Marketing messages to hotel guests: İYS registration and consent under Law 6563

İYS (İleti Yönetim Sistemi) is Türkiye's commercial electronic message management system. Under Law No. 6563 and its regulation, a hotel may send a marketing message to a guest only after prior approval, and a commercial message cannot be legally sent based on an approval that is not registered in İYS within three business days. Service messages about a booked stay need no approval but may not promote anything.

The seasonal offer is written, the guest list is ready, and nobody in the building can say which of those guests ever agreed to receive it. Under Turkish e-commerce law, that question decides whether the message may be sent at all. After reading this article you will be able to classify each message template as commercial or service, record approvals so they hold, run İYS registration on a fixed clock, and handle refusals within the legal window.

What counts as a commercial message to a guest?#

A commercial electronic message is a message sent to a contact detail by phone, SMS, email or a messaging app in order to promote a good or service. A confirmation or an operational note about a stay the guest has already booked is a service message and follows a different rule.

The test is content, not channel. If the message carries an offer, a price, a package or a call to book, it is commercial whether it leaves by SMS, email, WhatsApp or a guest app notification. The channel matters later, because the approval and the opt-out route are channel-specific, but the classification comes first from what the message says.

Article 6 of the regulation lists the messages that need no separate approval: information about changes to, use of or maintenance of the goods or services supplied, and notices about an ongoing subscription or membership, payment collection, debt reminders, updating information, purchase and delivery. Those service messages carry one condition: they may not promote any goods or services. A payment reminder with a spa discount at the bottom is no longer a service message.

Service messages are exempt from the prior-approval requirement, but the exemption is strict. If the primary purpose shifts to promotion, or if promotional content is not clearly secondary and incidental, the message may be reclassified as commercial. The hard cases sit in the middle: a pre-arrival email that gives directions and also offers a room upgrade. Either split it into two messages or treat the whole message as commercial. Our guide to hotel pre-arrival emails covers what belongs in each message.

Write the classification down once per message template, so the decision is not re-argued by whoever is on shift. The template owner labels it before the copy is written, and the label travels with the template.

Do you need prior approval before sending a hotel offer?#

Yes. Law No. 6563 requires the recipient's prior approval before a commercial electronic message is sent, and the message must match the approval that was given. The law is the Law on the Regulation of Electronic Commerce (Law No. 6563, Official Gazette 5 November 2014), with the duties in Articles 6 to 8, as set out in the consolidated text on the Mevzuat Bilgi Sistemi (opens in a new tab) (1 November 2026).

Approval can be given in writing or by any electronic means. This is why a checkbox on the booking engine and a signed form at the desk can both work, provided the evidence survives. What the evidence must show is the subject of the section on recording a permission.

The content must match the approval. A permission for a monthly email newsletter does not cover a weekly SMS campaign, and a permission for offers does not cover messages from a different brand in the same group. Recipients may refuse at any time without giving a reason, and the approval does not become permanent just because the guest stayed once.

Messages to tradespeople and merchants need no prior approval, but once such a recipient has refused, no message may be sent without approval. This matters for agency and corporate contacts, and we return to it below.

Approval under Law 6563 is a separate duty from KVKK consent (the personal data protection law): one covers the marketing message, the other covers the processing of personal data, and each needs its own record. Our article on KVKK for hotels covers the data side. Describe your own case to a legal adviser before relying on any exemption; the regulation is amended from time to time and the consolidated text is the one to read.

What is İYS and who has to register?#

İYS is the commercial electronic message management system defined in the regulation: the place where approvals are obtained, refusals are exercised and complaints are handled. Anyone who wants to send commercial electronic messages registers there as a sender.

The regulation is the Regulation on Commercial Communication and Commercial Electronic Messages (Resmî Gazete 15 July 2015, No. 29417), read in its consolidated text (opens in a new tab) (4 November 2026); it was amended on 4 January 2020 and 28 August 2020. Sender registration comes first: without it there is no route to check approvals or refusals, and İYS registration in Türkiye is the doorway through which every later step runs.

The operative rule is blunt: commercial electronic messages may not be sent to recipients who have no approval on İYS. A hotel may collect approval itself or through İYS. Approvals collected outside İYS must be registered in İYS within three business days, and approvals not registered there are invalid.

A business day here excludes weekend days and national and public holidays. A Friday approval can therefore legitimately land in İYS on the following Wednesday, but leaving registration to drift past the window voids the approval.

The regulation also sets record keeping. Approval records are kept for three years from the end of the approval's validity, and other message records for three years from the date of the record. Thresholds and exemptions are not stated here on purpose: confirm your own position with the Ministry of Trade's current announcements and your adviser before deciding that a rule does not apply to you.

How do you record a permission so it holds?#

Record the approval itself, not the fact that a box was ticked: who approved, for which channel and which content, when, through which door, and where the evidence sits.

Capture six fields at the moment of approval: contact detail, channel, scope of content, date and time, source (desk, booking engine, guest app, website), and the exact sentence the guest saw. Keep the wording version. If the offer text changes from "seasonal offers by email" to "offers and partner deals", the old approval may no longer match the new message.

Register approvals collected outside İYS within three business days, and keep the registration confirmation with the record. Keep approval records for three years from the end of the approval's validity, and other message records for three years from the date of the record; our guide on how long a hotel should keep guest records helps you place these clocks inside one retention table.

At the desk, use one form with one unticked box and have the receptionist read the sentence aloud. A pre-ticked box is not evidence of a choice. On the booking engine, place the marketing checkbox after the booking is complete and separate from the terms acceptance, so the two cannot be confused later.

Store the record where marketing, reservations and the front office all read the same source. Three parallel spreadsheets is how a refusal gets missed.

How does a guest opt out, and how fast must you act?#

Every commercial message must offer an easy, free way to refuse through the same channel it was sent on, and the hotel must stop sending within three business days after the refusal reaches it. A recipient may refuse at any time, without giving a reason, including through İYS.

Same channel means an SMS must be refusable by replying to the SMS, not only through a web form that requires a login. Refusals the hotel receives must be reported to İYS within three business days. Sending must stop within three business days after the refusal reaches the hotel, counted in business days, which excludes weekends and public holidays.

A refusal is not a preference setting: it applies to the contact detail and the content scope it covers, so suppress it across the desk list, the booking engine and the guest app at once. Do not ask for a reason, a password or a phone call to complete an opt-out; friction at this step is exactly what the rule is written against.

Log the refusal with its date and the date it was reported to İYS. That pair of dates is the only proof of timely action.

What about old lists, booking sites and messaging apps?#

A list without a recorded approval is not a marketing list. Treat it as unverified, and rebuild permission from zero rather than arguing that the guest "must have" agreed at some point.

If there is no approval on İYS and no evidence of an approval collected elsewhere and registered in time, the contact cannot receive a commercial message. Re-permission is not free either: the message asking a guest to confirm consent is itself a commercial message and needs a lawful route of its own, so take advice before sending one to a dormant list.

Guest details that arrive through a booking site support the stay and the bill; they do not by themselves create marketing approval, and the agency's terms may restrict further use. Corporate and agency contacts fall under the merchants and tradespeople rule: no prior approval is needed, but their addresses must be registered in İYS and checked for refusals before messaging.

Messaging apps follow the same content test as everything else. A WhatsApp thread opened to serve a guest during the stay is a service channel; turning the same thread into a campaign changes its character and its legal basis. Our rules for messaging guests on WhatsApp during the stay cover where that line sits. Any message that mixes a service update with an offer pulls the whole message back into the commercial category, however small the offer looks.

One permission routine for the desk, the booking engine and the guest app#

One routine with three doors: the same sentence, the same record and the same İYS registration, whether the guest arrives at reception, on the website or in the guest app.

Name one owner for the routine, usually the sales and marketing manager, with the front office manager as the second name. Agree the approved sentence once, in every language the hotel sells in, and use it word for word at all three doors. Fix the three-day clock in the calendar: approvals collected outside İYS are registered within three business days, and refusals are reported within the same window.

Audit a sample every quarter: does the stored wording still match the live campaign, and does the record show the channel and the source. Keep the classification table from this article next to the campaign brief, so each new template is labelled commercial or service before it is written.

What to do next#

Take one campaign list this week and count how many contacts have a recorded approval whose wording matches the message you are about to send. Register what is missing in İYS within three business days, drop what cannot be evidenced, and put the same sentence and the same record behind the desk, the booking engine and the guest app, so the next campaign starts from a list you can defend. Confirm your own case, and any exemption you intend to rely on, with a legal adviser.