Amendments to the Regulation on Private Health Insurance: Lifetime Renewal Guarantee and Data Protection Provisions

The Regulation Amending the Regulation on Private Health Insurance (“Amendment Regulation”) was published in the Official Gazette dated 20 October 2025,  to enter into force on 1 January 1 2026. The Amendment Regulation introduces significant provisions aimed at strengthening policyholders’ rights and ensuring uniform implementation within the field of private health insurance.

The principal provisions of the Amendment Regulation - which introduce obligations concerning contract continuity, data protection, and information disclosure for both insurance companies and policyholders - are summarized below.

1.      Regulation on Lifetime Renewal Guarantee

Under the Amendment Regulation, insurance companies are required to provide a lifetime renewal guarantee to policyholders who have not exceeded the age of 60 at the inception of the policy.

In order to be eligible for this guarantee, the policyholder must satisfy the following conditions:

• Maintain continuous coverage under the same plan for at least three years, and

• Ensure that the total amount of claims paid during this period does not exceed 80% of the total premiums paid.

For policies featuring a lifetime renewal guarantee, insurance companies shall not:

• Narrow the scope of coverage,

• Reduce coverage limits,

• Request additional premiums for new illnesses, or

• Make any amendments that would be prejudicial to the policyholder.

2.      Waiting Periods and Information Disclosure Obligations

The Amendment Regulation stipulates that waiting periods may only be applied during the initial policy term, and cannot be imposed again for the same plan upon policy renewal.

In the event that a policyholder transfers to a different insurance company, any completed waiting periods under the previous policy shall be credited to the new insurer. This provision aims to prevent any loss of entitlements for the policyholder.

In addition to these amendments, the level of policyholder protection in private health insurance has been enhanced, while transparency in data management and information disclosure processes of insurance companies has been strengthened.

Insurance companies are required to present, in a clear, comprehensible, and comparable manner, the conditions for acquiring the lifetime renewal guarantee, the coverage provided upon entitlement, and any changes in the scope of coverage.

Furthermore, policies must explicitly indicate whether a product is “with lifetime renewal guarantee” or “without guarantee,” and policyholders are required to be informed accordingly.

3.       Insurance Records and Personal Data Processing Obligations

Under the Regulation Amending the Regulation on Private Health Insurance, it is explicitly stipulated that:

• Insurance records and health information of policyholders must be kept on individual basis for both individual and group contracts, and

  
  

• All data processing activities in this context must comply with the Personal Data Protection Law No. 6698 and the applicable procedures and principles under the relevant legislation.

  
  

Accordingly, matters related to data processing within the scope of private health insurance - including obtaining explicit consent, data retention periods, and data destruction - are now directly linked to personal data protection legislation.

The Amendment Regulation will enter into force on 1 January 2026. Existing policies will continue under the rules applicable to their current tariffs; however, new policies will be subject to the provisions of the Amendment Regulation as of its effective date.