"In Advertising, What You Don’t Say Can Be Just as Legally Significant as What You Do Say!"

On April 17, 2025, the Advertising Board ("the Board"), operating under the Ministry of Trade, convened for its 356th meeting to review a wide range of commercial advertisements and marketing practices. Following its evaluations, the Board imposed various administrative sanctions on advertising activities that were found to violate the applicable legislation. One of the key principles emphasized in the Board’s assessments was the obligation to provide accurate and sufficient information to consumers in accordance with the rules of honesty and transparency.

In this article, we examine two distinct advertising cases published through different media channels but sanctioned on similar legal grounds, focusing on consumer protection implications.

1. TRY 863,580 Fine Imposed on an Automotive Company

   Media: Instagram & Official Website

   Campaign Message:“... TRY 1,000,000 0% interest loan offer – Don’t miss this once-in-a-million chance!”“Credit Advantage Up to TRY 1,000,000”

   Violation: Misleading and contradictory information

   
   

Why Was the Fine Issued?

Although the campaign prominently promoted a “0% interest” credit offer, it failed to disclose the total cost of the loan, including the annual and monthly percentage rates. Additionally, the credit opportunity was actually limited to commercial customers, yet this critical restriction was not mentioned alongside the main promotional message.

The Board decided that this lack of transparency and omission of key terms misled consumers, violating the principles of honesty and transparency. As a result, the company was ordered to cease the campaign and pay an administrative fine of TRY 863,580 (approx. EUR 18,800 based on the exchange rate as of June 24, 2025).

2. An Incomplete In-Store Campaign Received an TRY 86,358 Fine

   Media: Poster (In-store, shopping mall)

   Campaign Message:“Free suitcase with purchases over TRY 3,000” — illustrated with three different suitcase sizes

   Violation: Lack of information about campaign conditions

   
   

Why Was the Fine Issued?

The campaign featured visuals of small, medium, and large suitcases but failed to disclose that the gift varied based on the purchase amount -small suitcase: TRY 3,400, medium suitcase: TRY 3,500, large suitcase: TRY 4,000-. By omitting these distinctions in the promotional material, consumers were misled into believing that all suitcase sizes were available with purchases over TRY 3,000.

The Board deemed this campaign as a misleading practice and imposed an administrative fine of  TRY 86,358 (approx. EUR 1,880 based on the exchange rate as of June 24, 2025) along with the order of cease of the campaign.

The EYAS Perspective: Compliance First, Creativity Second

While attention-grabbing design and creative messaging are essential in advertising, they should never come at the expense of compliance with consumer protection laws.

Let’s not forget: the primary subject safeguarded by advertising regulations is the consumer.

To ensure legally fulfilled and ethically responsible advertising:

• Campaign terms must be clearly and prominently disclosed,

• Language should be plain and understandable,

• Vague or potentially misleading phrases should be strictly avoided,

• And most importantly, ads should undergo legal review before being published.

At EYAS Legal Consultancy, we assist brands and creative agencies in navigating advertising regulations to create campaigns that are legally compliant.