Labour law compliance checklist Türkiye: 12 questions on hours, records and data

What does the compliance check measure — and what not?

The check asks about twelve of an employer’s most frequently inspected obligations on working time, records and personal data under Turkish law. Every question is phrased so that “yes” means compliant. The score is the share of “yes” answers: 9 out of 12 gives 75. “Not sure” and unanswered questions do not count as compliant, because an unchecked obligation is not a record you could show in an inspection.

The check is deliberately narrow. Occupational health and safety, disabled and ex-offender employment quotas, union rights and timely payment of wages are not covered; they need separate expertise. The check also shows no administrative fine amounts: they are revalued every year and an unverified figure gives false confidence.

Question texts are shortened from the relevant articles; the full wording is in the explanation under each question and in the sources at the end of the page.

Overtime: consent, documentation and 270 hours

Overtime carries three separate obligations, and all three must be shown on paper. The first is the employee’s written consent: obtained when the contract is signed or when the need arises and kept in the personnel file; the employee may withdraw it with thirty days’ written notice (Overtime Regulation art. 9). Overtime for compelling reasons and in emergencies is outside this requirement.

The second is documentation: the employer prepares a document showing the overtime hours of employees who worked overtime and keeps a signed copy in the personnel file (Overtime Regulation art. 10). The third is the annual cap: total overtime may not exceed 270 hours a year (Labour Law No. 4857 art. 41). For a sample consent form see the overtime consent form guide; for pay, overtime calculation.

Time limits: 11 hours, breaks, weekly rest, night

The four limits are independent; one can hold while another is breached. Daily working time may not exceed 11 hours under any arrangement (Working Time Regulation art. 4); overtime consent does not lift this limit. The rest break is at least 15 minutes, 30 minutes or 1 hour depending on the length of the day, and is not counted as working time (Law No. 4857 art. 68).

An employee who has worked the working days of the week gets at least 24 hours of uninterrupted weekly rest within a seven-day period (Law No. 4857 art. 46). Night runs from 20:00 at the latest to 06:00 at the earliest, and night work may not exceed 7.5 hours; in tourism, private security, health services and petroleum exploration and drilling it may be exceeded with the employee’s written consent (Law No. 4857 art. 69). To check a week against these limits use the working hours calculator; details in the rest break and night work guides.

Records: leave record, personnel file, pay slip

The first thing an inspector asks for is records. The employer must keep the annual leave record showing employees’ leave; a leave book or card file on the same basis may also be used (Regulation on Paid Annual Leave art. 20). A personnel file is kept for each employee, holding identity details and every document and record the law requires, and shown to the authorities on request (Law No. 4857 art. 75).

With every wage payment the employee receives a signed or stamped pay slip showing the calculation, with additions such as overtime, weekly rest, national and public holiday pay and deductions such as tax, insurance premiums and advances shown separately (Law No. 4857 art. 37). See the annual leave and personnel file guides.

Personal data: privacy notice and the biometrics ban

Clock-in, location and shift records are personal data. When the data is collected, the employee must be told the controller’s identity, the purpose of processing, who the data may be transferred to and why, the collection method and legal basis, and their rights (Personal Data Protection Law No. 6698 art. 10). The privacy notice is a separate obligation from explicit consent.

In its principle decision 2026/921 the Personal Data Protection Board held that processing fingerprint, facial, iris and retina data for attendance tracking is unlawful even with explicit consent, on proportionality grounds. If you use a fingerprint reader, the honest answer to that question is “no”. See the biometric attendance ban and KVKK-compliant employee tracking guides.

How to read the compliance score

The score is not a ranking but a to-do list. A score of 100 does not show that the workplace is compliant on every subject; it only shows that you say your practice is backed by records on these twelve questions. The real value is in the explanations that open under your “no” and “not sure” answers: each gives its legal basis and a related guide. Keep a screenshot of the result and repeat the check a few months later; changed answers show your progress.

Before answering “yes”, ask yourself: could I prove this with a document in an inspection? Is the overtime consent signed, is the leave record up to date, was the privacy notice actually given to employees? If the practice exists but the document does not, the honest answer is “not sure”.

Closing the gaps with records

Most of the obligations in the questions need a record-keeping routine. In our workforce management system clock-ins are recorded from the phone by location or QR code, or by PIN on a shared tablet; no biometrics are used. Overtime starts with the employee’s request and is confirmed by an authorised approver; an approval is rejected by the system if the employee’s overtime consent is not on file or if it would exceed 270 hours a year. Leave requests, approvals and balances are kept; timesheets build themselves from clock-ins and the approved month is locked. Pay slips and payroll remain your accountant’s job; the system prepares the payroll input. See workforce management software. To start on paper, use the free templates.

This check is for information only and is not a legal opinion. Collective agreements, workplace rules and sector regulations may add obligations; for your workplace’s specific situation consult a labour lawyer or payroll accountant.