With the Regulation on Direct Sales (“Regulation”) published in the Official Gazette dated 8 August 2025 and numbered 32980, direct sale systems have been re-regulated, which are sales systems established by a direct sale company and in which direct sellers (who are not employed by the relevant direct sale company under an employment contract but rather act as independent representatives, distributors, consultants or under similar titles, and engage in return for benefits such as commissions, bonuses, incentives, and rewards) sell or market goods or services to consumers. As of the enactment of the Regulation, the direct sale systems have been excluded from the scope of the Regulation on Contracts Established Outside the Business Premises.
In parallel with the amendments made to the Consumer Protection Law (“Law”) on 24 October 2024 and which entered into force on 30 July 2025, as envisaged by the Law, new regulations are intended to determine rights and obligations of direct sale companies, direct sellers and consumers as well as contracts falling outside the scope, sale of goods or services, right of withdrawal, obligations to inform, delivery and other procedural rules and principles applicable in such systems. For the first time, specific provisions have been introduced for the previously under-regulated direct sale systems. The purpose of these regulations is to prevent direct sale systems to be implemented as pyramid sales schemes, to ensure that such systems operate in a transparent, fair and reliable manner, and to meet the need for clear and enforceable rules applicable to this sales model.
Certain key amendments are evaluated below. It should be noted at the outset that these rules apply not only to direct selling business models where sales to consumers are carried out by direct sellers, but also to business models where third parties act as intermediaries for purchases of goods or services from the direct sale company and obtain benefits such as commissions, bonuses, incentives and rewards under a compensation plan offered by direct sale companies in return for their marketing activities. Accordingly, the Regulation covers business models not only where the contractual relationship with consumers is established directly with direct sellers, but also where consumers purchase goods or services from direct sale companies through or as a result of marketing activities of third-party referrals.
Authors:
Görkem Bilgin, Partner
Email: gorkem.bilgin@gun.av.tr
Yalçın Umut Talay, Managing Associate
Email: umut.talay@gun.av.tr