This page summarises the position under Turkish law of fake content, generated with AI, that shows real people in sexually explicit images, videos or audio without their consent. It is based on the publications of Prof. Dr. Murat Volkan Dülger listed at the end. The legislation cited was checked against official sources on 1 November 2026.

The nature of the problem

Today a few ordinary photographs of a person on social media are enough to produce a realistic fake sexual image of them. Victims are therefore no longer only public figures; former spouses, colleagues, students and journalists are targeted as well.

In Prof. Dr. Murat Volkan Dülger's view, non-consensual fake sexual content is not a matter of insult or obscenity but an attack on a person's sexual autonomy and intimate identity. That the image is fake does not lessen the attack. Where the content cannot be told apart from a real image, the victim also bears the burden of proving to others that it is fake.

AI-generated “revenge porn”

In his 2019 paper on sexual offences committed via the internet, Dülger used the term “revenge porn” for the non-consensual distribution, after a relationship ends, of intimate images recorded by or given to a former partner, and noted that perpetrators act not only out of revenge but also for financial gain or to damage the victim's reputation. In the same paper he pointed out that a perpetrator unable to obtain a former partner's images could commit the same act by creating them.

Generative AI has turned this possibility into a widespread phenomenon. The perpetrator no longer needs a real intimate image of the victim, so a former spouse or partner who never shared an intimate image can now become a victim. Although the term is established in public debate, the concept to be used in legal analysis is “non-consensual intimate image”.

Current provisions of Turkish law

The Turkish Criminal Code (TCK) contains no provision that directly criminalises non-consensual fake sexual content. In practice, different offences are relied on depending on the case, and each covers only part of the problem.

Distributing real intimate images without consent amounts to unlawful disclosure of images or sounds relating to private life and is punishable by two to five years' imprisonment (Art. 134(2) TCK). A fake image, however, does not relate to the victim's actual private life, so applying Article 134 to fake content is doubtful in view of the prohibition of analogy (Art. 2(3) TCK). As a result, a perpetrator who distributes a real intimate photograph is punished, while the liability of one who produces and distributes an indistinguishable fake from ordinary photographs remains unclear.

Since the elements of sexual harassment (Art. 105 TCK) do not require an image, that provision may also apply to fake images where sexual intent and harassment are present. Forcing a victim to do or not do something by threatening to distribute such images constitutes blackmail (Art. 107 TCK), whether the image is real or fake.

Fake content produced using a real person's face, voice and distinctive features is personal data. The offences of unlawfully recording personal data (Art. 135 TCK; the penalty is increased by half where the data relate to sexual life) and of unlawfully giving or disseminating data (Art. 136 TCK) may therefore apply. The provisions on insult (Art. 125 TCK) and obscenity (Art. 226(1)-(2) TCK) do not capture the core wrong, the attack on sexual autonomy.

The choice of provision also matters procedurally. Violation of privacy requires a complaint, whereas unlawfully recording personal data and unlawfully giving or obtaining data do not (Art. 139 TCK). For offences requiring a complaint, the complaint must be filed within six months of the day on which the victim learned of the act and the perpetrator (Art. 73 TCK).

Remedies available to the victim

The victim's most urgent need is rapid removal. A person who claims that a publication on the internet violates their privacy may apply directly to the Presidency of the Information and Communication Technologies Authority for access to the content to be blocked (Art. 9/A of Law No. 5651). The application must state the full address (URL) of the content, how the right is infringed, and identity details. A criminal complaint may also be filed with the public prosecutor's office; recording the addresses and dates of the content is important for preserving evidence.

Comparative law

EU Directive 2024/1385 on combating violence against women and domestic violence requires Member States to criminalise producing, manipulating or altering material that makes it appear as though a person is engaged in sexually explicit activities, and then making it accessible to the public, without that person's consent and where this is likely to cause serious harm (Art. 5(1)(b)). Threatening to do so in order to coerce is also to be criminalised (Art. 5(1)(c)). Commission of the offence against a former or current spouse or partner must be capable of being treated as aggravating (Art. 11(k)), and such material must be promptly removed (Art. 23). The transposition deadline is 14 June 2027.

The EU AI Act (Regulation (EU) 2024/1689), as amended by Regulation (EU) 2026/1744 (Digital Omnibus), adds two prohibited practices: systems that generate or manipulate realistic material showing an identifiable person's intimate parts or the person engaged in sexually explicit activities without consent, and systems that generate child sexual abuse material (Art. 5(1)(ba) and (bb)). They apply from 2 December 2026. The duty of deployers of deep fake systems to disclose that the content is artificially generated has applied since 2 August 2026 (Art. 50(4)).

In the United Kingdom, creating, or requesting the creation of, an image that purports to show an adult in an intimate state without consent has been an offence since 6 February 2026 (Sexual Offences Act 2003, ss. 66E and 66F). In the United States, the federal TAKE IT DOWN Act, in force since 19 May 2025, criminalises the knowing publication of AI-generated intimate images without consent and requires platforms to remove such content within forty-eight hours of a victim's notice.

Content depicting children

Article 226(3) TCK punishes anyone who uses children, representative images of children or persons appearing to be children in producing obscene products with five to ten years' imprisonment and a judicial fine. In Dülger's view, AI-generated child abuse images fall within “representative images of children”. Here the problem is not a legal gap but enforcement that cannot keep pace with the speed and volume of production.

Assessment

In Prof. Dr. Murat Volkan Dülger's view, a specific offence should be added to the Turkish Criminal Code among the offences against sexual integrity, after sexual harassment. It should cover producing, giving to others and disseminating content that shows a person, without consent, engaged in sexual activity or with their intimate parts and is hard to distinguish from reality, with dissemination punished more severely than production. The offence should be technology-neutral, and labelling the content as fake should not remove liability, since the attack on the victim's sexual identity continues even when the content is known to be fake. Commission against a former or current spouse or partner should be an aggravating circumstance, and prosecution should require a complaint.

Criminal law cannot solve the problem alone. Article 9/A of Law No. 5651 should expressly cover such content and include procedural safeguards against abuse. In Dülger's view the most effective measure lies at system level: placing on the market AI systems that are designed to produce non-consensual intimate images, or make this a reasonably foreseeable result without safeguards against it, should be prohibited in Turkish law too, along the lines of Article 5(1)(ba) of the EU AI Act. This is not a ban on technology but a duty to have safeguards. For content depicting children, priority should likewise go to a system-level prohibition and to platforms' duties to detect and remove such material.

The legislation and sources cited and their status for Türkiye

The legislation and sources cited on this page are listed below with their full titles and their legal status for Türkiye. For texts not in force in Türkiye, the list states why they are cited and in which cases they may nevertheless bind persons in Türkiye.

  • Turkish legislation: Turkish Criminal Code, Law No. 5237 (TCK; Official Gazette 12.10.2004, No. 25611); Law No. 5651 on the Regulation of Internet Publications and Combating Crimes Committed through Such Publications (Official Gazette 23.5.2007, No. 26530); Law No. 6698 on the Protection of Personal Data (KVKK; Official Gazette 7.4.2016, No. 29677). In force and binding in Türkiye.
  • Directive (EU) 2024/1385 of the European Parliament and of the Council of 14 May 2024 on combating violence against women and domestic violence: directives bind only EU Member States and must be transposed into national law (deadline 14 June 2027). It does not bind Türkiye. Cited to show the EU's response to the same problem and as a model for Turkish law.
  • EU AI Act: Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024. In force in the EU since 1 August 2024. Since Türkiye is not an EU member, it is not in force in Türkiye and does not bind Turkish authorities or courts. It does, however, bind providers and deployers in Türkiye that place systems on the market or put them into service in the EU, or whose systems' output is used in the EU (Art. 2(1)(a) and (c)). Because Türkiye is an EU candidate country and is required, within the Customs Union, to align its technical legislation on products, the Act is also cited as a model for Turkish legislation.
  • Digital Omnibus: Regulation (EU) 2026/1744 of the European Parliament and of the Council of 8 July 2026, amending the AI Act; in force in the EU since 27 July 2026. Its status for Türkiye is the same as that of the AI Act.
  • United Kingdom, Sexual Offences Act 2003, ss. 66B, 66E and 66F (inserted by the Online Safety Act 2023 and the Data (Use and Access) Act 2025): applies in England and Wales; does not bind Türkiye. Cited as a comparative example.
  • United States, TAKE IT DOWN Act (Pub. L. 119-12, 19.5.2025): US federal law; does not bind Türkiye. Cited as a comparative example.

Related publications and pages

Status of the law: 1 November 2026. This page provides general information and does not replace legal advice on a specific case.