Football Agent Regulation in Turkey: Developments since Law No. 7405 (2026 Update)

October 27, 2026 · Mosturoğlu & Çopuroğlu

This article is the 2026 update of our July 2022 article “New Sports Law: What Lies Ahead for Football Agents?”.

Introduction

Additional Article 2, added to Law No. 5894 on the Establishment and Duties of the Turkish Football Federation by Law No. 7405 on Sports Clubs and Sports Federations, introduced formal requirements, a maximum term and fee caps for agency contracts. In our 2022 article, we assessed the impact of these rules on the agency market. In the four years since, fundamental changes have taken place both in the regulations of the Turkish Football Federation (“TFF”) and in FIFA’s agent rules. In this article, we summarise the legal framework applicable to football agents as of 2026.

1. Statutory Framework: Additional Article 2 of Law No. 5894 Remains in Force

Additional Article 2 remains in force in its 2022 form. Accordingly:

• Agency contracts may be concluded for a maximum of two years and must be executed before a notary; for minors, the signature of a parent or guardian is required.
• The contract must contain the names of the parties, the date and term, the scope of the agency services, the fee, payment terms, termination provisions and the signatures of the parties. If services are provided by a company, the company’s details and trade registry documents must be attached.
• Notaries must send signed agency contracts to the Ministry of Youth and Sports and the TFF within 30 days.
• The fee of an agent representing a player may not exceed 10% of the player’s annual base gross income, or 5% where that income exceeds TRY 2 million. An agent representing a club transferring a player may agree a fee of up to 10% of the transfer fee received by the club.
• Where any legal transaction other than the notified contract providing a benefit to the parties or third parties is identified, the agent’s activity is terminated, the player is suspended from matches for three months to one year, and the club officials concerned are disqualified. Club officials who breach the fee caps face imprisonment of one to three years, and agents face cancellation of their licence.

Our assessment: The TRY 2 million threshold in the Law has not been updated since 2022. Owing to inflation in the meantime, most professional football contracts are now in practice subject to the 5% upper tier. Because the threshold is not indexed, the tiered structure intended by the Law has effectively become inoperative.

The Constitutional Court’s decision of 17.06.2025 (E.2022/85, K.2025/131; Official Gazette 02.04.2026, No. 33212), which annulled certain provisions of Law No. 7405, covers rules such as the appointment of TFF Arbitration Board members and the determination of professional athletes’ status by the federations. Most of the annulments will take effect nine months after publication. The decision does not annul any of the agency provisions of Additional Article 2.

2. Developments in TFF Regulations

The 2023 Regulations replacing the 2015 Regulations

The Regulations on Working with Football Agents of June 2015, which we described as being in force in our 2022 article, were replaced by the Football Agents Regulations adopted by the TFF Board on 01.11.2023 and published on 21.11.2023. Modelled on FIFA’s agent rules, these Regulations:

• required agents to obtain a FIFA agent licence first and then register with the TFF in order to work in Turkey; licences of persons without a FIFA licence expired on 01.10.2023;
• required agency companies to be incorporated as joint-stock companies;
• introduced fee caps consistent with international rules, rules on dual representation and payment of fees through the FIFA Clearing House.

Annulment by the Arbitration Board and repeal of the Regulations

The Regulations were short-lived. Upon an application by a club, the TFF Arbitration Board annulled in January 2024 the scope provision, the definitions of “gross income” and “agency contract”, the provisions on fee payments and fee caps, the notification and publication obligation and certain sanction provisions. The TFF Board then repealed the Regulations at its meeting of 10.01.2024 (announced on 12.01.2024). The decision referred to FIFA’s suspension of key provisions of its own rules by Circular No. 1873 of 30.12.2023 and to the Arbitration Board’s annulment decision, stated that the provisions of Additional Article 2 of Law No. 5894 remain reserved, and announced that new regulations would be prepared in light of FIFA’s future decisions.

As far as we have been able to determine, no new TFF agent regulations have been published as of the date of this article to replace the repealed Regulations. The core national rule for agency activity in Turkey is therefore the statutory Additional Article 2.

3. FIFA Football Agent Regulations (FFAR): Entry into Force, Suspension and CJEU Judgments

The FIFA Football Agent Regulations (“FFAR”) entered into force on 09.01.2023 for the licensing provisions and on 01.10.2023 for the remaining provisions. They introduced fundamental changes such as a mandatory licensing exam, continuing professional development, fee caps, the “client pays” principle and a ban on dual representation.

The FFAR were soon challenged in court in several countries. In Germany, the Dortmund Regional Court granted an interim injunction in May 2023 against the fee cap, the “client pays” principle and the dual representation ban; similar interim relief was granted in Spain. CAS, by contrast, dismissed the agents’ challenge in July 2023. Following these developments, FIFA suspended worldwide, by Circular No. 1873 of 30.12.2023, the provisions on the fee cap, the “client pays” principle, the dual representation ban and the uploading and publication of transactions on the FIFA Agent Platform, pending the outcome of the cases before the Court of Justice of the European Union (“CJEU”). The licensing requirement, the exam, continuing professional development and national registration remain in force.

In summer 2026, the CJEU delivered two important judgments: C-428/23 (ROGON) of 09.07.2026 and C-209/23 (RRC Sports) of 16.07.2026. In these judgments, the Court assessed sports federations’ agent rules under EU competition law and the applicable proportionality review. However, the judgments did not automatically reinstate the suspended FFAR provisions; the cases before the national courts are still to be decided on the merits. FIFA has announced that it will consult agents’ representatives. FIFA’s new transfer system, planned to start on 01.01.2027, is seen as the next key milestone for the future shape of the rules.

4. Practical Implications

As things stand, agency activity in Turkey is subject to a two-tier framework developing at different speeds:

• National tier: The formal requirements, two-year maximum term, notary and notification obligations and fee caps in Additional Article 2 remain valid as statutory provisions, irrespective of FIFA’s suspension. Breaches may have serious consequences such as imprisonment and licence cancellation.
• International tier: The FIFA licence and national registration requirements continue to apply, while contested FFAR provisions such as the fee cap and the dual representation ban are suspended.

It is therefore important for clubs, players and agents to execute agency contracts before a notary for a maximum of two years, to comply with the fee caps, to notify contracts in time and not to enter into any side arrangements outside the notified contract. In international transfers, it should always be verified whether the agent holds a valid FIFA licence.

Conclusion

The objectives of transparency and legal certainty that we welcomed in 2022 have been preserved at statutory level but have turned into uncertainty at the level of secondary regulation. The gap left by the repeal of the TFF regulations, combined with uncertainty about the future of FIFA’s rules, means that practice now relies largely on the statutory provisions directly. Updating the TRY 2 million threshold in the Law and publishing TFF regulations consistent with FIFA’s new rules are necessary to restore legal certainty in this area. We will continue to monitor closely FIFA’s next steps following the CJEU judgments and the TFF’s work on new regulations.