A new Regulation on Shipping Agencies (the “Regulation”) has been published in the Official Gazette dated 14 May 2026, replacing the previous regulation that has been in for since 2012 in its entirety. The Regulation significantly tightens operational criteria, introduces a classification and region-based licensing framework, enhanced financial and personnel requirements, and a formal disciplinary mechanism for the shipping agency sector.

Set out below is a summary of the key changes that may be of concern to our clients.

Classification of Shipping Agencies

The Regulation replaces the former single class authorisation model with a three-tier classification system based on the type of vessels to be serviced and the geographic area which the agency is authorised to operate. The new Regulation divides the Turkish territorial waters into four regions, which are essentially the Black Sea Region, Marmara Region, Aegean Region and the Mediterranean Region with the jurisdictional limits drawn per the below:

1st Region	From Hopa HM’s jurisdiction to Bartin HM’s jurisdiction (Black Sea Region)
2nd Region	From Zonguldak HM’s jurisdiction to Ayvalik HM’s jurisdiction (Marmara Region)
3rd Region	From Dikili HM’s jurisdiction to Fethiye HM’s jurisdiction (Aegean Region)
4th Region	From Kas HM’s jurisdiction to Iskenderun HM’s jurisdiction (Mediterranean Region)

Accordingly, the agency’s operating licenses will identify the geographical limits of their operations. Agents shall perform their geographical operations within the class of services they are authorized to perform.

Scope of Services:	Class A*	Class B	Class C
All Vessels within the designated region, incl. the Turkish Straits	✓	X	X
All Vessels within the designated region, excl. the Turkish Straits	✓	✓	X
All Yachts within the designated region, incl. the Turkish Straits	✓	✓	✓
All Yachts within the designated region, excl. the Turkish Straits	✓	✓	✓

Accordingly, shipping agencies are now required to provide services to vessels within the scope of services prescribed for each class under the Regulation. In addition to the above limitations, commercial vessels transiting the Turkish Straits without calling at a port (uğraksız geçiş) can now only be serviced by Class A agencies, regardless of the above regional boundaries. As it can be seen from the above, the new framework restricts non-Class A agencies from handling commercial vessels transiting or operating in the Turkish Straits.

Agencies are required to set up their offices within the region for which they apply for authorisation. Agencies operating outside their designated territorial zones and servicing vessels outside of their class’s permitted services will be deemed to be in regulatory violation.

Opening Branches: Agencies may open branches in order to perform services in other regions subject to obtaining the relevant authorisation for each branch. Also worth considering is that a branch office is not permitted to hold a higher classification than its headquarters (e.g., a Class B headquarters cannot open a Class A branch). Thus, the Regulation aims to prevent the circumvention of the restrictions to provide services in the Turkish straits. In this regard, if your agency’s headquarters is authorized as Class B or C, the agency will not be able to service the Turkish straits by simply opening a branch in Istanbul or Canakkale. To handle such transits for commercial vessels, the agency’s core corporate structure must be upgraded to Class A.

Appointing Sub-Agents: Under the Regulation, appointment of sub-agents (tali acente) is permitted, with the primary agent remaining fully legally liable. However, the primary agent may not appoint a sub-agent for services that it is not authorised to perform itself. Crucially, the primary agent is now legally mandated to pay the sub-agent at least 30% of the official tariff fee. All existing Sub-Agency Agreements (Tali Acentelik Sözleşmeleri) must be reviewed and amended to comply with the 30% statutory minimum fee.

Requirements, Limits and Prohibitions for Agents

• Financial Requirements

The new Regulation introduces separate minimum paid-in capital requirements for the incorporation of the main office and for each additional branch. The amounts vary according to the agency’s registered class.

	Headquarters	Each Branch
Class A	TRY 5,000,000 (approx. EUR 95,000 as on the date of this alert)	TRY 100,000 (approx. EUR 2,000 as on the date of this alert)
Class B	TRY 5,000,000 (approx. EUR 95,000 as on the date of this alert)	TRY 100,000 (approx. EUR 2,000 as on the date of this alert)
Class C	TRY 500,000 (approx. EUR 10,000 as on the date of this alert)	TRY 50,000 (approx. EUR 1,000 as on the date of this alert)

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• Personnel, Corporate Governance and Office Standards

Under the Regulation, all real person agents and the shareholders of corporate agencies are required to obtain authorisation certificates after passing rigorous background checks. Individuals with convictions for smuggling, tax evasion, or white-collar crimes will not be permitted to take on agency activities.

Authorisation certificates are issued for a five-year term and are non-transferable. Applications are to be submitted electronically through the Ship Agency Information System (GABS – Gemi Acenteliği Bilgi Sistemi). Persons or entities without a valid authorisation certificate are prohibited from providing agency services on behalf of shipowners, masters, operators or charterers.

Personnel: The Regulation further imposes some management and personnel requirements to be fulfilled at a minimum. For instance, Class A and B agencies must employ at least two personnel who are graduates of maritime-related undergraduate or associate degree programmes recognised by the Council of Higher Education. Also, each agency’s head office must have one designated agency manager and each branch must have at least one employee. Also, a designated "Agency Supervisor" (Acente Sorumlusu) should be appointed and such supervisor is permitted to serve only one company. The Regulation seems to aim to prevent paper-shuffling the same individuals as agency supervisors among multiple entities.

Offices: In addition, the Regulation prohibits the conduct of shipping agency services from residential premises or virtual offices. However, and probably most importantly, the Regulation permits only one agency to be registered at one business address. Thus, clients with more than one agency companies which are registered at the same offices should reconsider their corporate structures in order to avoid being in violation of the Regulation.

In this regard, the Ministry aims to enhance its existing efforts to cleaning up “shell agencies” by strictly prohibiting virtual offices, home offices, and shared office spaces. Accordingly, agencies must maintain a dedicated, physically independent commercial workspace equipped with localized digital archiving systems and Registered Electronic Mail (KEP) addresses.

• Conflict of Interest, Disciplinary Provisions and Consequences

The Regulation signals a major shift towards accountability and market transparency by imposing limitations on cross-surveying and restricting sharing credentials between agents. One of such surprising developments is that the Regulation strictly prohibits agencies that have a commercial relationship with the cargo owner or receiver from conducting surveying/inspection activities on that same vessel. Also, port/terminal operators are now also legally barred from blocking any third-party agencies from freely operating within their facilities to favour their own in-house agency arms.

Accordingly, agency service providers’ internal corporate IT and data protection (KVKK) policies must be reviewed, and if needed, updated. Agency employees may be required to provide undertakings regarding credential confidentiality, as sharing credentials as part of daily operations or a leaked password could jeopardize the company's authorisation.

Also worth noting is that if an agency’s headquarter’s license is suspended or deactivated due to a violation of the Regulation, the authorisations of all of its branch offices are automatically suspended simultaneously. This being said, the suspension of a branch’s authorisation does not automatically suspend that of the headquarters. Thus, a suspension at the headquarters level carries the potential of legally paralysing all branches and relevant operations. Accordingly, agencies with high-volume operations may consider corporate restructuring, especially with regard to their volume and market sensitive branches.

Timeline for Clients

The Regulation adopts a phased entry into force. All of the above requirements will enter into force on 14 August 2026 and the existing agencies are provided an interim period to adjust to the new framework. During the interim period (14 May – 14 August 2026), no new agency or branch office applications will be accepted.

As regards existing authorisation certificates, the following transitional regime applies:

• Agencies whose certificates expire within six months of 14 August 2026 (i.e. by 14 February 2027) will have their certificates automatically extended until the end of that six-month period, without any action required on their part.

• Agencies whose certificates have more than six months of remaining validity will retain their certificates until the original expiry date; however, this period may not exceed one year from the entry into force date (i.e. 14 August 2027 at the latest).

All renewal applications must be submitted at least one month prior to the expiry of the current certificate.

All existing agencies retain their current authorisations within their designated regions throughout the transition period until their certificates are renewed under the new framework.

Thus, the countdown has begun, and we would be happy to assist with constructing a compliance calendar tailored to your specific corporate structures, regions and volume of operation and license expiration dates. Please note that structural changes—such as office relocation, capital injection, and contract redrafting—must be synchronized within the grace period.

Should you require a detailed audit of your current corporate structure, sub-agency agreements, or assistance with capital increases to align with the new regulation, please do not hesitate to contact us.