Overview

Türkiye’s approach to artificial intelligence (AI) governance is undergoing a rapid and consequential evolution, marked by ambitious national strategies, landmark legislative proposals, and a complex interplay between economic aspiration and state control. This report provides an exhaustive analysis of this landscape, tracing its development from the foundational 2021 National AI Strategy (NAIS) to the more focused and technologically current 2024-2025 Action Plan. The analysis reveals a nation at a pivotal moment, striving to secure a competitive position in the global AI race while simultaneously building a comprehensive regulatory and institutional framework from the ground up.

The cornerstone of this new era is the introduction of the Draft AI Law in June 2024. This legislation represents Türkiye’s first dedicated attempt to regulate AI, and its structure is deliberately modeled on the European Union’s AI Act. This strategic alignment signals a clear intent to harmonize with international standards, fostering a predictable environment for foreign investment and technological partnership. However, the draft law contains significant ambiguities, particularly in its failure to define “high-risk” AI systems or designate a supervisory authority, which provides the government with considerable regulatory latitude.

Governance is centrally managed by the Presidency’s Digital Transformation Office (DTO) and the Ministry of Industry and Technology (MoIT), which have co-authored the national strategy. This top-down structure is designed to marshal state resources effectively but faces criticism for a lack of on-the-ground coordination, contributing to a discernible gap between strategic ambition and practical execution. This gap is reflected in Türkiye’s modest ranking in global AI readiness indices, which contrasts sharply with its stated goal of becoming a top-20 AI nation.

Progress within the domestic AI ecosystem is tangible, with a growing number of startups, significant academic contributions from leading universities, and increasing public sector adoption. The government has successfully fostered a pipeline of talent and supported innovation through targeted programs. Yet, this progress is shadowed by a fundamental tension. While official policy champions a “human-centric” and “responsible” approach to AI, often showcased through beneficial applications in healthcare, a parallel and substantial investment is being channeled into expanding AI-powered state surveillance systems. This raises profound questions about the future of digital rights and civil liberties in the country.

Ultimately, Türkiye’s AI journey is defined by this central contradiction. Its success in becoming a leading AI power will depend not only on technological and economic prowess but on its ability to resolve the conflict between its pursuit of an open, innovative, EU-aligned economic model and its simultaneous construction of a closed, state-controlled digital infrastructure. Bridging the gap between ambition and execution, resolving institutional fragmentation, and addressing this fundamental duality will determine whether Türkiye can realize its vision of an agile, sustainable, and prosperous AI ecosystem.

 

1. The Strategic Blueprint: From National Vision to Actionable Policy

 

Türkiye’s formal journey into AI governance began with a comprehensive national strategy designed to mobilize the entire state and private sector apparatus. This initial blueprint has since evolved, adapting to the breakneck pace of technological change and refining its focus from broad ambitions to specific, actionable priorities. This evolution reflects a growing maturity in the country’s policy thinking, while the governance architecture reveals a highly centralized, state-driven approach to managing this technological transformation.

 

1.1. The 2021-2025 National AI Strategy (NAIS): Charting an Ambitious Course

 

In August 2021, Türkiye officially entered the global AI policy arena with the publication of its first National Artificial Intelligence Strategy (NAIS) for 2021-2025.1 Prepared jointly by the Presidency’s Digital Transformation Office (DTO) and the Ministry of Industry and Technology (MoIT), the NAIS was a foundational document intended to provide a comprehensive roadmap for the nation’s AI efforts.3 Aligned with the country’s broader 11th Development Plan and overarching strategic visions like “Digital Türkiye” and the “National Technology Initiative,” the strategy was positioned as a critical enabler of national progress.3

The vision articulated in the NAIS was ambitious: to “create value on a global scale with an agile and sustainable AI ecosystem for a prosperous Turkey”.1 To realize this vision, the strategy was structured around six holistic strategic priorities that covered the full spectrum of ecosystem development 1:

  1. Human Capital: Training AI experts and increasing employment in the field.
  2. Innovation Ecosystem: Supporting research, entrepreneurship, and innovation.
  3. Infrastructure: Expanding access to quality data and technical infrastructure.
  4. Socioeconomic Alignment: Enacting regulations to accelerate socioeconomic adjustment.
  5. International Collaboration: Strengthening cooperation at the international level.
  6. Structural Transformation: Accelerating the transformation of structures and the workforce.

To anchor these priorities in measurable outcomes, the NAIS established a set of aggressive quantitative targets to be achieved by the end of 2025. These benchmarks provided a clear framework for assessing the strategy’s success and included goals to increase AI’s contribution to GDP to 5%, expand AI-related employment to 50,000 people (with 1,000 in the public sector), produce 10,000 graduate-level AI specialists, and secure a position among the top 20 countries in major international AI indices.1

From its inception, the strategy incorporated the language of responsible innovation. It emphasized the need for a human-centered, trustworthy, and accountable approach to AI development, laying a nominal ethical foundation by referencing principles of fairness and transparency that would later be codified in legislation.8

 

1.2. The 2024-2025 Action Plan: A Strategic Pivot Towards Generative AI and Sovereignty

 

Recognizing the seismic shifts in the global AI landscape, particularly the explosion of generative AI, the Turkish government demonstrated policy agility by updating its strategy. In July 2024, the DTO released the “Artificial Intelligence 2024-2025 Action Plan,” a revised roadmap designed to align with the 12th Development Plan and address the dynamic needs of the country.10 This update signaled a strategic pivot from the broad-based approach of the original NAIS to a more focused and technologically current set of priorities.

The 2024-2025 Action Plan sharpens the national focus onto several high-impact areas that reflect contemporary geopolitical and technological imperatives 11:

  • Productive AI Technologies: A pragmatic emphasis on using AI to enhance resource efficiency and productivity across the economy.
  • Turkish Large Language Models (LLMs): The most significant new priority is the development of major Turkish LLMs.11 This represents a clear move toward establishing digital and technological sovereignty, aiming to reduce dependency on foreign models and create value-added AI products that are culturally and linguistically tailored to the Turkish context.
  • Reinforced Ecosystem Pillars: The plan continues to prioritize the foundational areas of R&D, innovation, and workforce transformation, reinforcing the original strategy’s core objectives.

The updated plan translates these priorities into 71 specific actions, moving from abstract goals to concrete initiatives.13 Key actions include the establishment of the “Türkiye AI Portal” under the management of the Scientific and Technological Research Council of Turkey (TÜBİTAK) to serve as a centralized ecosystem hub.10 It also mandates the creation of a “Central Public Data Space” to facilitate secure access to anonymized public datasets for researchers and developers, addressing a critical bottleneck in AI development.3 Furthermore, the plan calls for the development of policies to counter AI-enhanced cybersecurity threats and the issuance of national regulations aligned with international norms, directly setting the stage for the subsequent Draft AI Law.10

 

1.3. The Governance Architecture: Mapping the Institutional Landscape

 

The implementation of Türkiye’s AI strategy is managed through a multi-tiered and highly centralized governance structure, with ultimate authority resting within the Presidency. The DTO, established in 2018 to spearhead the nation’s digital transformation, and the MoIT serve as the chief architects and overseers of the national AI policy.3

To coordinate the complex web of stakeholders, a formal governance mechanism was established 1:

  • National AI Strategy Steering Committee: This body, co-chaired by the Head of the DTO and the Deputy Minister of MoIT, convenes quarterly to guide policy development and monitor implementation.
  • High-Level Steering Board (“Yönlendirme Kurulu”): For top-level strategic coordination, a board chaired by the Vice President of the Republic of Turkey oversees the entire strategy, underscoring the high political priority assigned to AI.4
  • Stakeholder Engagement Bodies: An AI Ecosystem Advisory Group and various Action Plan Coordination Groups were created to formally incorporate input from the private sector, academia, and non-governmental organizations, although the core decision-making power remains with the state-led committees.

Several key institutions are tasked with the practical implementation of the strategy. TÜBİTAK stands out as the central R&D and execution agency. Its BİLGEM AI Institute (YZE) is positioned as a catalyst for the entire ecosystem, tasked with managing the Türkiye AI Portal and administering crucial support programs for industry-specific AI solutions in priority sectors like smart manufacturing, finance, and agriculture.4 More recently, the

Ministry of Justice announced the formation of its own “AI Science Commission,” signaling a deepening focus on the legal and judicial ramifications of AI and the need to build a robust legal infrastructure.21

The evolution from the 2021 strategy to the 2024 action plan demonstrates a clear maturation in Türkiye’s policy approach. The initial strategy was a necessary, broad-based declaration of intent. The updated plan, with its specific focus on Turkish LLMs and cybersecurity, is a more pragmatic and targeted response to the current global technological environment. It reflects a shift from a general desire to participate in the AI revolution to a specific strategy for securing national interests within it. This is further supported by the top-down governance model, where a structure heavily centralized within the Presidency is designed for decisive action and the alignment of state resources. While this can facilitate rapid policy formulation, it also carries the risk of insufficient stakeholder feedback and challenges in translating high-level directives into coordinated action across a diverse and fragmented ecosystem.

 

2. Building the Legal Guardrails: A New Regulatory Frontier

 

As Türkiye operationalizes its AI strategy, it is simultaneously erecting a new legal framework to govern the technology’s development and deployment. This nascent regulatory regime is defined by a landmark legislative proposal, a proactive data protection authority, and a clear strategic orientation toward the European Union. However, this alignment with international standards is coupled with significant domestic ambiguities, creating a complex and evolving legal landscape for all stakeholders.

 

2.1. The Draft AI Law (June 2024): A Deep Dive into Türkiye’s First AI Legislation

 

A pivotal moment in Turkish AI governance arrived on June 24, 2024, with the submission of the country’s first comprehensive Draft AI Law to the Grand National Assembly.5 The bill, which is currently under review in the parliamentary committee stage, aims to establish a definitive regulatory framework for all AI-related activities in the country.24

The proposed law’s scope is intentionally broad, applying to the entire AI value chain, including providers, users, importers, and distributors of AI systems, as well as the individuals and entities affected by their operation.25 At its core, the draft codifies five fundamental principles intended to serve as the ethical foundation for AI in Türkiye, mirroring established international guidelines 22:

  1. Safety: AI systems must operate safely and not cause harm.
  2. Transparency: The operational logic of AI systems must be clear and understandable.
  3. Fairness: Systems must not engage in or perpetuate discrimination.
  4. Accountability: The parties responsible for the outcomes of AI systems must be clearly identifiable and answerable.
  5. Privacy: The development and use of AI must adhere to principles of personal data protection and privacy.

A central feature of the draft is its adoption of a risk-based approach to regulation. This framework requires that risk assessments be conducted for all AI systems, while mandating special, more stringent measures for those classified as “high-risk.” These measures include compulsory registration with authorities and formal conformity assessments to ensure they meet safety and ethical standards before being deployed.22 To give these provisions teeth, the draft introduces a tiered system of significant administrative fines for non-compliance, with penalties escalating based on the severity of the violation.22 This signals a clear intent to establish a robust enforcement regime.

 

2.2. A Comparative Analysis: The Turkish Draft Law vs. The EU AI Act

 

Türkiye’s decision to model its Draft AI Law closely on the EU AI Act is a strategic one, reflecting a broader geopolitical and economic orientation toward Europe.22 This alignment aims to create a harmonized regulatory environment, which is crucial for attracting foreign direct investment and ensuring that Turkish technology companies can operate seamlessly within the vast EU market.27 Both legal frameworks are built upon the same foundational pillars: a risk-based approach and a shared set of core ethical principles.22

However, a detailed comparative analysis reveals that the Turkish draft, in its current form, is significantly less detailed than its European counterpart, containing critical ambiguities that leave key aspects of the regulatory regime undefined.22

  • Definition of “High-Risk”: The most significant divergence is the Turkish draft’s failure to specify which categories of AI systems are to be considered “high-risk.” The EU AI Act provides an explicit, annexed list of high-risk use cases (e.g., in critical infrastructure, law enforcement, employment). The Turkish law defers this crucial classification, which will likely be detailed later in secondary legislation.25
  • Designation of a Supervisory Authority: The draft law empowers a “supervisory authority” to conduct inspections and enforce compliance but fails to name the specific institution that will hold this power.22 This creates uncertainty for businesses regarding who they will be accountable to.
  • Scope and Definitions: The definitions in the Turkish draft are less precise. For instance, while the EU AI Act explicitly excludes personal, non-professional activities from its scope, the Turkish draft’s language is ambiguous on this point, potentially broadening its reach unintentionally.22

This approach creates a duality in the legislative framework. On one hand, by mirroring the EU Act’s structure, Türkiye presents a familiar and predictable regulatory face to international businesses. On the other, the deliberate vagueness on critical definitions and enforcement bodies provides the Turkish state with significant flexibility to shape the domestic application of the law, potentially in ways that prioritize national security or administrative discretion over other considerations.

Feature EU AI Act Provision Turkish Draft AI Law Provision Analysis & Implications
Risk Classification Provides a detailed, four-tiered risk classification (Unacceptable, High, Limited, Minimal) with an explicit list of high-risk systems in an annex. Adopts a risk-based approach but does not define or list “high-risk” systems. States special measures are required for them. The Turkish draft’s ambiguity creates significant uncertainty for developers and users. The final definition of “high-risk” will be the most critical element determining the law’s practical impact.
Supervisory Authority Designates national supervisory authorities in each member state and establishes the European AI Board for coordination. Authorizes a “supervisory authority” to conduct inspections and enforce sanctions but does not specify which institution this will be. Lack of a designated authority creates a major gap in the governance framework. Businesses cannot know who will oversee compliance or how enforcement will be managed.
Scope of Application Explicitly excludes AI systems used for purely personal, non-professional activities. The definition of “supplier/user” is broad and does not explicitly exclude personal use, creating potential ambiguity. The Turkish law could be interpreted more broadly than the EU Act, potentially affecting non-commercial actors unless clarified.
Sanctions Establishes fines up to €35 million or 7% of global annual turnover for the most severe violations. Establishes fines up to TRY 35 million or 7% of global annual turnover for prohibited applications. The penalty structures are conceptually similar, indicating a strong enforcement posture. The Turkish fines are substantial and designed to deter non-compliance.

 

2.3. Data as the Bedrock: The Enduring Role of the KVKK in the AI Era

 

Until the Draft AI Law is enacted, the primary legal instrument governing AI in Türkiye has been the Law on Protection of Personal Data No. 6698 (KVKK).22 Any AI system that processes the personal data of individuals in Türkiye falls under its jurisdiction. The regulatory body, the Turkish Personal Data Protection Authority (also known as the KVKK), has been notably proactive in addressing the challenges posed by AI, issuing a series of influential, albeit non-binding, guidelines that have effectively set the compliance standard in the market.30

Key publications from the KVKK include:

  • Recommendations on AI (2021): This foundational document urged developers and users of AI to uphold fundamental rights, minimize data interference, and ensure transparency and accountability in their systems.31
  • Guidelines on AI Chatbots (2024): Responding to the rise of generative AI, these guidelines specifically address the risks of large language models, recommending that organizations conduct comprehensive risk assessments and integrate privacy-by-design principles.32
  • Guidelines on Genetic Data: The KVKK has classified genetic data as “sensitive personal data,” subjecting its use in AI systems to the strictest processing rules under the law.33

This proactive stance means that a robust, privacy-focused regulatory regime for AI is already in effect, with the KVKK acting as the de facto AI regulator. Furthermore, Türkiye has been actively working to harmonize the KVKK with the EU’s General Data Protection Regulation (GDPR), particularly on complex issues like cross-border data flows, to bolster investor confidence and facilitate digital trade.5

 

2.4. Uncharted Legal Waters: Intellectual Property, Algorithmic Accountability, and Liability

 

Beyond data protection, AI raises a host of novel legal questions that Türkiye’s existing frameworks are not yet equipped to answer. The 2024-2025 Action Plan acknowledges these gaps and explicitly calls for the development of new guidelines and regulations.13

  • Intellectual Property: Current Turkish copyright and patent laws do not recognize AI as a legal “author” or “inventor,” as these roles are generally understood to require a human creator.14 This creates ambiguity around the ownership of AI-generated content. More pressingly, the practice of using vast amounts of copyrighted material to train generative AI models could be deemed a violation of existing copyright law, a risk that the Action Plan aims to clarify.14
  • Algorithmic Accountability: Addressing the “black box” problem, where the decision-making processes of complex AI models are opaque, is a key priority. The Action Plan mandates the preparation of supervision guidelines on “Algorithmic Accountability” and the creation of mechanisms for technical audits of AI systems.13
  • Bias and Discrimination: While Türkiye has a general anti-discrimination law (Law No. 6701), it lacks provisions specifically tailored to the unique ways AI systems can perpetuate or amplify bias.14 The National AI Strategy acknowledges this risk, but a concrete legal mechanism to address algorithmic discrimination has yet to be established.

 

Violation Type Administrative Fine (in TRY) Administrative Fine (as % of Global Annual Turnover)
Prohibited AI Applications TRY 35,000,000 up to 7%
Breach of Obligations TRY 15,000,000 up to 3%
Providing False Information TRY 7,500,000 up to 1.5%
Data compiled from sources.22

 

3. The Turkish AI Ecosystem: Implementation, Innovation, and Impact

 

Beyond strategy documents and legal drafts, the success of Türkiye’s AI ambitions hinges on the development of a vibrant and capable domestic ecosystem. The government’s top-down approach has focused on cultivating human capital, stimulating innovation through targeted support, and driving adoption through public sector leadership. This has been complemented by the foundational research and talent development occurring within the country’s leading universities, creating the nascent yet interconnected components of a functional national AI ecosystem.

 

3.1. Cultivating Human Capital: Progress on Education and Employment Goals

 

A core pillar of the National AI Strategy is the creation of a skilled workforce capable of developing and deploying AI technologies. To this end, the government has launched a multi-pronged effort targeting every level of the education system. The 2024-2025 Action Plan includes specific measures such as developing AI teaching programs and digital content for vocational and technical high schools (Eylem 1.14) and providing in-service AI training to build the capacity of existing teachers (Eylem 1.15).17 The Ministry of Industry and Technology has also established specialized training programs in high-demand fields like AI, autonomous driving, and chip design to create a pool of qualified human resources.34

At the higher education level, the DTO’s “Digital Youth Artificial Intelligence Ecosystem” initiative aims to foster a community of practice by connecting university AI clubs and supporting hands-on, practice-based training and competitions.19 These efforts are yielding tangible results. A progress report from early 2024 on the initial 2021 strategy indicated that 3,494 graduate-level degrees in AI had been awarded, 648 doctoral theses were completed, and the number of academics working in the field had risen to 3,562.20 Furthermore, 47 new workforce training and higher education programs directly related to AI have been established, demonstrating a rapid expansion of educational capacity.15

 

3.2. Fostering Innovation: The Startup, R&D, and Investment Landscape

 

The government is actively working to create a fertile ground for AI innovation and entrepreneurship. The national strategy prioritizes the activation of AI-oriented venture capital (VC) funds and the improvement of public incentives for AI startups.3 A key policy is the prioritization of locally developed AI solutions in public procurement, which aims to create a stable domestic market for Turkish companies.1

TÜBİTAK is the primary vehicle for channeling state support to the R&D ecosystem. Through initiatives like the “Artificial Intelligence Ecosystem Call” and the TEYDEB support program, it provides funding for collaborative, industry-led R&D projects in strategic areas such as smart manufacturing, intelligent agriculture, and financial technologies.4 This is complemented by support programs from KOSGEB, the small and medium enterprise development organization, which encourage SMEs to adopt AI solutions developed through domestic R&D.17

This support has helped nurture a growing startup scene, with Istanbul emerging as a significant regional hub.35 While estimates of the total number of AI startups vary, from around 80 to over 600, the ecosystem has produced notable successes, including the marketing technology firm Insider, which achieved “unicorn” status with a valuation over $1 billion.4 Other promising startups are active in diverse fields, such as Syntonym (privacy-enhancing technology), Vispera (computer vision for retail), and Finedine (AI for the hospitality industry).35 To fuel further growth, the “Türkiye International Direct Investment Strategy (2024-2028)” explicitly targets foreign investment in high-tech sectors, including AI, semiconductors, and data centers, with plans to enhance incentive mechanisms and develop innovative financing models to attract global capital.10

 

3.3. AI in the Public Sector: Flagship Projects and Early Outcomes

 

In line with the national strategy, public institutions are mandated to act as pioneers in AI adoption, leveraging the technology to enhance the efficiency and quality of citizen services.11 The DTO has taken the lead in developing several high-profile flagship projects, particularly in the healthcare sector, which serve as powerful showcases for the potential of “AI for good”.20

  • Sayısal Göz-Mamografi (Digital Eye-Mammography): This project involves an AI-powered decision support system designed to assist radiologists in the early detection of breast cancer. The AI models have been successfully integrated into the Ministry of Health’s national cancer screening and reporting system, helping to prioritize cases with potentially malignant masses for faster review by specialists.20
  • Sayısal Göz-Karaciğer (Digital Eye-Liver): This initiative uses AI to model the liver’s anatomy from scans and integrates this with a virtual reality (VR) environment. This allows surgeons to better plan complex liver transplant operations, improving the efficiency and safety of the procedure.20

Beyond these flagship projects, AI is being deployed across a range of government functions.15 The Ministry of Finance is utilizing AI algorithms to analyze corporate financial data to crack down on tax evasion. In agriculture, AI is being used to process satellite imagery to identify different crop types and monitor land use.20 However, the most extensive public sector application of AI appears to be in the domain of security. The Interior Ministry is undertaking a massive expansion of its nationwide City Security Management System (KGYS), integrating thousands of new cameras with AI-powered facial recognition capabilities.37

 

3.4. The Academic Engine: Contributions from Türkiye’s Leading Universities

 

The foundation of Türkiye’s AI ecosystem rests on the advanced research and talent development conducted at its top-tier universities. These institutions have established dedicated centers and laboratories that are pushing the frontiers of AI science and producing the next generation of experts.

  • Boğaziçi University: A leading institution, it hosts the Institute for Data Science & Artificial Intelligence, which offers specialized MSc and PhD programs.38 Its research labs, such as the Cognitive and Learning Systems Lab (CoLoRs) and the Artificial Learning Lab (ALLab), are engaged in cutting-edge projects on cognitive robotics, neurosymbolic AI, lifelong learning, and adversarial machine learning.39
  • Koç University: The Koç University İş Bankası Artificial Intelligence Research Center (KUIS AI) is another major hub, with a strong focus on computer vision, natural language processing (NLP), robotics, and computational medicine.41 A significant contribution from KUIS AI is the development of “Cetvel,” a comprehensive benchmark specifically designed to evaluate the performance of large language models on the Turkish language, a crucial tool for advancing sovereign AI capabilities.41
  • Middle East Technical University (METU): METU boasts a wide array of AI-focused research groups, including the Applied NLP Group, the Intelligent Systems Laboratory (ISL), and the dedicated Robotics and AI Technologies Application and Research Center (ROMER).42 Their research portfolio includes work on Turkish LLM benchmarks, social media analysis for hate speech detection, and advanced robotics.44
  • Sabancı University: The university’s Faculty of Engineering and Natural Sciences has prominent research groups in AI, Machine Learning, and Cognitive Robotics. Their work spans both fundamental and applied research, with projects in medical image analysis, biometrics, smart agriculture, and the mathematical foundations of knowledge representation.45

The synergy between these elements—a government-driven strategy, targeted support for innovation, pioneering public sector projects, and a strong academic base—indicates the formation of a functional, albeit still nascent, national AI ecosystem. The high-quality research from elite universities is creating a vital pipeline of talent and new ideas. The government’s strategic investments and public procurement policies are, in turn, creating demand for this talent and providing pathways for commercialization, fostering a positive feedback loop that is essential for sustainable growth. However, the dual nature of public sector adoption, which champions beneficial applications in areas like healthcare while simultaneously pursuing a massive expansion of state surveillance, presents a complex and challenging dynamic at the heart of this emerging ecosystem.

 

4.  A Critical Assessment: Challenges, Contradictions, and the Path Forward

 

While Türkiye’s strategic ambitions for AI are clear and its ecosystem shows signs of dynamism, a critical assessment reveals a significant gap between policy and reality. The country’s performance on global benchmarks lags behind its goals, and its governance model faces internal critiques of fragmentation. More profoundly, the official narrative of “responsible AI” is increasingly at odds with the state’s use of the technology for surveillance, creating a central contradiction that challenges the very foundation of its governance framework.

 

4.1. The Strategy-Execution Gap: Coordination, Competitiveness, and Global Benchmarks

 

Despite the government’s ambitious goal of ranking among the top 20 AI nations by 2025, external assessments paint a more sobering picture. The Oxford Insights 2024 AI Readiness Index placed Türkiye 53rd out of 188 countries.47 This ranking, which evaluates countries not just on investment but on crucial dimensions like education systems, public sector strategy, and digital governance capacity, positions Türkiye just above war-torn Ukraine and suggests a substantial disconnect between its strategic vision and its on-the-ground capabilities.47

This performance gap has fueled criticism from within the political system. Evrim Rızvanoğlu, a Member of Parliament from the DEVA Party, has pointed to a lack of centralized coordination as a primary cause, stating that key institutions like the DTO and the MoIT operate independently and that a persistent disconnect exists between academic research and private sector application.47 This critique directly challenges the official portrayal of a seamlessly coordinated, multi-stakeholder governance structure and suggests that the high-level steering committees may not be effectively translating strategy into unified action. The persistent coordination problems have led industry analysts and policymakers to call for the establishment of a single, empowered “Central Artificial Intelligence Agency” to align strategy, coordinate stakeholders, and drive global competitiveness more effectively.47

 

Strategic Objective 2025 Target Latest Reported Status (as of 2024) Source(s) Analysis/Gap
AI Contribution to GDP Increase to 5% No specific progress figure reported. 1 This is the most ambitious and hardest-to-measure target. The lack of interim reporting suggests that tracking and achieving this goal is a significant challenge.
AI-related Employment 50,000 people No comprehensive figure reported. 1,000 targeted for public sector. 1 While educational outputs are tracked, a clear picture of total AI employment is missing, making it difficult to assess progress toward this key goal.
Graduate-level Graduates 10,000 people 3,494 graduate-level degrees awarded. 1 Significant progress has been made, indicating the success of higher education initiatives. However, the target still requires a substantial increase in graduation rates.
International AI Index Ranking Top 20 Ranked 53rd in the Oxford Insights 2024 AI Readiness Index. 1 This represents the most significant and concerning gap. The low ranking suggests systemic weaknesses in governance, data infrastructure, and human capital that the strategy has yet to overcome.

 

4.2. The Digital Rights Dilemma: Balancing National Security with Individual Freedoms

 

The most profound challenge to Türkiye’s AI governance framework lies in the deep contradiction between its stated commitment to ethical principles and its practical application of AI for state security and surveillance. While the national strategy and draft law are replete with references to “human-centric,” “responsible,” and “trustworthy” AI, a parallel and arguably more vigorous effort is underway to build one of the region’s most sophisticated AI-powered surveillance systems.8

Publicly available procurement documents and ministerial statements reveal a massive, ongoing expansion of the City Security Management System (KGYS). This includes the purchase of thousands of AI-powered facial recognition cameras for deployment in at least 30 provinces.37 The stated goal of the Interior Minister is to leave no street in Istanbul without camera coverage and to equip every police officer with body cameras featuring facial recognition technology by the end of 2025.37

This rapid expansion is occurring in a legal vacuum. While the Turkish Constitution provides general protections for privacy, and the KVKK law governs personal data, there are no specific, binding laws that regulate the use of high-risk AI technologies like facial recognition in policing.37 Existing data protection laws contain broad, ill-defined exceptions for “national security” and “crime prevention,” which human rights experts argue create legal loopholes that can be exploited for mass surveillance.37

This situation has drawn sharp criticism from domestic and international civil society organizations. Digital rights groups like Turkey Blocks, along with organizations such as Human Rights Watch and AlgorithmWatch, have long documented a pattern of widespread internet censorship, content blocking, and government pressure on social media platforms in Türkiye.48 They warn that the deployment of AI-powered surveillance will have a chilling effect on fundamental rights, particularly the freedoms of expression and assembly, by making it easier for the state to monitor and identify protesters and critics.37 This creates a stark dichotomy where the benign, publicly promoted applications of AI in healthcare serve as a legitimizing facade for the development of technologies that can be used for social control.

 

4.3. International Positioning: Navigating Global AI Diplomacy and Economic Ambitions

 

On the international stage, Türkiye is actively pursuing a strategy of engagement and strategic balancing. It became a member of the Global Partnership on Artificial Intelligence (GPAI) in 2022 and is an active participant in the OECD’s AI policy working groups.19 This engagement is a core component of its “AI Diplomacy,” which aims to promote the responsible and ethical use of AI globally while protecting the data of its citizens.52

This diplomatic outreach is part of a broader effort to navigate a multipolar AI world. Turkish policy analysis suggests an attempt to find a “third way” between the market-driven, innovation-focused model of the United States, the state-controlled model of China, and the rights-focused, regulatory model of the European Union.53 Türkiye’s approach seeks to balance these imperatives: fostering a dynamic domestic innovation ecosystem without adopting overly permissive policies that could create security risks, while also aligning with international ethical norms without imposing excessive regulation that could stifle growth.53

This balancing act is intrinsically linked to its economic ambitions. The national strategy’s emphasis on creating new “unicorns” and the international investment strategy’s focus on attracting foreign capital to the digital sector are central to the country’s economic vision.4 In this context, harmonizing its legal framework with the EU AI Act is not just a matter of principle but a crucial act of economic diplomacy designed to reassure investors and secure market access.

 

5. Strategic Recommendations and Outlook

 

Türkiye stands at a critical juncture in its AI journey. The foundational strategies have been laid, the legislative process has begun, and the ecosystem is showing clear signs of life. However, to bridge the significant gap between ambition and reality, and to navigate the deep-seated contradictions within its own approach, a series of concerted actions are required from all key stakeholders. The country’s future trajectory will be determined by its ability to address these challenges head-on.

 

5.1. For Policymakers: Enhancing Legislative Clarity and Institutional Cohesion

 

  • Finalize and Clarify the AI Law: The highest priority for the Turkish Grand National Assembly and the government should be to expedite the legislative process for the Draft AI Law while addressing its current ambiguities. Providing a clear, legally binding definition of “high-risk” AI systems, modeled on the EU AI Act’s annexes, is essential for providing legal certainty to developers and users. Similarly, the law must designate a single, empowered, and sufficiently independent supervisory authority responsible for its enforcement.
  • Resolve Institutional Fragmentation: The critiques regarding a lack of coordination between key government bodies must be addressed.47 The government should either empower the National AI Strategy Steering Committee with a stronger mandate and the resources to enforce cross-governmental collaboration or heed the calls from experts to establish a truly centralized AI agency. This body would be responsible for aligning all state efforts, from R&D funding to public procurement and regulatory oversight.
  • Enact Binding Safeguards for AI in Law Enforcement: To build public trust and align practice with the stated ethical principles of the national strategy, specific and binding legal safeguards governing the use of AI by law enforcement and in public administration are urgently needed. This should include strict rules for the use of facial recognition and other biometric surveillance technologies, requiring judicial oversight and ensuring that their application is necessary and proportionate, in line with constitutional protections.

 

5.2. For Businesses and Investors: Navigating Regulatory Risk and Opportunity

 

  • Prioritize KVKK Compliance: In the current regulatory environment, the guidelines issued by the Turkish Personal Data Protection Authority (KVKK) serve as the de facto standard for any AI application involving personal data. Businesses should prioritize full compliance with the KVKK’s recommendations on AI, chatbots, and sensitive data, proactively adopting privacy-by-design and privacy-by-default principles in their product development cycles.30
  • Prepare for EU-Aligned Regulation: Businesses should closely monitor the progress of the Draft AI Law and anticipate a final compliance framework that will largely mirror the requirements of the EU AI Act. This includes preparing for obligations related to risk management systems, data governance, transparency, and technical documentation, particularly for any systems that could be classified as high-risk.
  • Engage Strategically with the Ecosystem: The government has created numerous support mechanisms for R&D and innovation through bodies like TÜBİTAK and KOSGEB.4 Businesses, both domestic and international, should actively explore these opportunities and forge partnerships with Türkiye’s leading academic institutions to access top talent and cutting-edge research. However, this engagement must be paired with rigorous due diligence concerning the evolving digital rights landscape and the potential dual-use applications of certain technologies.

 

5.3. Concluding Outlook: Projecting Türkiye’s Trajectory in the Global AI Race

 

Türkiye is well-positioned to emerge as a significant regional power in artificial intelligence. It possesses the key ingredients for success: strong political will, a solid academic research base, a dynamic and youthful population, and a growing startup culture. The strategic framework is in place, and the legislative machinery is in motion.

However, the path to becoming a global leader, or even to achieving its own ambitious 2025 targets, is fraught with substantial challenges. The primary obstacle is not a lack of vision but a deficit in execution, coordination, and, most importantly, trust. The persistent gap between strategic goals and performance on global benchmarks points to systemic issues in governance that must be resolved.

Ultimately, Türkiye’s AI trajectory will be defined by its ability to reconcile the central contradiction at the heart of its governance model. It cannot long sustain a dual path of pursuing an open, innovative, and EU-aligned economic model for international audiences while simultaneously building a closed, state-controlled surveillance apparatus for domestic purposes. A truly “agile and sustainable AI ecosystem” requires more than just technology and capital; it requires an environment built on the rule of law, institutional transparency, and the protection of fundamental freedoms. Without a genuine commitment to these principles, Türkiye risks creating a technologically advanced but brittle system that will fall short of its own vision for a prosperous and globally competitive future.

References

  1. Turkey’s National Artificial Intelligence Strategy has been Published …, accessed July 31, 2025, https://www.morogluarseven.com/news-and-publications/turkeys-national-artificial-intelligence-strategy-has-been-published/
  2. TURKEY’S NATIONAL ARTIFICIAL INTELLIGENCE STRATEGY WHAT TO EXPECT NEXT? – SETA, accessed July 31, 2025, https://www.setav.org/en/assets/uploads/2021/08/P66-AI.pdf
  3. The Turkey National Artificial Intelligence Strategy (2021-2025) | Digital Watch Observatory, accessed July 31, 2025, https://dig.watch/resource/the-national-artificial-intelligence-strategy-2021-2025
  4. İŞTE TÜRKİYE’NİN YAPAY ZEKA STRATEJİSİ Tarih – Haber | T.C. Sanayi ve Teknoloji Bakanlığı, accessed July 31, 2025, https://www.sanayi.gov.tr/medya/haber/iste-turkiyenin-yapay-zeka-stratejisi
  5. Türkiye – Digital Economy – International Trade Administration, accessed July 31, 2025, https://www.trade.gov/country-commercial-guides/turkiye-digital-economy
  6. Ulusal Yapay Zeka Stratejisi yürürlükte – YASED | Uluslararası Yatırımcılar Derneği, accessed July 31, 2025, https://www.yased.org.tr/haberler/Ulusal-Yapay-Zeka-Stratejisi-Yururlukte
  7. Ulusal Yapay Zekâ Stratejisi 2024-2025 Eylem Planı ve Güncel Gelişmeler – KECO, accessed July 31, 2025, https://www.kecolegal.com/post/ulusal-yapay-zeka-stratejisi-2024-2025-eylem-plani-ve-guncel-gelismeler
  8. Turkey, accessed July 31, 2025, https://s899a9742c3d83292.jimcontent.com/download/version/1659371362/module/8292103163/name/AISCI-2020a-Turkey.pdf
  9. Hanife Gülin DİZER, Expert, Digital Transformation Office (DTO) of the Presidency of Turkey, accessed July 31, 2025, https://govinsider.asia/intl-en/article/hanife-gulin-di%CC%87zer-expert-digital-transformation-office-dto-of-the-presidency-of-turkey
  10. Recent Developments in Artificial Intelligence – Moroğlu Arseven, accessed July 31, 2025, https://www.morogluarseven.com/news-and-publications/recent-developments-in-ai/
  11. Turkey: Presidency Digital Transformation Office publishes updated national AI strategy 2024-2025 action plan | News | DataGuidance, accessed July 31, 2025, https://www.dataguidance.com/news/turkey-presidency-digital-transformation-office
  12. National Artificial Intelligence Strategy 2024-2025 Action Plan Published – Duyurular, accessed July 31, 2025, https://www.zumbul.av.tr/tr/duyurular/a-a
  13. 2024-2025 Action Plan on Artificial Intelligence Strategy Published, accessed July 31, 2025, https://www.esin.av.tr/2024/07/30/2024-2025-action-plan-on-artificial-intelligence-strategy-published/
  14. AI, Machine Learning & Big Data Laws 2025 | Turkey – Global Legal Insights, accessed July 31, 2025, https://www.globallegalinsights.com/practice-areas/ai-machine-learning-and-big-data-laws-and-regulations/turkey/
  15. As use matures, Türkiye moves to the next stage of its AI journey – GovInsider, accessed July 31, 2025, https://govinsider.asia/intl-en/article/as-use-matures-turkiye-moves-to-the-next-stage-of-its-ai-journey
  16. Ministry funds sector-specific projects to advance Turkish AI models | Daily Sabah, accessed July 31, 2025, https://www.dailysabah.com/turkiye/ministry-funds-sector-specific-projects-to-advance-turkish-ai-models/news
  17. 1/14 ULUSAL YAPAY ZEKÂ STRATEJİSİ 2024-2025 EYLEM PLANI …, accessed July 31, 2025, https://www.sanayi.gov.tr/assets/pdf/UlusalYapayZekaStratejisi2024-2025EylemPlani.pdf
  18. Yapay Zeka Stratejisine İlişkin 2024-2025 Eylem Planı Yayımlandı, accessed July 31, 2025, https://www.esin.av.tr/tr/2024/07/30/yapay-zeka-stratejisine-iliskin-2024-2025-eylem-plani-yayimlandi/
  19. AI REGULATIONS IN TURKEY – JustAI, accessed July 31, 2025, https://justai.in/ai-regulations-in-turkey/
  20. Ulusal Yapay Zeka Stratejisi adım adım hedeflerine ulaşıyor – Anadolu Ajansı, accessed July 31, 2025, https://www.aa.com.tr/tr/dosya-haber/ulusal-yapay-zeka-stratejisi-adim-adim-hedeflerine-ulasiyor/3197270
  21. “44 Years of Data Protection: The Age of AI from a Privacy Perspective” Conference Held, accessed July 31, 2025, https://www.kvkk.gov.tr/Icerik/8179/-44-Years-of-Data-Protection-The-Age-of-AI-from-a-Privacy-Perspective-Conference-Held
  22. The Regulatory Landscape of artificial intelligence: What lies ahead, accessed July 31, 2025, https://www.odsavukatlik.com/fr/news-insights/the-regulatory-landscape-of-artificial-intelligence-what-lies-ahead/
  23. Turkey Introduces Comprehensive AI Regulation Bill Aligned with EU Standards – BABL AI, accessed July 31, 2025, https://babl.ai/turkey-introduces-comprehensive-ai-regulation-bill-aligned-with-eu-standards/
  24. Turkey: AI bill submitted to Parliamentary Committee | News – DataGuidance, accessed July 31, 2025, https://www.dataguidance.com/news/turkey-ai-bill-submitted-parliamentary-committee
  25. New Turkish AI Law on the horizon, accessed July 31, 2025, https://cms-lawnow.com/en/ealerts/2024/07/new-turkish-ai-law-on-the-horizon
  26. www.mofo.com, accessed July 31, 2025, https://www.mofo.com/artificial-intelligence/turkey#:~:text=The%20proposed%20law%20would%20establish,individuals%20affected%20by%20these%20systems.
  27. Türki̇ye’s Digital Transformation Strategy for 2024-2028 in the Context of Foreign Direct Investment | GenTemizer, accessed July 31, 2025, https://www.gentemizer.com/insight/turki%CC%87yes-digital-transformation-strategy-for-2024-2028-in-the-context-of-foreign-direct-investment/
  28. Legislative Developments for Artificial Intelligence in Turkiye | Gün + Partners, accessed July 31, 2025, https://gun.av.tr/insights/updates/legislative-developments-for-artificial-intelligence-in-turkiye
  29. Initial Legislative Developments for Artificial Intelligence in Turkiye | International Network of Privacy Law Professionals – inplp, accessed July 31, 2025, https://inplp.com/latest-news/article/initial-legislative-developments-for-artificial-intelligence-in-turkiye/
  30. AI Watch: Global regulatory tracker – Turkey | White & Case LLP – JDSupra, accessed July 31, 2025, https://www.jdsupra.com/legalnews/ai-watch-global-regulatory-tracker-9711736/
  31. Turkey: KVKK recommendations on AI | Opinion | DataGuidance, accessed July 31, 2025, https://www.dataguidance.com/opinion/turkey-kvkk-recommendations-ai
  32. Turkey Addresses Data Privacy Risks in AI Chatbots – BABL AI, accessed July 31, 2025, https://babl.ai/turkey-addresses-data-privacy-risks-in-ai-chatbots/
  33. Turkey’s KVKK creates draft guidelines for handling genetic data – IAPP, accessed July 31, 2025, https://iapp.org/news/b/turkeys-kvkk-creates-draft-guidelines-for-handling-genetic-data
  34. Republic of Turkey Ministry of Industry and Technology National Directorate General of Technology Training Program Annou, accessed July 31, 2025, https://sbf.erciyes.edu.tr/en/announcement-detail/republic-of-turkey-ministry-of-industry-and-technology-national-directorate-general-of-technology-training-program-announcement
  35. 18 Best Ai Startups in Istanbul to Watch in 2025 – Seedtable, accessed July 31, 2025, https://www.seedtable.com/best-ai-startups-in-istanbul
  36. Top Artificial Intelligence Companies in Turkey (Jul, 2025) – Tracxn, accessed July 31, 2025, https://tracxn.com/d/artificial-intelligence/ai-startups-in-turkey/__7WpCwjDhpue5gsOtxueW9X5UPkXPihMC5fk_ZRyExzo/companies
  37. Turkey’s AI-Powered Protest Crackdown – New Lines Magazine, accessed July 31, 2025, https://newlinesmag.com/spotlight/turkeys-ai-powered-protest-crackdown/
  38. Institute for Data Science & Artificial Intelligence, accessed July 31, 2025, https://bogazici.edu.tr/en/pages/institute-for-data-science-artificial-intell/575
  39. Artificial Learning Lab – GitHub, accessed July 31, 2025, https://github.com/ALLab-Boun
  40. COLORS Lab | Cognitive Learning and Robotics, accessed July 31, 2025, https://colors.cmpe.boun.edu.tr/
  41. Kuis AI | Koç University, accessed July 31, 2025, https://ai.ku.edu.tr/
  42. Research | Department of Computer Engineering – METU/CEng, accessed July 31, 2025, https://ceng.metu.edu.tr/research
  43. Home | Your Site, accessed July 31, 2025, https://romer.metu.edu.tr/
  44. Research & Projects – Applied Natural Language Processing Group | METU, accessed July 31, 2025, https://nlp.ceng.metu.edu.tr/research.html
  45. Research Areas | Faculty of Engineering and Natural Sciences, accessed July 31, 2025, https://fens.sabanciuniv.edu/en/research-areas
  46. Artificial Intelligence, Machine Learning | Computer Science …, accessed July 31, 2025, https://cs.sabanciuniv.edu/en/research/research-areas/artificial-intelligence-machine-learning
  47. Türkiye Ranks 53rd in Global AI Readiness, Trails Behind as Investments Surge Worldwide, accessed July 31, 2025, https://www.paturkey.com/news/2025/turkiye-ranks-53rd-in-global-ai-readiness-trails-behind-as-investments-surge-worldwide-20426/
  48. Turkish civil society: Declaration on the state of the internet – European Digital Rights (EDRi), accessed July 31, 2025, https://edri.org/our-work/turkish-civil-society-declaration-on-the-state-of-the-internet/
  49. Türkiye: Big Tech Should Protect Online Expression, Resist Censorship, accessed July 31, 2025, https://www.hrw.org/news/2024/03/04/turkiye-big-tech-should-protect-online-expression-resist-censorship
  50. Turkey Doubles Down on Violations of Digital Privacy and Free Expression, accessed July 31, 2025, https://www.eff.org/deeplinks/2020/11/turkey-doubles-down-violations-digital-privacy-and-free-expression
  51. Türkiye welcomes inclusion in global artificial intelligence group – Anadolu Ajansı, accessed July 31, 2025, https://www.aa.com.tr/en/science-technology/turkiye-welcomes-inclusion-in-global-artificial-intelligence-group/2746254
  52. Türkiye’s AI diplomacy: Protecting citizen data a primary goal – TRT Global, accessed July 31, 2025, https://www.trtworld.com/turkiye/turkiyes-ai-diplomacy-protecting-citizen-data-a-primary-goal-13270820
  53. Türkiye and EU: Quest for AI regulation and responsibility, Opinion Cenay Babaoğlu | SETA, accessed July 31, 2025, https://www.setav.org/en/opinion/turkiye-and-eu-quest-for-ai-regulation-and-responsibility