Penalties for Companies Without VERBİS Registration: Updated KVKK Fines for 2026
Companies that fail to register with VERBİS despite being required to do so under KVKK face a risk of administrative fines. This risk is not limited to failure to register in the system.…
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Penalties for Companies Without VERBİS Registration: Updated Amounts for 2026
Companies that fail to register with VERBİS despite being required to do so under KVKK face
a risk of administrative fines. This risk is not limited to failure to register in the system.
Incomplete, inaccurate or outdated VERBİS notifications can create additional compliance risks for companies.
In 2026, KVKK administrative fines were updated, taking into account the revaluation rate declared in the Official Gazette.
Under General Communiqué No. 585 on the Tax Procedure Law, published in Official Gazette No. 33090 of 27 November 2025,
the revaluation rate for 2025 was set at 25.49%.
The administrative fine that may be imposed in 2026 for a breach of the VERBİS registration and notification obligation
can, according to current assessments, range from TRY 341,809 to TRY 17,092,242.
The fine may vary depending on the nature of the breach, company size, volume of data processing, degree of fault and the Board’s assessment.
What Is the Legal Basis for Sanctions for Failure to Register with VERBİS?
VERBİS registration is one of
the fundamental obligations imposed on data controllers under Personal Data Protection Law No. 6698. Data controllers that meet certain conditions must
register with the Data Controllers Registry.
Failure to meet the registration obligation is subject to sanctions under the KVKK provisions governing administrative fines.
Failure to register with VERBİS is therefore more than an administrative omission: it is a compliance breach that directly exposes the company to sanctions.
The KVKK administrative fines are updated each year, taking into account the revaluation rate.
The revaluation rate used to calculate the 2026 fines
was set by General Communiqué No. 585 on the Tax Procedure Law, published in the Official Gazette, at
25.49%.
Administrative fines that may be imposed under the KVKK in 2026 are determined in different ranges according to the type of infringement.
Breaches of the VERBİS registration and notification obligation are among the highest-risk items for companies in this table.
| Violation Type | 2026 Minimum | 2026 Maximum |
|---|---|---|
| Failure to meet the duty to inform | 85,437 TL | 1,709,200 TL |
| Violation of data security obligation | 256.357 TL | 17.092.242 TL |
| Failure to comply with Board decisions | 427.263 TL | 17.092.242 TL |
| Violation of registration and notification obligation to VERBIS | 341.809 TL | 17.092.242 TL |
| Failure to meet the duty to notify standard contracts | 90,308 TL | TRY 1,806,377 |
The VERBIS penalty is not a single fixed amount. The Board assesses between the lower and upper limit according to the circumstances of the concrete event.
Therefore, the same violation can lead to different penalty amounts for different companies.
Companies at risk in relation to VERBİS obligations are not limited to very large businesses.
Employee count, balance sheet total, processing of special categories of personal data and data processing volume should be assessed together.
- Companies with more than 50 employees per year
- Companies whose annual financial balance sheet total exceeds the relevant threshold
- Businesses whose main activity is processing special categories of personal data
- Healthcare, clinical, laboratory and medical service providers
- E-commerce firms and structures that process high volume customer data
- Franchises, dealerships and companies with multiple branches
- Data controllers based abroad that process personal data in Türkiye
The idea that "our number of employees is below 50, so we don't have to register with VERBIS" is not always true.
The balance sheet total or the processing of special categories of data may also give rise to the obligation.
When imposing an administrative fine, the KVKK Board considers more than whether registration has taken place.
The characteristics of the concrete event, the size of the data controller, the duration of the breach, and the nature of data processing activities are evaluated together.
- Whether the company’s VERBİS obligation is clear
- How long the obligation remained unfulfilled
- The company's data processing volume
- Whether special categories of personal data are processed
- Whether the breach was remedied voluntarily
- Responses to correspondence from the Board or Authority
- Whether similar breaches occurred previously
- The company's overall KVKK compliance level
No. For VERBİS, both failing to register at all and fulfilling registration and notification obligations incompletely or incorrectly can create risks.
For example, even if the company has registered with VERBIS, if data processing activities have not been properly declared,
additional compliance risks arise if special categories of personal data are underreported or cross-border transfers are reported incorrectly.
- No registration is made to VERBIS
- Missing the registration deadline
- Incomplete reporting of data categories
- Declaring false retention period
- Incomplete reporting of recipient groups
- Failure to report overseas data transfer
- Not keeping the VERBIS record up to date
VERBİS registration alone does not establish KVKK compliance.
The VERBİS declaration must align with the data inventory, privacy notices, retention and destruction policy and actual operational processes.
Subsequent registration of VERBIS does not automatically eliminate past infringement in all cases.
However, prompt action after recognizing the obligation, remedying the omission and documenting compliance measures
may be taken into account positively in the Board’s assessment.
As soon as companies realize that the obligation has arisen, they should therefore do more than simply register in the system;
they must also review the data inventory, privacy notices, retention and destruction policy and technical and administrative measures.
Examples involving different types of companies can help clarify VERBİS fine risks.
Example 1: Manufacturing Company with 60 Employees- Number of employees: 60
- Balance sheet total: TRY 45 million
- VERBIS registration: not done
Even with a low balance sheet total, this company may be subject to VERBİS obligations because of its employee count.
Failure to register may create a risk of an administrative fine.
- Number of employees: 30
- Balance sheet total: TRY 130 million
- Customer data: processed extensively
- VERBIS registration: not done
Even if the number of employees is less than 50, a VERBIS registration obligation may arise due to the sum of the financial balance sheet.
Extensive processing of customer data also increases KVKK compliance risks.
- Number of employees: 12
- Total financial balance sheet: under general threshold
- Health data: processed under main activity
- VERBIS registration: not done
Healthcare organizations whose main activity is processing special categories of personal data may be assessed differently from the general thresholds.
The VERBİS obligation must also be analyzed specifically because health data is processed.
Verbis risk is not just the problem of large companies.
Companies with few employees but a high balance sheet total or processing of special categories of data may also be required to register.
Companies must regularly assess their obligations to protect against VERBİS fine risks.
This assessment should be repeated at year-end and whenever the company grows, adds new data processing activities or changes its digital systems.
- Number of employees per year
- Annual financial balance sheet total
- Main business activity
- Whether special categories of personal data are processed
- Data processing inventory
- privacy notice
- Retention and disposal policy
- Technical and administrative measures
- Whether the VERBİS registration is up to date
Companies whose balance sheet total becomes clear after filing the corporate tax return
must check their VERBİS obligations without delay.
Once the balance sheet threshold is exceeded, companies must not overlook the registration deadline or analysis of their obligations.
Companies without VERBİS registration face a serious risk of administrative fines in 2026.
Under the current fine ranges, a breach of the VERBİS registration and notification obligation can attract a fine of
TRY 341,809 to TRY 17,092,242.
Companies must therefore answer “Are we subject to the obligation?” through
a concrete analysis of employee count, balance sheet total, business activity and data processing, rather than assumptions.
VERBIS registration is an important part of the KVKK compliance process; however, it alone is not enough.
Effective compliance requires joint management of the data inventory, privacy notices, retention and destruction policy, data security measures and regular updates.
At B10 Digital Agency, we analyze whether your company must register with VERBİS
based on employee count, balance sheet total, business activity and data processing.
Through our hybrid model, in which legal advisors and technical teams work together,
we assess VERBİS registration, data inventory, privacy notices, retention and destruction policy, cookie compliance and technical and administrative measures together.
The number of employees, financial balance sheet and activity are evaluated together. 📋 Data Inventory Review
The VERBİS declaration is compared with actual data processing activities. ⚖️ KVKK Action Plan
Deficiencies are converted into a viable legal, administrative and technical roadmap.
If you are unsure whether your company must register with VERBİS, its obligations should be analyzed before a fine risk arises.
Request a VERBİS Fine Risk Analysis
Yes. Data controllers that fail to register despite being subject to VERBİS registration and notification obligations may receive an administrative fine under KVKK.
How much is the VERBIS penalty in 2026?In 2026, the administrative fine for breaching the VERBİS registration and notification obligation is assessed within a range of TRY 341,809 to TRY 17,092,242.
Does Registering with VERBİS Later Remove the Fine?Registering later may not automatically remedy the earlier breach. However, promptly addressing omissions and documenting compliance steps may matter in the assessment.
Is registration at VERBIS sufficient for KVKK compliance?No. VERBİS registration is only one part of KVKK compliance. The data inventory, privacy notices, retention and destruction policy and technical and administrative measures must also be managed.
Sources and related documents
These documents provide references for the methods and rules discussed in this article.