Differences Between the EU AI Act and Turkish Law: A Roadmap for Startups

⏱️ Reading time: 5 min · 📁 Category: Entrepreneurship & Technology

The EU Artificial Intelligence Act (AI Act) is the first comprehensive regulation for safe, ethical and transparent AI development. Türkiye does not yet have an equivalent Artificial Intelligence Law in force, but KVKK, Consumer Protection Law, Turkish Penal Code and competition law indirectly cover AI systems. Understanding these differences matters particularly for startups entering the European market.

1️⃣ Risk-based approach: the backbone of the AI Act

The AI Act classifies AI systems by risk level. Turkish legislation has no equivalent distinction, so startups operating in Europe need to organise their systems around risk categories.

High-risk systems: Healthcare, finance, recruitment, justice and public services
Limited risk: Chatbots and recommendation systems requiring clear notices
Minimal risk: AI systems for gaming or entertainment
Instead of a risk-based framework in Turkey, general provisions apply on the "data protection" axis

2️⃣ Transparency, Ethics and Human Control

The AI Act requires human oversight of algorithmic decisions. Turkish law does not explicitly formulate this principle, but Article 11 of the KVKK provides similar protection through the right to object to decisions based on automated processing.

AI Act: "Explainability" obligation - user should be able to understand algorithm's decision logic
Turkey: indirect information via explicit consent and privacy notice
AI Act: human intervention, or human-in-the-loop, is required
Turkey: No such obligation is directly defined

3️⃣ Data quality and training-set review

The AI Act mandates that data sets used in artificial intelligence systems be neutral, up-to-date, and representative. This brings serious responsibilities to startups' data collection and tagging processes.

AI Act: training data must be bias-free, with documented sources and currency
AI Act: Data management plan (Data Governance Plan) required
Turkey: No direct regulation of data quality, but Article 4 of the KVKK includes the principle of "being accurate and up to date"
In practice, startups need to prepare their own "Data Governance Policy" documentation

4️⃣ Compliance and Control Process

The AI Act introduces a CE-like AI Conformity Assessment process for developers. Since Türkiye has no equivalent certification mechanism, startups often create their own internal controls.

AI Act: Certification, registration obligation and independent audit processes
Turkey: Voluntary audit or compliance through ISO 42001 / ISO 27001 standards
Investors demand these documents, especially in initiatives targeting the EU market.

5️⃣ Roadmap for startups

Startups in Türkiye expanding into Europe can coordinate AI Act and KVKK compliance using these steps:

Identify the system’s risk category, referring to AI Act Annex III.
Document data sources and processing purposes in a Data Inventory and Data Governance Plan.
Add clear user notices, such as “This system is supported by AI.”
Establish human oversight and manual correction mechanisms.
Revise explicit-consent and privacy notices for KVKK compliance.

Conclusion: The AI Act addresses technical, ethical and legal dimensions of AI. Turkish startups should view it as a global trust standard rather than an obstacle. B10’s AI Compliance Framework model brings startups’ KVKK and AI Act compliance processes into one report.

Learn about the AI Compliance Framework