What is İYS, and which patient messages need consent?
Published 23 October 2026Reviewed 23 October 20266 min read
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What is a commercial electronic message, and where does the consent rule come from?
According to the Regulation on Commercial Communication and Commercial Electronic Messages, a commercial electronic message is a message with data, voice or image content sent for commercial purposes by means such as telephone, call centre, automatic dialling machine, smart voice recorder, e-mail or text message. Its basis is Article 6 of Law No. 6563 on the Regulation of Electronic Commerce: commercial electronic messages cannot be sent without the recipient's prior consent, which may be given in writing or electronically.
Article 7 requires the content of a message to match the consent and to carry the provider's identity. Article 8 gives the recipient the right to refuse messages at any time without giving a reason; the provider must act on it within three business days. Under the Regulation the consent form cannot be pre-ticked, consent cannot be made a condition of the service, and the burden of proving consent lies with the provider.
Which messages count as commercial?
Article 6(2) of the Regulation says notices about subscriptions, memberships, payments, debt reminders, deliveries and information updates do not need prior consent but must not promote or advertise anything. An appointment reminder is informational by the same logic; that mapping is our interpretation.
- Appointment confirmation and reminder
- Consent needed?No
- NoteAppointment details only; do not slip in promotion.
- Quote link (the patient asked)
- Consent needed?No
- NoteA reply to the patient's request; the quote itself is information.
- A payment date is coming
- Consent needed?No
- NoteA payment and debt notice; keep it free of promotion.
- Post-treatment follow-up question
- Consent needed?No
- NoteCare information; adding “our new campaign” makes it commercial.
- Discount, campaign or package announcement
- Consent needed?Yes
- NoteHealth promotion rules also apply (see below).
- Newsletter, “our new service”
- Consent needed?Yes
- NotePrior consent and an İYS record.
- Birthday greeting plus a discount
- Consent needed?Yes
- NoteAdding the discount makes it promotion.
What is İYS and how does it work?
Article 11(5) of the law has the Ministry of Trade set up an electronic system: providers transfer the consents they hold to it within the set time, consents not transferred are void, and recipients can view their own consents. That system is the Message Management System, İYS.
Under the amendment to the Regulation of 28 August 2020 (Official Gazette no. 31227), consents were to be transferred to İYS by 1 December 2020 and recipients were to check them by 16 January 2021. According to the Ministry of Trade's press release of 30 November 2020, the extended deadlines were 31 December 2020 for providers with more than 150,000 consents and 31 May 2021 for those with 150,000 or fewer. Today, as a new provider, the job is to register with İYS and enter the consents you collect.
How do the health promotion rules come in?
İYS consent does not free you to send any content. According to the Ministry's FAQ on the Regulation on Promotion and Information Activities in Health Services (12 November 2025, no. 33075), advertising is banned domestically; promotion with testimonials, thanks, prices, discounts and campaigns is not allowed. Messages, SMS, e-mail and phone calls for promotion without the person's knowledge and consent are also banned (Art. 5(1)(k)).
International health tourism facilities may promote only on a separate foreign-facing platform in languages other than Turkish, with the Health Turkiye logo and the authorisation certificate; prices and campaigns may be shown there. If the recipient is outside Türkiye, check Article 2 of the Regulation and ask your lawyer about the scope of the İYS regime.
Fines
- Breach of Art. 6(1) or 7(1) (Art. 12(1)(a))
- For 2026Administrative fine of 2,859 TL to 14,309 TL (Ministry of Trade communiqué, Official Gazette 25 December 2025, no. 33118)
- Messages sent to several people at once (Art. 12(2))
- For 2026Up to ten times
Step by step: sort out patient messages
Split your messages in two
Informational (appointment, quote, payment, follow-up) and promotional. List each message type in a table.
Clean the informational ones
Add no campaign, newsletter link or service advert to them.
Get consent before promotion
The form is not pre-ticked, not a condition of service, and records who agreed to what channel and when.
Register with İYS and enter consents
Transfer the consents you collect; act on withdrawals within three business days.
Check promotional content
Domestically, follow the health promotion rules; on a foreign-facing platform, meet the certificate and language conditions.
Use the content check
Read the warnings on public texts; do not send a campaign before your lawyer has seen it.
How it is done in Klinikbook
Klinikbook sends no promotions and does not upload anything to İYS. The e-mails it sends to patients are transactional.
Publish the marketing consent text
In the compliance centre the marketing consent text comes from a template and is published in the portal; the consent is recorded against the workspace's published text version.
Record consent on the contact
The contact's marketing consent carries an İYS state (not registered, registered, failed), shown only on Türkiye workspaces. You enter the consent into İYS yourself and write the result here.
Handle withdrawal
When a data request chooses objection, marketing and photo consents are withdrawn.
Keep transactional messages separate
Appointment reminders, quote links, payment reminders and follow-up e-mails carry no promotion; they go to the patient in the clinic's name and replies reach the clinic.
Consents and texts
Frequently asked questions
Do I need İYS consent for an appointment reminder?
If the reminder holds only appointment details and carries no promotion, then by the logic the Regulation gives to informational notices, no consent is needed. If you add a campaign or a service advert, the message becomes commercial.
The patient gave me their number. May I send a campaign?
Giving a number is not consent. Promotion needs a separate, prior consent you can prove. In Board decision 2022/923 a doctor who used a number taken at an examination for an advertising SMS was fined 100,000 TL.
May I refuse service if the patient gives no consent?
No; under the Regulation consent cannot be made a condition of the service.
How fast must I stop after a withdrawal?
Under Article 8 of the law the provider acts on the request within three business days.
Is a WhatsApp message a commercial electronic message too?
The Regulation defines commercial electronic messages as messages with data, voice or image content sent for commercial purposes by means such as telephone, e-mail or text message. The same rule logic applies to a promotional WhatsApp message; confirm the scope with your lawyer.
Does Klinikbook upload consents to İYS?
No. You enter the consent into İYS and record the result on the contact. Klinikbook itself sends no promotions.
Sources
- Law No. 6563 on the Regulation of Electronic Commerce, Articles 6, 7, 8, 11 and 12 (Turkish text) — Mevzuat Bilgi Sistemi, Official Gazette, 5 May 2015
- Regulation on Commercial Communication and Commercial Electronic Messages (Turkish) — Official Gazette, 15 July 2015, no. 29417
- Amendment to the Regulation (Turkish) — Official Gazette, 4 January 2020, no. 30998
- Press release on the Message Management System (İYS) (Turkish) — Ministry of Trade, 30 November 2020
- Regulation on Promotion and Information Activities in Health Services (Turkish) — Official Gazette, 12 November 2025, no. 33075
- Promotion in health services: frequently asked questions (Turkish) — General Directorate of Health Services, Department of Inspection and Evaluation, November 2025
- Communiqué on administrative fine amounts for 2026 (Turkish) — Ministry of Trade, Official Gazette, 25 December 2025, no. 33118
- Board decision summary 2022/923 (Turkish) — Personal Data Protection Authority (KVKK), 8 September 2022
Keep information and promotion apart
Transactional patient e-mails, marketing consent records and data requests in one place.
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