Executive Summary
The Regulation on Direct Sales, published in the Official Gazette on August 8, 2025, is the first comprehensive legislation in Türkiye to regulate the direct sales sector in detail. Its purpose is to protect consumers while ensuring that companies operating in the sector work transparently, fairly, and sustainably.
Pre-Regulation Situation:
Direct sales is a sales model in which products or services are delivered to consumers through independent representatives, without intermediary stores. Previously, the sector was subject to the general provisions of Law No. 6502 and the regulations on “door-to-door sales” and “distance sales.” There was no special licensing requirement, capital requirement, or oversight mechanism for company structures. This gap created a fertile ground for certain illegal pyramid schemes to operate under the guise of “direct sales.”
Key Innovations of the New Regulation:
License Requirement: Companies must obtain a “Direct Sales License” from the Ministry of Trade, valid for three years.
Capital and Security Deposit: A minimum paid-in capital of TRY 10 million and a blocked bank account of TRY 3 million (effective from 01.01.2026).
Consumer Rights: An unconditional 30-day withdrawal right, extendable up to one year in cases of incomplete information; 30-day refund period.
Mandatory Pre-Contract Information: A form containing product details, price, delivery, withdrawal conditions, and company information.
Seller Rights and Restrictions: No participation fees or membership dues; persons under 18, those lacking legal capacity, and close relatives of company partners/managers cannot join; starter kits regulated with price limits.
Pyramid Scheme Prevention: The total of commissions and bonuses may not exceed 50% of the company’s annual net sales revenue; incentives based on recruiting new members may not exceed 30%.
Inspection and Sanctions: The Ministry may revoke the licenses of non-compliant companies and publicly disclose such companies.
Impact on the Sector:
The regulation will strengthen the presence of financially strong, product-oriented companies while removing illegal or financially insecure entities from the sector. It is a critical step toward transparency, consumer confidence, and sustainable growth in the direct sales sector, aiming to create a safe commercial environment for both professionals and consumers.
Legal Assessment on the Regulation of Direct Sales and Its Impact on the Sector
The Regulation on Direct Sales, published by the Ministry of Trade in the Official Gazette on August 8, 2025, introduces for the first time in Türkiye a comprehensive set of rules specifically tailored to direct sales systems. This new framework aims to protect consumers’ rights while defining the conditions necessary for the transparent, fair, and reliable operation of the direct sales sector. In recent years, the sector has grown rapidly with the participation of new entrepreneurs, reaching a market volume of USD 550 million in Türkiye as of 2024. With this regulation, the sector has entered a new era. Below, the concept of direct sales and the differences between previous and new practices are discussed.
What is Direct Sales?
Direct sales is a model in which products or services are offered directly to consumers without a fixed store or traditional retail chain. In this method, companies use independent representatives or distributors (direct sellers) to make sales, usually face-to-face, in consumers’ homes, workplaces, or similar settings. The consumer purchases the product directly from the seller or the company they represent, and the seller earns a commission or bonus from the sale. This system is used across a variety of sectors, from cosmetics and dietary supplements to household cleaning products. Direct sales may include multi-level marketing structures such as network marketing; however, pyramid schemes—unsustainable structures characterized as saadet zinciri under Article 80 of the Consumer Protection Law—are prohibited. The new regulation specifically aims to draw a clear line between legitimate direct sales and illegal pyramid systems.
The Direct Sales Sector Before the Regulation
Before the regulation, there was no special licensing or minimum capital requirement for direct sales companies and sellers. Activities in this area were generally limited to the general provisions of the Consumer Protection Law No. 6502 and the regulations on distance sales or contracts concluded away from business premises (door-to-door sales). For example, a sale made by a direct sales representative in a consumer’s home was considered a sale concluded away from business premises, giving the consumer a 14-day right of withdrawal. However, there was no specific oversight mechanism for companies’ organizational structures, commission systems, or capital adequacy. This sometimes allowed pyramid-like structures based primarily on member recruitment rather than product sales to operate under the guise of direct sales. While pyramid sales systems were already banned under Law No. 6502, and heavy penalties were prescribed for those who established such structures, there remained grey areas between legitimate direct sales and illegal schemes.
Leading companies in the sector had long operated under the Direct Selling Association (DSD), which established self-regulation and ethical rules. In 2024, with the addition of Article 47/A to the Consumer Protection Law, the direct sales system gained a legal definition. This legal basis paved the way for the August 8, 2025 regulation. The goal is to prevent entities whose main focus is not product sales, and which operate with low capital while causing consumer harm, from presenting themselves as “direct sales companies.”
Key Provisions of the New Regulation
License Requirement:
Any company wishing to operate in direct sales must obtain a Direct Sales License from the Ministry of Trade. This license will be valid for three years and registered in the Ministry’s records. Licensed companies will be listed publicly by the Ministry, and expired licenses must be renewed through reapplication. Operating without a license will result in sanctions.Capital and Security Deposit:
To ensure financial stability and protect consumers from potential losses, direct sales companies must meet significant capital requirements. The company must be a capital company with a paid-in capital of at least TRY 10 million. In addition, it must maintain a blocked bank account in Türkiye with TRY 3 million. This amount will serve as collateral to cover consumer claims if necessary. (These provisions will take effect on January 1, 2026, giving companies a compliance period.)30-Day Right of Withdrawal for Consumers:
Consumers who purchase goods via direct sales have an unconditional right to withdraw within 30 days. This period is twice the 14-day withdrawal period in standard distance/door-to-door sales contracts, offering significant protection in favor of consumers. Once the withdrawal notice reaches the company or seller, they must refund all payments, including delivery costs, within 30 days. If the pre-contract information form is not provided or is incomplete/incorrect, the withdrawal period can be extended up to one year. Certain goods and services, as in other consumer contracts, are excluded from the right of withdrawal (e.g., custom-made products, perishable goods, opened products unsuitable for return due to hygiene or health reasons).Pre-Contract Information Obligation:
Sellers must provide a written or electronic form before the sale, containing details such as product/service description, total price including taxes, delivery/performance conditions, company name and contact details, seller identity and registration number, conditions and duration of withdrawal rights, and dispute resolution channels. This form becomes an integral part of the sales contract, and sales without it are considered invalid. Companies must also establish systems that make order, delivery, and return information easily accessible to consumers.Participation Rules and Seller Rights:
Persons under 18, those lacking legal capacity, and the immediate relatives of company shareholders/managers cannot join as sellers. No participation fees, membership dues, or deposits may be charged. If starter kits are sold, their price cannot exceed the company’s suggested retail price, and purchasing a kit will not confer any hierarchical advantage. Sellers may leave the company at any time without penalties or debts. If a seller leaves within 30 days, the company must buy back unsold products and refund their cost within 30 days (minus any paid commissions).Pyramid Scheme Prevention (Fair Compensation Plan):
The primary source of income in a direct sales organization must be sales to consumers, not recruiting new sellers. Misleading promises of quick wealth are prohibited. Two financial limits apply: (1) Total benefits paid to sellers (commissions, bonuses, etc.) cannot exceed 50% of the company’s annual net sales revenue; (2) Incentives based on recruiting new sellers cannot exceed 30% of total annual benefits paid. At least 70% of all commissions must come from actual product/service sales.Inspection and Sanctions:
The Ministry of Trade is authorized to monitor companies and enforce compliance. Companies must maintain all requirements continuously. Failure to comply (e.g., insufficient capital or deposit) may lead to license revocation if not remedied. Serious violations such as turning the compensation plan into a pyramid scheme may result in immediate license cancellation without warning. Revoked companies will be publicly listed and barred from reapplying.
Impact on the Sector
This regulation marks the beginning of a comprehensive transformation in direct sales. Major companies, already operating under international ethical standards and possessing strong financial bases, have welcomed the clear legal framework. The new licensing and capital requirements will eliminate small-scale or unregistered entities, leaving a market dominated by more reliable and institutional companies. The distinction between legitimate direct sales and pyramid schemes will become clearer, enhancing the sector’s reputation.
For consumers, the regulation provides a safer shopping environment. Knowing they have a 30-day right of withdrawal, consumers will feel more comfortable making purchases. The obligation for written pre-contract information reduces the risk of misdirection. Transparent withdrawal and refund processes will boost satisfaction.
Honest sellers will also benefit, as the removal of bad actors will make it easier for dedicated sellers to operate and ensure more sustainable compensation plans.
While some short-term challenges may arise—especially for companies unable to meet the TRY 10 million capital and TRY 3 million deposit requirements—this filtering process will ultimately result in a market of financially sound companies. Publicly listing licensed companies will improve transparency and help consumers distinguish between authorized and unauthorized operators. The regulation provides the sector with a corporate identity and ensures that the flexible entrepreneurship opportunities offered by the direct sales model can continue in a safer environment.
Attorney and Mediator Fatih Mehmet Tercan