VERBİS Registration Guide: 2026 Updates and Points to Consider

VERBİS (Data Controllers Registry Information System) is one of the fundamental cornerstones of KVKK compliance. However, many companies forget this system after registering once.

What is VERBİS and Who Must Register?

VERBİS is the official system where data controllers register themselves with the Board and declare their data processing activities.

Those with registration obligation:

• Companies with more than 50 annual employees
• Companies with annual financial balance sheet total exceeding 100 million TL
• Companies whose main activity is processing special category personal data

What Changed in 2026

1. Dynamic Update Requirement

VERBİS registration is no longer a "one-time" process. Every change in your business processes (new software, new supplier, new data category) must be reflected in VERBİS within 30 days.

2. Detailed Data Categories

In 2026 standards, general categories (e.g., "identity information") are not sufficient. Specific data types (ID number, birth date, address, etc.) must be specified separately.

3. Third-Party Transfers

All third parties you transfer data to (cloud service providers, payment systems, marketing tools) must be clearly listed.

Common Mistakes

• Outdated Records: Registration made 3 years ago doesn't reflect today's business processes
• Missing Data Categories: Data collected by the marketing department is not in the registration
• Wrong Retention Periods: Registration says "2 years" while in practice data is stored for 5 years
• Missing Third-Party Declarations: Tools like Google Analytics, Facebook Pixel not declared

Warning: Inconsistencies between VERBİS registration and actual situation are evaluated as "misleading statement" in Board audits and cause heavy penalties.

Action Plan

1. Download and review your current VERBİS registration
2. Compare with your current data inventory
3. Identify missing or incorrect information
4. Make updates within 30 days
5. Create a regular (quarterly) review schedule

Your VERBİS registration is the mirror of your company's data processing activities. Make sure this mirror always reflects reality.