Selling pricing">tokens and subscriptions online to consumers in Türkiye falls under the Consumer Protection Law no. 6502 and the Distance Contracts Regulation. Three documents matter at checkout: the preliminary information form, the distance sales agreement, and the seller's refund policy. This article explains what each must contain for a product that delivers digital content the moment it is paid for, and what a seller should do beyond the minimum.

The withdrawal exception

Consumers normally have fourteen days to withdraw from a distance contract without giving a reason. Article 15 of the Regulation lists exceptions, and two apply to digital content: services performed instantly in the electronic environment and intangible goods delivered instantly (item ğ), and services whose performance begins with the consumer's approval before the withdrawal period ends (item h). Tokens credited to a wallet on payment fall under the first; a subscription that starts immediately falls under the second.

The exception only holds if the consumer was told before paying and expressly approved. In practice that means a visible sentence on the payment step, a checkbox the consumer ticks, and a record of the tick. Without the record, the exception is unenforceable and the consumer keeps the fourteen-day right.

What must be disclosed

  • Seller identity: legal name, address, trade registry and tax numbers, contact details including an electronic address.
  • The essential characteristics of the product: what a token is, what a plan includes, how costs are charged per operation.
  • Total price including VAT, the currency, and for subscriptions the renewal price and period.
  • Payment and performance method, and when the invoice is issued.
  • That the withdrawal right does not apply and why, with the consumer's approval recorded.
  • Complaint channels: seller contact, consumer arbitration committees, consumer courts, and the monetary thresholds that decide which applies.

The preliminary information form carries these items; the distance sales agreement repeats them as contract terms. Both must be available to the consumer in a durable form after purchase, which in practice means a page they can open from their account and an email.

Subscriptions

A subscription is a continuing contract. The Regulation and the law on subscription contracts require that cancellation be at least as easy as signing up, that the consumer can cancel through the same channel, and that the seller confirms the cancellation. Automatic renewal must be disclosed before the first payment. A seller that hides the cancel button, or requires a phone call to cancel an online subscription, is exposed regardless of what the agreement says.

Tokens

Tokens are a prepaid unit for services. They should have no expiry while the account is active, or a clearly disclosed one; a silent expiry is an unfair term. Charges per operation must be visible before the operation starts, and failed operations must be refunded to the wallet automatically. Whether tokens are refundable in money is a policy choice; the law only requires that the policy be disclosed.

A policy consumers accept

Going beyond the law costs little and removes friction. Refund entirely unused token packs within fourteen days as a matter of goodwill, even though the exception allows otherwise. Allow subscriptions to be cancelled at any time with access until the period ends and no further charge. Refund tokens automatically for any failure on the seller's side. Publish all of this in plain language in the refund policy, and link it from the payment step.

Consent records

Record which document version the consumer accepted, when, from which application and under which account. Do not edit published versions; when the text changes, publish a new version and ask for acceptance again where the change is material. The record is what proves the withdrawal exception applied and what the seller produces if a dispute reaches an arbitration committee.

Other languages

If the product is sold in several languages, the binding version should be stated. A common approach is to make the Turkish text binding for consumers in Türkiye and provide translations for convenience, with a note on each translation saying so. Where the translation is missing, showing the English text with the same note is acceptable for information, but the consumer must still be able to open the binding text.

Frequently asked

Does the exception cover a subscription bought but never used? Legally yes, if performance began with the consumer's approval. Commercially, refunding an unused first period is cheap goodwill and avoids disputes.

Must the invoice be an e-invoice? For consumers, an e-archive invoice sent by email satisfies the requirement; the seller's own tax status decides the format.

Where do disputes go? Below the annual threshold, to the consumer arbitration committee of the consumer's district; above it, to the consumer court. The thresholds are updated every year and should not be hard-coded into the documents.

This article is general information, not legal advice.