KVKK vs GDPR: A Comparison Guide

KVKK (Law No. 6698) and GDPR (the EU General Data Protection Regulation) serve the same goal: protecting personal data. Their principles are largely similar, but there are important differences in scope, authority and certain obligations. For organizations operating in both Türkiye and the EU, knowing these differences is critical.

This content is for general information only and does not constitute legal advice.

Scope and geography

• GDPR covers organizations established in the EU/EEA and those offering goods/services to, or monitoring the behavior of, people in the EU — meaning it has an extraterritorial reach.
• KVKK applies to personal-data processing activities in Türkiye.

A Turkish company serving people in the EU may be subject to both KVKK and GDPR.

Authority

• GDPR: Each EU member state has a data protection authority (DPA), with the European Data Protection Board (EDPB) at the top level.
• KVKK: The Personal Data Protection Authority and its decision body, the Board, are competent.

Registration obligation

• KVKK: Data controllers meeting certain criteria register with VERBİS.
• GDPR: There is no central registry; instead organizations keep records of processing activities (Article 30).

Data-subject rights

Both frameworks include rights such as access, rectification, erasure and objection to processing. GDPR more explicitly regulates data portability and the "right to be forgotten"; under KVKK, rights are listed in Article 11.

Cross-border data transfer

Both regimes condition cross-border transfers. GDPR uses mechanisms such as adequacy decisions and standard contractual clauses (SCC). On the KVKK side, transfers abroad are also subject to specific safeguards and procedures. Keeping up with current mechanisms matters on both sides.

Sanctions

• GDPR: Depending on the type of violation, it provides for high administrative fines up to a certain percentage of turnover.
• KVKK: Administrative fines apply under Article 18; amounts are updated each year by the revaluation rate.

For current specific figures, rely on the official sources of the relevant authorities.

The common ground: provable compliance

Whichever regime you are subject to, the common requirement is the same: knowing your processing activities, taking measures, and being able to prove it. A well-built compliance system covers much of both KVKK and GDPR obligations from the same foundation.

Kivuz KVKK is a KVKK compliance software that manages compliance in a documentable way — from inventory to audit — and keeps data in Türkiye. To see the process end to end, read our KVKK compliance process guide, or request a demo for an assessment tailored to your organization.