TİHEK's Discrimination-Based Digital Accessibility Enforcement — Turkey's Complaint-Driven Route to Inclusive Design

Turkey's Law No. 5378 on the Rights of Persons with Disabilities (Article 7) requires public and, since a 2024 revision, private digital services to be accessible; Presidential Circular No. 2025/10 subsequently obliged public institutions, universities, municipalities, banks, private hospitals and e-commerce platforms to bring websites and mobile apps into line with WCAG 2.2 Level A. Enforcement sits with the Turkiye Insan Haklari ve Esitlik Kurumu (TIHEK), the national human rights and equality body, which investigates citizen complaints and can issue administrative fines for disability-based discrimination.
Rather than only auditing sites proactively, TIHEK's model is complaint-driven: a blind user who could not use screen-reader software to access the GAIN digital platform filed a complaint. TIHEK's investigation found the platform inaccessible with no concrete remediation timeline offered, ruled this indirect disability discrimination, and issued the maximum administrative fine of TRY 204,285 -- reported as among the first digital-accessibility fines issued under the framework.
Treating inaccessible design as an equality-law violation, adjudicated case by case with a real financial penalty, is a distinctive enforcement lever beyond voluntary technical standards. But the public record so far is thin -- a small number of individual rulings since 2024/2025 rather than a systematic national audit -- so the mechanism's deterrent reach and its actual effect on the accessibility of Turkish digital services are not yet demonstrated at scale.

Read the full analysis: https://www.tihek.gov.tr/web-siteleri-ve-mobil-uygulamalarin-erisilebilirligi-konulu-2025-10-sayili-cumhurbaskanligi-genelgesi-hakkinda-basin-aciklamasi