Deepfake

A deepfake is content in which artificial intelligence techniques are used to imitate or alter a person’s image, voice or movements in a way that is hard to distinguish from reality. Replacing a face in a video with someone else’s, showing a person saying words they never said, or cloning their voice are typical examples.

The Position Under Turkish Law

Turkish law has no deepfake-specific statute or criminal offence. Deepfake content is assessed under general provisions depending on its nature:

• Personality rights: Using a person’s image or voice without permission infringes their personality rights under the Turkish Civil Code. Pictures and portraits are also protected by Article 86 of the Law on Intellectual and Artistic Works. The victim may seek an injunction and damages.
• Access blocking: For content infringing personality rights, the victim may apply to a criminal judgeship of peace under Law No. 5651 for removal of the content or blocking of access.
• Criminal law: Depending on the content, offences such as defamation, violation of privacy, unlawful recording or dissemination of personal data, obscenity, blackmail and fraud may be relevant.
• Personal data: A person’s face and voice are personal data; when processed through technical means aimed at identifying the person, they may qualify as biometric data, a special category. Victims may also exercise their rights under the KVKK.

For a detailed assessment, see Deepfake Technology: Legal Challenges and Key Questions.

European Union: Labelling Obligation

Article 50 of the EU AI Act requires deployers of AI systems that generate or manipulate deepfake content to disclose that the content has been artificially generated or manipulated. This obligation has applied since 2 August 2026 and applies even where there is no intent to deceive. Turkish companies producing advertising, marketing or other content for the EU market may also be subject to this rule.

Risks for Companies

• Advertising and marketing: Using the image or voice of a celebrity or an ordinary person through AI without permission leads to personality rights infringement and unfair competition claims.
• Fraud: Payment instructions given through calls imitating an executive’s voice or image are increasingly common; payment processes should use a second verification channel.
• Employees: Deepfake content produced within a company may raise disciplinary issues and employer liability under employment law.