Penalties for Companies Without VERBİS Registration: Updated Amounts for 2026

A controller required to register with VERBİS risks an administrative fine under Article 18 of Law No. 6698 if it fails to meet the Registry registration and notification obligations.

For 2026, avoid using outdated figures found online. The Authority’s current table gives an administrative fine range of TRY 341,809 to TRY 17,092,242 for breaches of VERBİS registration and notification obligations.

VERBİS fine range for 2026

Under Article 18/1/ç of Law No. 6698, breaches of the Data Controllers Registry registration and notification obligations are subject in 2026 to administrative fines ranging from TRY 341,809 to TRY 17,092,242.

The Authority’s official fine table gives a revaluation rate of 25.49% for 2026.

Does every company automatically receive the maximum fine?

No. The Law does not set a single fixed VERBİS fine; it provides a range between a minimum and a maximum.

The specific outcome for a company also depends on the nature of the breach and other applicable criteria under administrative sanctions law. It is therefore incorrect to say that failure to register with VERBİS automatically leads to a TRY 17 million fine.

First establish whether you are required to register

The first step in assessing fine exposure is to establish correctly whether the controller is required to register with VERBİS.

Assess employee numbers, the balance-sheet criterion, whether accounts are kept on a balance-sheet basis, the main activity and processing of special categories of personal data together.

What if registration exists but the notification is outdated?

VERBİS obligations are not limited to initial registration. The data categories, purposes, recipient groups, international transfer details, security measures and retention periods reported in the Registry must also remain current.

A Registry entry that still describes the old setup after substantial changes to actual processing creates an additional compliance risk.

VERBİS fines are not the only sanctions under the KVKK

Failure to meet VERBİS registration obligations is only one ground for administrative sanctions under the Law. Separate provisions address other obligations, such as informing individuals, ensuring data security and complying with Board decisions.

Therefore, completing the registration alone and neglecting other KVKK controls is not an adequate risk management method.

Steps to assess and manage fine exposure

Reassess the registration obligation with current criteria
Document the grounds for any exemption relied on
Check that the VERBIS record is active and up to date
Compare the actual data inventory with the Registry notification
Review new systems and international data flows
Keep a dated record of the internal review findings

Manage VERBİS as an ongoing control, not a static registration

VERBİS and the personal data inventory can quickly become outdated when disconnected from actual company operations. A new employee application, CRM, payment infrastructure, web form, marketing tool, SaaS service, cloud provider or AI application can introduce new data categories, recipient groups or international transfers. Procurement, software development, integration and supplier onboarding processes therefore need checks on their personal data implications.

In a sound control model, each processing activity is linked to a business process owner, a system owner and a legal assessment. Recording the source and destination systems, data-subject group, data category, purpose, legal basis, recipient, transfer country or arrangement, retention period and security measures together allows VERBİS notifications to reflect actual operations. The registry entry then becomes more than a document opened only for audits.

Periodic reviews should cover discontinued processes as well as new ones. Unused applications, old user accounts, archives, logs, backups and terminated supplier connections can create data-retention and access risks. Cross-checking the inventory against technical systems in both directions helps prevent both incomplete notifications and obsolete processing activities remaining unnecessarily in the Registry.

B10 Digital Agency’s approach to KVKK and digital compliance

B10 Digital Agency treats KVKK work as more than document preparation: it is an operational compliance model combining the data inventory, VERBİS, system and integration mapping, international data transfers, security controls and change management.

Frequently Asked Questions

What is the VERBİS fine in 2026?

The official KVKK table provides for administrative fines ranging from TRY 341,809 to TRY 17,092,242 for breaches of the registration and notification obligations.

Is the TRY 17,092,242 maximum automatically applied to everyone?

No. This is the maximum for the relevant sanction in 2026; the Law does not prescribe one fixed fine.

Does this fine apply to a company exempt from VERBİS registration?

First, establish correctly whether the company has a Registry registration obligation.

Does VERBİS registration eliminate other KVKK fines?

No. The KVKK also contains obligations and sanction provisions beyond VERBİS.

Related VERBIS Guidelines

Official Sources

Note: This content provides general information. A company’s specific VERBİS and KVKK obligations require a separate assessment of its activities and current legislation.

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