, provide support throughout drafting and implementation, and insist on continuous civil society participation.
- Amend the Internet Law without delay. The Internet Law grants extensive censorship powers to already powerful state bodies with minimal oversight. It must be urgently revised to remove excessive authority and align with a human rights-based framework. The process must be fully transparent and publicly accountable, ensuring exercise of state power remains within democratic oversight and fundamental freedoms.
- Establish binding transparency and accountability mechanisms. Türkiye must introduce formal oversight systems ensuring transparency in digital platform regulation, including enforcement checks, sanctions for abuse of power, and independent monitoring through multistakeholder mechanisms integrated into regulation and implementation.
- Guarantee media independence and self-regulation. Institutions, including the Presidential Directorate of Communications, are currently used to control and censor media and digital platforms and must have their powers curtailed. Media independence must be guaranteed, followed by self-regulatory frameworks.
- Strengthen data protection and privacy frameworks. The Personal Data Protection Law and Cyber Security Law must be amended to prioritise privacy protection and address evolving threats to personal data. The PDPL must be aligned with GDPR principles and standards. The Cyber Security Law must remove provisions restricting journalists’ and researchers’ work and refocus on strengthening critical infrastructure against cyber threats.
- Ensure meaningful, good-faith civil society participation. The exclusion of NGOs from regulatory processes must be reversed, guaranteeing their substantive role in shaping digital governance frameworks.
- Stop adoption of the Anti-LGBTQI+ Law. The process must be halted immediately to prevent further deterioration of freedom of expression. Protection of the human rights of LGBTQI+ individuals and other minority groups must be ensured as a non-negotiable priority.
Digital Governance Risks: A Framework
The assessment is based on a bespoke, replicable risk matrix, structured around three risk groups:
- Misalignment with international standards of human rights protection and the rule of law;
- External and internal risks: external risks stem from the broader context (e.g. political climate or potential misuse), while internal risks arise from the regulation itself, including legal gaps, weak or missing redress mechanisms, and loopholes;
- Legislative process factors refer to risks related to how a law or policy is developed, including transparency, stakeholder and expert involvement, and potential political influence during drafting and adoption.
Türkiye: Risk Assessment of the Regulation of Digital Platforms and Media in the Digital Environment [in Turkish]
The integral – regional collection publication [in English]: Regulating Digital Platforms and Media in the Digital Environment: Risk Assessments
This article was produced within the UNESCO project “Building Trust in Media in South East Europe: Support to Journalism as a Public Good”, financed by the EU.
The designations employed and the presentation of material throughout this article do not imply the expression of any opinion whatsoever on the part of UNESCO or the European Union concerning the legal status of any country, territory, city or area or its authorities, or concerning the delimitation of its frontiers or boundaries.
The authors are responsible for the choice and presentation of the facts contained in this article and for the opinions expressed therein, which are not necessarily those of UNESCO or the European Union and do not commit the Organization.
