ETBİS registration: does a hotel website that takes bookings need it?
Determine if your hotel website needs ETBİS registration. This guide explains the legal definition of electronic commerce, the specific tourism exclusions, and the exact reporting steps for your booking engine.
Contents
Key takeaways
- The Communiqué on the Electronic Commerce Information System and Notification Obligations (Resmî Gazete, 11 August 2017, No. 30151) requires three groups to register in ETBİS before they start operating, and it never names hotels.
- Neither Law No. 6563 nor the Regulation of 29 December 2022 exempts accommodation: the only tourism carve-out covers businesses licensed under Travel Agencies Law No. 1618.
- Registration is made through e-Devlet, and the notification within 30 days reaches the KEP address, payment methods, infrastructure providers and the country where guest data is stored.
- The Communiqué does not apply to providers that make contracts only by e-mail, telephone, text message or similar one-to-one tools, which is where a brochure site ending in a phone call sits.
- The text sets notification duties, not a display rule, so confirm the current text before adding an ETBİS badge to your footer.
ETBİS is Türkiye's electronic commerce information system, run by the Ministry of Trade. Registration is required of businesses that conclude contracts through their own website, mobile site or app. The 2017 Communiqué does not name hotels and does not exclude them: a hotel taking bookings on its own domain may fit its definition, depending on whether the site concludes the contract. Your own case still needs an adviser's confirmation.
Your booking engine confirms a reservation on your own domain, the guest pays by card, and the confirmation lands in an inbox. Nothing in that moment feels like electronic commerce to a hotelier, and the Ministry of Trade's register never uses the word hotel either. This article reads the actual texts for what counts as electronic commerce, whether accommodation is treated differently, who registers when the engine belongs to a provider, and what has to be reported. By the end you will have a one-page description of your own booking flow, a registration checklist and five questions to put to your adviser.
What is ETBİS, and which text creates it?
ETBİS is the Ministry of Trade's electronic commerce information system: a register of businesses that sell online and of what they report about those sales. It is created by a communiqué, not by a licence or a tax rule.
ETBİS stands for Elektronik Ticaret Bilgi Sistemi. It is a notification system, not a permit: registering does not authorise you to trade, and trading online does not wait for approval. The operative text is the Communiqué on the Electronic Commerce Information System and Notification Obligations (opens in a new tab), published in the Resmî Gazete on 11 August 2017, No. 30151, and amended on 15 February 2019, No. 30687.
The communiqué sits under two other layers. Law No. 6563 on the Regulation of Electronic Commerce sets who is in scope. The Regulation on E-Commerce Intermediary Service Providers and E-Commerce Service Providers (Resmî Gazete, 29 December 2022, No. 32058) sets the obligations of the two provider categories. The Communiqué sets what goes into ETBİS and by when.
Registration is made through e-Devlet, so the record is tied to the business's own credentials rather than to a website vendor's account. That matters when you change providers: the duty to keep the record correct stays with you.
Finally, ETBİS is not KBS, the guest identity notification, not a KVKK filing, not a tax registration. It does not replace the guest-facing paperwork of a distance sale, which follows the sale itself.
Does a booking engine on your own website count as electronic commerce?
On the text as written, yes: a hotel that concludes a reservation contract through its own website, mobile site or app is a service provider operating its own e-commerce environment. The Communiqué never uses the word hotel, and it never excludes one either.
The first of the three groups in the Communiqué is defined by the channel, not by the sector: a website, a mobile site or an app through which the business sells. What makes the sale electronic commerce is the contract, not the payment. A reservation confirmed online at a stated price, with terms, is a contract concluded electronically even when the guest pays at the desk on arrival.
The only tourism carve-out does not cover hotels
The exclusion list is narrow and sector-specific. Article 1(3) of Law No. 6563 (opens in a new tab), added by Law No. 7416 of 1 July 2022, and Article 2(2) of the 2022 Regulation cover businesses governed by Travel Agencies Law No. 1618 and by the listed aviation, private pension, banking, insurance, leasing and finance, capital markets, payment services and electronic communications laws, acting only in the fields they are authorised for.
Hotels certified under Law No. 2634 are not on that list. A hotel is not a travel agency, and holding a Ministry certificate does not move it into the carve-out. The honest limit is that the text does not name accommodation, so the classification rests on how your site actually concludes the contract, not on the fact that you are a hotel.
Here is the decision rule as a table, using the three groups the Communiqué names:
| Group named in the Communiqué | What it means in practice | Where a hotel fits |
|---|---|---|
| Service provider operating its own e-commerce environment (website, mobile site, app) | The business concludes the contract on its own channel | A hotel with a booking engine on its own domain |
| Intermediary service provider | A platform that brings buyer and seller together | A marketplace or booking site, not the hotel's own site |
| Türkiye-based provider contracting through an intermediary abroad | A Turkish business selling only through a foreign-based platform | A hotel whose only online sales run through a platform abroad |
The decision rule for your own site is one question: does the guest leave with a confirmed reservation at a stated price, or with a request that a person will answer later? If you want to strengthen the booking path itself, see how to increase direct bookings on your hotel website.
What about a site that only shows a phone number or a contact form?
The Communiqué does not apply to providers that make contracts only by e-mail, telephone, text message or similar one-to-one communication tools. A brochure site that ends in a phone call sits outside it; a form that returns a confirmed booking does not.
The test is the contract again, not the presence of a form. A contact form that produces a question and a human reply is one-to-one communication. A form that returns a confirmed reservation at a price is a contract concluded on the site. A "request availability" form that a receptionist answers by e-mail is closer to the excluded case, and you should document how it actually works, because the classification follows the flow, not the label on the button.
A site that only links out to booking sites is different again: the contract is concluded on the booking site, so the hotel's own pages are not the e-commerce environment for that sale. The booking site has its own position to manage.
Mixed sites are the normal case. A hotel with a booking engine on the room pages and a plain contact form elsewhere is in scope for the engine. Whatever the answer, the guest-facing paperwork does not change: distance contracts and pre-information duties follow the sale, not the register entry, as covered in the distance contract rules for hotel bookings.
NoteWrite the flow down before you ask anyone
Three lines are enough: what the guest submits, what the hotel sends back, and whether a price is fixed at that moment. Every classification question in this article turns on the third line.
The engine belongs to a provider and the domain is yours: who declares what?
The hotel declares the domain it operates, and the engine provider appears in that same notification as an e-commerce infrastructure provider. The Communiqué does not settle every split, so read the contract before assuming the vendor has covered you.
The notification includes the domain names and mobile apps the business uses, so your own domain is yours to declare, whoever built the site. It also includes the business's e-commerce infrastructure providers, which is where a hosted booking engine, a site platform or a payment layer is named.
A white-label engine that concludes the contract in the hotel's name normally sits as infrastructure. An intermediary is a platform that concludes the contract in its own name, which a booking engine on your own domain does not do. Ask the provider two questions in writing: whether they are registered in ETBİS themselves, and under which category they expect to appear in your notification. Put the answer in the contract next to the data-protection and availability terms, so a change of provider does not leave your record stale.
The 30-day change duty belongs to you, not to the vendor. If you switch engines or add a domain, the notification is yours to update. For the pre-purchase stage, the same discipline applies to the questions to ask a hotel booking engine provider.
How do you register, and what has to be reported?
Registration is made through e-Devlet, and the notification that follows within 30 days is longer than most hoteliers expect: it reaches payment methods, infrastructure providers and the country where guest data is stored.
Identity comes first: merchants enter their MERSİS and tax numbers; tradesmen and craftsmen enter their T.C. identity and tax numbers. Then the channels: the domain names and the mobile apps used for electronic commerce. Within 30 days of registering, you report a KEP address for official notices, the type of e-commerce, other commercial activities, and the goods and services offered. Also within 30 days: payment methods and payment service providers, e-commerce infrastructure providers, and the country and address of the databases that hold personal and customer data.
Every year by the end of March, cross-border e-commerce volume is reported, broken down by country and payment method. Changes, and the end of electronic commerce activity, are reported within 30 days. Source for this section: Communiqué on the Electronic Commerce Information System and Notification Obligations, Resmî Gazete, 11 August 2017, No. 30151, as amended 15 February 2019, No. 30687.
ChecklistHave these ready before the session in e-Devlet
- MERSİS and tax number, or T.C. identity and tax number
- Every domain and mobile app used for selling
- An active KEP address
- The type of e-commerce and your other commercial activities
- The goods and services you offer
- Payment methods and payment service providers
- The booking engine and site platform named as infrastructure providers
- The country and address of the databases holding personal and customer data, confirmed with the vendor in writing
- A calendar reminder for the end-of-March cross-border report and for 30-day change updates
Do you have to show an ETBİS logo or code on the site?
The text sets notification duties, not a display rule. It says what must be reported to the system and when; it does not set out a badge, logo or code that must appear on the page.
Guidance circulating about an ETBİS logo or code does not appear in Articles 2 and 5 to 8 of the Communiqué as we read them. Treat it as unconfirmed until you have seen the current text. Check the Ministry of Trade's own pages and the consolidated communiqué on mevzuat.gov.tr before adding anything to your footer.
If a display duty exists elsewhere, it is a separate obligation from registration and needs its own line in your website checklist. Do not confuse the ETBİS record with the documents a booking needs: the pre-information form and the distance sales contract follow the sale and are unaffected by the register, as covered in the section-by-section sample of a distance sales contract. Ask your adviser to confirm in writing, so the answer survives the next staff change.
Watch outDo not copy a badge from another hotel's footer
If a display duty exists, it will be in the current text or in the Ministry's guidance, and it will say what the badge must contain and where it goes. A copied image proves nothing about your own obligation.
Keeping the record current, and what to ask your adviser
The record is a living notification: changes and the end of electronic commerce activity are reported within 30 days, and cross-border volume once a year by the end of March. Put both on a calendar and give the file an owner.
Name an owner, whether that is the web manager, the accountant or both, and keep the ETBİS record next to the domain, hosting and booking-engine contracts. The trigger list for an update is short: a new domain, a new engine, a new payment provider, a new database location, a new commercial activity, or the closure of online sales.
The questions for the adviser: does our booking flow conclude a contract on the site; which of our domains are in scope; is the engine infrastructure or an intermediary; what exactly must appear on the site today; what changes if we stop selling online. Keep the answers dated. This text has been amended before, on 15 February 2019, and can be again.
The honest limit stands: the Communiqué does not name accommodation, so a dated written opinion from your adviser is worth more than any blog post, including this one.
TipOne page, five lines
The domains in scope, the engine and its category, the payment providers, the database countries, and the date of the last notification. Hand the same page to your adviser and to whoever takes over the website next.
What to do next
Write down two things this week: every domain and app through which a guest can leave with a confirmed reservation, and the three-step flow of what the guest submits, what the hotel sends back and when the price is fixed. Take that page and the five adviser questions above to your accountant or legal adviser. ETBİS is a register, and whether your hotel belongs in it turns on how your site concludes the contract, not on the sector you trade in. For the wider picture of what a compliant booking path needs, see the hotel website checklist.
Frequently asked questions
Is ETBİS registration mandatory for a hotel?
The Communiqué (Resmî Gazete, 11 August 2017, No. 30151) requires three named groups to register before they start operating. Hotels are neither named nor excluded, and the only tourism carve-out in Law No. 6563 and the 2022 Regulation covers businesses licensed under Travel Agencies Law No. 1618. Whether a particular hotel is in scope depends on whether its site concludes the contract. Confirm your own case with an adviser; no penalty amounts are stated here.
Does a hotel that only takes bookings by phone or e-mail need ETBİS?
The Communiqué does not apply to providers that make contracts only by e-mail, telephone, text message or similar one-to-one communication tools. A site that shows a number and a contact form and ends in a conversation is the case the text describes. A form that returns a confirmed reservation at a price is not that case.
Who registers when the booking engine is a third-party product?
The hotel declares the domain it operates and names the engine among its e-commerce infrastructure providers. A white-label engine concluding the contract in the hotel's name normally sits as infrastructure rather than as an intermediary. Ask the vendor in writing whether they are registered and in which category, and remember that the 30-day update duty stays with the hotel.
What information goes into ETBİS?
MERSİS and tax number, or T.C. identity and tax number for tradesmen and craftsmen; the domains and mobile apps used; within 30 days a KEP address, the type of e-commerce, other commercial activities, the goods and services offered, payment methods and providers, infrastructure providers, and the country and address of the databases holding personal and customer data. Cross-border volume is reported every year by the end of March.
Is there an ETBİS logo I must put on my website?
The articles we read set notification duties, not a display rule. Before adding a badge or code to your footer, check the consolidated communiqué on mevzuat.gov.tr and the Ministry of Trade's own guidance. If a display duty exists elsewhere, it is separate from registration and should be confirmed in writing by your adviser.
Sources
- Elektronik Ticaret Bilgi Sistemi ve Bildirim Yükümlülükleri Hakkında Tebliğ, Articles 2 and 5-8 (opens in a new tab)T.C. Cumhurbaşkanlığı Mevzuat Bilgi Sistemi (mevzuat.gov.tr)mevzuat.gov.tr
- Elektronik Ticaretin Düzenlenmesi Hakkında Kanun (Kanun No. 6563), consolidated text, Article 1(3); with Elektronik Ticaret Aracı Hizmet Sağlayıcı ve Elektronik Ticaret Hizmet Sağlayıcılar Hakkında Yönetmelik, Article 2(2) (opens in a new tab)T.C. Cumhurbaşkanlığı Mevzuat Bilgi Sistemi (mevzuat.gov.tr)mevzuat.gov.tr