Significant Amendments Have Been Made To Various Health-Related Laws.

Law No. 7557 titled “Law Amending Certain Health-Related Laws and Decree Law No. 663” (“the Law”) was published in the Official Gazette on July 24, 2025, and entered into force on the same date. This omnibus law introduces substantial changes in the field of healthcare, addressing a wide range of issues such as healthcare service delivery, working conditions of healthcare professionals, professional organizations, product inspections, and patient rights.

This article outlines the main changes brought by the Law concerning physicians’ work permits, disciplinary provisions, administrative sanctions, optician chambers, organ donation, pharmacies, medical devices and products, and the implementation of electronic consent (e-consent).

Work Permits and Multi-Institutional Practice for Physicians

One of the most significant innovations introduced by the Law concerns the easing of restrictions on physicians and specialists working in multiple private healthcare institutions. With the amendment to Article 12 of the Law on the Practice of Medicine No. 1219, physicians are now permitted to work in up to two private healthcare institutions. Previously, working at more than one location was entirely prohibited; the amendment replaces this with a cap of two. This practice is permitted only under employment contracts covered by subparagraph (a) of paragraph 1, Article 4 of the Social Insurance and General Health Insurance Law.

The rationale behind this regulation is to utilize the healthcare workforce more efficiently, ensure a more balanced distribution of healthcare services across the country, and alleviate shortages in certain medical specialties. It also aims to foster flexible employment opportunities within the private sector. Additionally, the new regulation seeks to ensure uniformity in physicians’ social security practices, reinforce institutional structures, and enhance the traceability and quality control of healthcare services.

A transitional provision has been included to align the current system with the new rules. Accordingly, physicians and specialists currently working at private healthcare institutions or foundation universities must renew their existing work permits by June 1, 2026. Failure to comply will result in automatic invalidation and cancellation of such permits after that date.

Disciplinary Provisions

The Law also strengthens disciplinary procedures applicable to healthcare professionals. In line with a prior decision by the Turkish Constitutional Court, the disciplinary rules governing certain professions have been granted a statutory basis.[1] For instance, the disciplinary sanctions and professional organization structures related to the optician profession—previously regulated at the level of secondary legislation—are now clearly defined in statutory law. Thus, disciplinary investigations, sanctions, and appeal mechanisms concerning professionals have been clearly regulated by law, ensuring legal certainty.

In addition, the disciplinary regime for contracted healthcare personnel under Decree Law No. 663 has been addressed. The Law stipulates that contracted personnel working in the Ministry of Health and affiliated institutions shall be subject to the same disciplinary provisions as their civil servant counterparts when committing comparable disciplinary infractions.

Restrictions on Advertising and Promotional Activities in Healthcare Institutions

The existing advertising ban applicable to physicians and dentists has been extended under the new Law to also cover private healthcare institutions. According to the newly introduced provisions, private healthcare providers are prohibited from engaging in promotional activities that exceed the limits of informational and educational content regarding healthcare services. Only objective and factual content is permitted, including the institution’s address, contact details, working hours, medical specialties offered, titles of the healthcare professionals on staff, and general public health information aimed at protection and prevention. Any content beyond these limits — including misleading, deceptive, harmful to human health, or unfairly competitive advertising — is explicitly prohibited.

The Law imposes strict administrative fines on private hospitals and clinics that violate the advertising and promotional restrictions. Institutions found to have engaged in unlawful advertising may be fined no less than TRY 100,000, and up to 2% of their gross service revenue for the previous month.

Chambers of Opticians and the Turkish Association of Opticians and Optometrists

One of the notable innovations introduced by the Law concerns the professional organization of the opticianry profession. Through amendments made to the Law on Opticianry No. 5193, both the Turkish Association of Opticians and Optometrists and local optician chambers have been granted a legal basis.

Accordingly, a chamber of opticians and optometrists may be established in any province that reaches a sufficient number of professionals (at least 150 opticians/optometrists), and these chambers will be organized under the umbrella of the national Association. The Law provides detailed regulations on the chambers’ general assembly, executive board, disciplinary board, supervisory board, and the procedures governing their elections and operations. Within this framework, professionals who are not members of the chamber — except those employed in permanent public positions or other specified exceptions — will not be permitted to engage in professional activities.

It is important to note that the organization of the opticianry profession was previously envisaged by legislation; however, the Turkish Constitutional Court annulled certain provisions.[2] In its reasoning, the Court emphasized that the fundamental rules regarding the organizational and disciplinary structure of professional bodies must be set out by law and cannot be regulated solely by secondary legislation. The new Law addresses this gap by explicitly defining, within the statutory text, the establishment, duties, governing bodies, and disciplinary rules of the chambers and the Association.

Facilitations Regarding Organ Donation and Transplantation

The Law also introduces major updates to bring the regulation of organ and tissue donation in line with current needs and technological advancements.

In this context, Article 14 of the Law on the Removal of Organs and Tissues No. 2238, dated 29 May 1979, has been amended to allow individuals to declare their consent to donate organs and tissues after death electronically.

Furthermore, individuals may now register their intent to donate their bodies or organs while alive — for treatment, diagnosis, or scientific purposes — via the e-Government Gateway or through secure digital systems to be established by the Ministry of Health.

Another critical innovation introduced by the Law is the protection of the donor’s expressed intent. If an individual has declared their consent to organ donation through one of the aforementioned procedures during their lifetime, this decision shall prevail, even if the person's relatives object after death. Conversely, if no declaration was made during the individual’s lifetime, consent must still be obtained from a spouse, adult children, parents, siblings, or other close relatives, in that order, in line with current practice.

The Law also introduces an incentive for the families of organ donors. Accordingly, the spouse and first-degree relatives of individuals whose organs have been donated and transplanted into others shall be granted priority on organ waiting lists, coming immediately after patients listed under urgent status.

Implementation of Electronic Consent (e-Consent)

With the enactment of the Law, electronic consent — referred to as e-consent — has been granted a legal foundation for the first time as part of the digital transformation of healthcare services. Through an amendment to Article 70 of the Law on the Practice of Medicine No. 1219, the informed consent required from patients prior to medical procedures and treatments can now be obtained via electronic communication devices.

Under this framework, for electronic consent to be deemed valid, the individual’s identity must be securely verified. According to the Law, during the process of obtaining digital consent, the patient’s identity shall be authenticated through biometric methods such as facial recognition or fingerprint scanning, or by using identity verification tools such as electronic ID cards or digital signatures.

Although the details of the implementation are yet to be clarified, the Law authorizes the Turksih Ministry of Health to issue secondary legislation on this matter, subject to the opinion of the Turkish Information and Communication Technologies Authority. Relevant regulations setting out the procedures and principles for electronic consent are expected to be published in the near future.

This regulation not only facilitates the digital recording and auditing of consent forms, but also paves the way for the secure collection of consent in remote healthcare services (telemedicine) and mobile health applications, especially in cases where the patient is unable to provide a physical signature.

Pharmacies, Pharmaceutical Warehouses, and the Product Tracking System

The Law introduces reinforced sanctions to enhance traceability within the supply chain of medicines and health products. In light of recent challenges regarding the availability of certain products in the market, new obligations have been imposed on pharmaceutical warehouses and pharmacies.

Accordingly, pharmaceutical warehouses are now required to report all supply chain movements of human medicinal products and foods for special medical purposes to the Product Tracking System in accordance with procedures and principles determined by the Ministry of Health. A new provision added to the Law on Pharmaceutical Warehouses No. 984, dated 1927, sets out severe penalties for non-compliance. If a warehouse fails to make the required notifications, an administrative fine equal to twice the total wholesale value of the unreported products will be imposed. In cases where the violation is repeated within the same year, the penalty amount will increase. Upon a third violation, the warehouse’s license will be revoked. This regulation primarily aims to prevent practices that jeopardize public health, such as medicine smuggling, distribution of illegal products, and stock hoarding. As emphasized in the article’s rationale, the barcode-based tracking system allows real-time monitoring of each unit of medicine. By imposing deterrent penalties, the regulation seeks to block counterfeit, smuggled, or unregistered products from entering the legal supply chain. It also enables the rapid recall of defective or noncompliant products from the market when necessary.

In addition, the Law amends the Pharmacists and Pharmacies Law No. 6197 to apply pharmaceutical warehouse standards to foods for special medical purposes. From now on, these products must also be stored and distributed by pharmaceutical warehouses in compliance with the Ministry of Health’s regulatory requirements.

The Law also provides that administrative fines will be imposed in cases where supply chain movements of human medicinal products and foods for special medical purposes are not reported to the tracking system in accordance with the relevant procedures. Under new paragraphs added to Article 44 of the Pharmacists and Pharmacies Law, pharmacies that fail to submit notifications as required by Article 24 of the same Law will face fines equal to twice the wholesale value of all products involved in the violation, calculated as of the date of the breach. If repeated within the same year, these penalties will increase accordingly. This enforcement framework will apply to actions such as possessing unauthorized products in pharmacies, selling counterfeit or smuggled products, and dispensing prescription-only medications in violation of applicable regulations.

Through these regulations, the Law aims to establish a transparent and accountable system for monitoring the supply chain of both medicinal products and specialized nutritional products. It is expected to improve product availability, reduce illegal trade, deter hoarding, and ultimately prevent patient harm.

Regulation on Medical Cannabis

The Law also introduces amendments to the Law on the Control of Narcotic Substances, particularly regarding cannabis-derived products. Under the revised provisions, licensing and registration procedures for medical products, health products, personal care products, and dietary supplements derived from cannabis shall be carried out by the Ministry of Health. These products may only be sold through pharmacies. The procedures and principles concerning the authorization and sale of such products, as well as the processing, preparation, and export of cannabis, will be defined by a regulation to be issued by the Ministry of Health, following consultations with the Ministry of Interior and the Ministry of Agriculture and Forestry. This regulation aims to ensure legal clarity and prevent misuse or abuse by clearly identifying the legal nature and classification of cannabis-derived products.

Inspection of Medical Devices

The Law also strengthens the inspection mechanisms for medical devices introduced into the market.

In this regard, Article 20 (Additional) has been added to the Fundamental Law on Health Services No. 3359 to establish a two-tiered system of administrative fines for violations:

• Producers, distributors, or holders of counterfeit (imitated) medical devices may face administrative fines ranging from TRY 1 million to TRY 10 million.

  
  

• Those who sell, advertise, distribute, or market medical devices without authorization, or who provide unauthorized technical services outside of licensed facilities, may be fined between TRY 500,000 and TRY 5 million.

In the event of repeat violations within a calendar year, the penalties shall be doubled for each additional offense. The authority to impose these fines is granted to both the Turkish Medicines and Medical Devices Agency (“TMMDA”) and the provincial governors (local administrative authorities).

TMMDA's Authority to Request Financial Records

Through the newly added Article 21 (Additional) to Law No. 3359, TMMDA is now authorized to request any financial information and documentation from natural and legal persons in connection with the inspection of products and services falling under its jurisdiction.

The legislative rationale emphasizes the importance of financial data in the monitoring of products that directly affect human health such as medicines, medical devices, and cosmetics and confirms that this access will be provided in compliance with Article 5 of the Tax Procedure Law.

Conclusion

The Law introduces comprehensive reforms across a wide range of health-related areas including physician employment, the structuring of professional health associations, patient rights, and product safety. With these amendments, the Law aims to expand and improve the quality of healthcare services, strengthen physical and human infrastructure within the health system, increase the effectiveness of preventive and therapeutic health services, and ensure that healthcare delivery evolves in line with technological developments, societal needs, and socioeconomic transformation.

Given the scope and impact of these changes, the Law is expected to usher in a compliance and adaptation process that will need to be closely followed by private hospitals, medical device companies, pharmaceutical warehouses, healthcare institutions, and other stakeholders in the healthcare sector.

[1] The Turkish Constitutional Court’s decision dated 12.05.2020 and numbered 2020/80 E. 2021/34 K.

[2] The Turkish Constitutional Court’s decision dated 12.05.2020 and numbered 2020/80 E. 2021/34 K.