What Did Law No. 7590 Change in Maritime Affairs?

Law No. 7590, titled “Law on Amendments to Certain Laws and Decree-Laws,” was published in the Official Gazette dated July 31, 2026, and numbered 33326, entering into force on the same day. The law has two provisions directly concerning the maritime sector:

• Article 29: It added Article 28/A, titled “Administrative Fines,” to the Decree-Law No. 655 dated 26/9/2011, on Certain Regulations Regarding the Field of Transportation and Infrastructure.
• Article 30: It added Article 28/B, titled “Fees to be Deposited to the Revolving Fund Enterprise Account,” to the same Decree-Law.

Article 28/A is gathered under three main paragraphs:

1. Those related to the regulation of transportation services,
2. Those operating in the field of sea and inland waterway transportation,
3. Those operating in the field of shipyards and coastal structures.

Under these paragraphs, separate sanctions were determined for maritime safety, seafarers, ship agents, port and coastal facilities, shipyards, ship recycling facilities, dredging activities, passenger transportation, and maritime tourism.

The fact that the text numbered 655 still bears the name “Decree-Law” might be confusing. However, the source of 28/A and 28/B is not an executive act, but Law No. 7590 accepted by the Grand National Assembly of Turkey (TBMM). This means that the basis for the new penalties is now directly a law.

Are These Penalties Being Introduced to the Maritime Sector for the First Time?

No, for the most part. A significant portion of obligations such as minimum safe equipment, alcohol limits, seafarer and agent discipline, technical requirements for private vessels, Green Port, vessel registration, ship construction and modification, and dredging and shipyard permits already existed in regulations.

What has changed is this: For the first time, which acts will be penalized, to whom the penalties will be applied, and what their lower and upper limits will be, have been collectively specified in a law passed by the Turkish Grand National Assembly. A few examples:

• The penalty per meter for private vessels was already present in the regulation dated January 17, 2026.
• A penalty of 5,000 TL per hour for facilities not obtaining a Green Port Certificate had been introduced by the regulation dated March 24, 2026. The law maintained this amount and added an annual upper limit of 10 million TL per facility.
• Meter-based penalties in ship construction and modification existed in the regulation dated January 14, 2026. The law placed these within a legal range and considered the facility owner, ship owner, classification society, and control engineer directly liable.

Therefore, it is more accurate to describe the resulting situation not as a “new penalty system from scratch” but as legislating, updating, and partial re-regulation. Nevertheless, new or expanded consequences have arisen in areas such as missing seafarers, alcohol-related penalties, disciplinary penalties, the Green Port annual ceiling, and vessel registration delay penalties.

Why Did the Constitutional Court Annul the Old Penalty System?

At the root of the regulation is the Constitutional Court’s decision numbered E.2024/54, K.2025/163, dated 22/7/2025.

The former Article 28 of Decree Law No. 655 granted relevant general directorates the authority to “stipulate” administrative monetary penalties of up to 1 million TL and 5 million TL. However, which act would be penalized by what amount was largely left to regulations and the administration’s discretion.

The Constitutional Court did not find merely indicating a general upper limit sufficient. It determined that the penalized acts were not sufficiently defined in the law and that there were no objective criteria limiting the administration’s discretion. It found the rule to be contrary to Article 2 of the Constitution (rule of law and certainty) and Article 38 (legality of crimes and penalties).

Since the Court deemed the resulting void to be contrary to public interest, it postponed the effective date of the annulment for nine months. The decision published on December 9, 2025, would have entered into force on September 9, 2026. Law No. 7590 established the new legal framework before this date, on July 31, 2026.

How Much Administrative Fine Will Be Imposed for Which Violation?

The tables below show the main violations under 28/A in groups. Amounts are in Turkish Liras.

Seafarer, Safety, and Inland Waters

Agencies, supervision, survey, and cargo

Port, coastal facility, ISPS, and Green Port

Shipyard, construction-renovation, and dredging

Note: The tables have been summarized based on official and sectoral announcements related to the text of Law No. 7590 published in the Official Gazette. In a specific case, the current version of the article text should be checked separately. In accordance with the general rule in Article 17/7 of the Misdemeanors Law, administrative fine amounts may be updated at the beginning of each calendar year according to the revaluation rate.

How is the Under-manning Penalty Calculated?

This is the most debated provision of the new regime. If a ship is not manned with the number and qualifications of crew members specified in the minimum manning certificate or relevant legislation, a penalty of 250,000 TL will be applied for each missing crew member. The amount is fixed, not subject to lower or upper limits.

This provision does not take into account hull length, passenger capacity, operational area, or the scale of the business. A day-trip boat operating with two or three personnel faces the same fixed amount as a large cargo ship.

What to look for in defense?

• What was the minimum equipment certificate at the time of detection, and for which type of voyage was it issued?
• Was the person considered “missing” truly not on board, or is the document or qualification disputed?
• Was the vessel underway at the time, or was it in port, under maintenance, or moored?
• Whether a penalty was issued to the same person for the same incident under multiple provisions (Misdemeanor Law, Article 15 rules on accumulation of offenses).

What Should Private Boat and Yacht Owners Pay Attention To?

Sea tourism and private boat owners are directly affected by the new regulation. A significant portion of the penalties is calculated per meter based on the vessel’s overall length.

Technical requirements and user proficiency

For private boats with a hull length between 2.5 – 24 meters and private yachts over 24 meters that fall within the definition, in case of non-compliance with technical requirements and user proficiency, a penalty of 1,000 – 2,500 TL per meter is applied. For example, for a 12-meter vessel, the penalty is set in the range of 12,000 – 30,000 TL.

Voyage permit and border gate procedures

If sea tourism vehicles other than cruise ships do not obtain a voyage permit, enter or exit without completing border gate procedures, or fail to report changes in the document, a meter-based penalty will be applied:

• For vehicles smaller than 10 meters, 100 TL per meter,
• Between 10 – 25 meters, 500 TL per meter,
• For 25 meters and above, 1,000 TL per meter.

Mooring registry certificate

In case of violation of the obligations regarding registry record, valid license, notification of change, marking of name and port of registry, presentation of the license, and flying the Turkish flag, a penalty of 5,000 – 50,000 TL is imposed on the owner or operator.

If there is no valid license at all, in addition to the main penalty, an additional 1,000 – 10,000 TL is added for each month of delay, starting from the date the license should have been issued or renewed. Delays shorter than one month are rounded up to one month. For boats whose licenses have not been renewed for years, this item can multiply and greatly exceed the main penalty.

In disputes regarding marina and pier fees, you can also refer to our article titled what happens if yacht or ship owners do not pay pier or marina fees regarding the collection of receivables.

Are New Penalties Applied to Violations Before July 31, 2026?

As a rule, no. In accordance with Article 38 of the Constitution and Article 5 of the Misdemeanors Law, the law in force at the time the act was committed is applied. A regulation that comes into force later can only be applied retroactively if it is in favor of the person. Heavier new amounts cannot be enforced for acts completed before July 31, 2026.

On the other hand, since Constitutional Court (AYM) annulment decisions are not retroactive, it cannot be said that all penalties imposed based on the old provision are automatically invalid. In each case, these four questions should be asked separately:

1. When was the act committed or concluded?
2. Based on which provision was the penalty imposed?
3. Has the decision become final?
4. Which of the old and new regulations is more favorable?

What to Do When an Administrative Fine is Notified?

Unless a separate application method is stipulated in a special law, the general rule is the Misdemeanors Law numbered 5326:

• Time limit and authority: An application must be made to the criminal judgeship of peace within a maximum of 15 days from the notification or promulgation of the decision (Art. 27/1). If the time limit is missed, the penalty becomes final.
• Force majeure: If the time limit was missed due to force majeure, an application can be made within 7 days from the cessation of the cause.
• If there are other administrative sanctions: If the penalty was issued along with a decision falling within the jurisdiction of administrative justice, such as suspension of activity or cancellation of a document, a joint lawsuit against both must be filed in the administrative court (Art. 27/8).
• Advance payment: According to the general rule in Article 17/6 of the Misdemeanors Law, if the fine is paid within 15 days from notification, three-fourths of it will be collected (a one-fourth discount). This payment does not eliminate the right to object.

What Grounds of Illegality Can Be Raised in an Objection?

The new system has initiated an era where penalties will be directly reviewed based on legal grounds, clarity, and proportionality. The main grounds for objection are as follows:

1. Non-compliance of the act with the definition in 28/A: Does the act recorded in the report meet the elements of the act listed in the article?
2. Wrong addressee: The law sometimes addresses the vessel, sometimes the owner or operator, sometimes the captain, the classification society, or the control engineer. Issuing the penalty to the wrong person is a ground for annulment.
3. Unjustified discretion between minimum and maximum limits: In wide ranges such as 850,000 – 8,250,000 TL, the reason for determining the penalty at that amount must be justified with concrete criteria. Article 17/2 of the Law on Misdemeanors requires that the content of the unlawfulness, fault, and economic situation be considered together.
4. Application regarding time: Application of the new amount to acts or months prior to its effective date.
5. Regulation exceeding the law: A penalty cannot be imposed based on a regulation that conflicts with the law or exceeds legal limits. The adaptation of secondary legislation to 28/A may not yet be complete.
6. Deficiencies in report and determination: Lack of date, place, measurement method, witnesses, and documents.
7. Ambiguous concepts: In penalties based on expressions such as “principles determined by the Ministry” or “maritime customs and traditions,” it should be questioned whether the specific rule was knowable beforehand.
8. Claim of Proportionality and Unconstitutionality: The fact that the scale of the business is not considered at all in fixed-amount penalties can be raised as a claim of unconstitutionality before the appeal authority.

What Changed in Document and Service Fees with 28/B?

28/B regulates a matter separate from administrative fines: the document and service fees collected by the Ministry. It is now stipulated in the law that authorization certificates, permits, licenses, registrations, approvals, and safety documents; seaworthiness certificates, vocational qualification documents, ship surveys and inspections, dredging, technical testing, and training fees shall be deposited into the Ministry’s revolving fund account.

Behind this, there is also a Constitutional Court decision. In its decision numbered 15/1/2026, E.2025/167, K.2026/13, the Constitutional Court considered the document fees regulated by Presidential Decree as “duties” and test and control fees as “charges”. It ruled that these obligations, falling under Article 73 of the Constitution, cannot be regulated by Presidential Decree and postponed the effective date of the annulment to January 3, 2027.

28/B indicates the legal basis for collection and the account into which it will be deposited, but it does not specify concrete tariffs and fee amounts.

Why is the Sector Objecting to the New Penalties?

The first reaction came from the maritime tourism sector. The International Yachting Professionals Association (PYI Global) and the Bodrum Seafarers’ Association found the subjection of commercial yachts to the same sanction regime as large merchant ships to be contrary to the principles of proportionality and fairness.

At the center of the criticisms is a fixed fine of 250,000 TL per missing crew member. Sector representatives are demanding a tiered system based on boat length, passenger capacity, and operational scale, and the separate evaluation of maritime tourism vessels.

These demands have not yet resulted in a change. The text currently in force continues to be applied. In specific cases, the same arguments can be brought before the court as an objection of proportionality and unconstitutionality.

Compliance Checklist for Ship Owners and Operators

As failure to provide information or documents during an inspection is punishable by a fine of 50,000 – 500,000 TL, keeping documents accessible at the time of inspection is of particular importance. The Ministry may now also request financial documents, including e-invoices.

For the basic framework regarding maritime claims and ship arrest, you can refer to our ship arrest page and other articles in the maritime law category.

Frequently Asked Questions

When did Law No. 7590 come into force?

It was published in the Official Gazette dated July 31, 2026, and numbered 33326, entering into force on the same day. Articles 28/A and 28/B are also applied as of this date.

Who is fined for insufficient crew?

The law applies the penalty to the ship. The amount is 250,000 TL for each missing crew member and is fixed, not subject to upper or lower limits.

How much is the penalty for a seafarer due to alcohol?

A seafarer who exceeds the limit specified in the law (BAC 0.05% or 0.25 mg/ml) is subject to an administrative fine of 50,000 TL.

Where can one object to a maritime administrative fine?

Unless there is a specific regulation, an appeal must be made to the criminal judgeship of peace within 15 days from the notification, in accordance with Article 27 of the Misdemeanor Law. If the penalty was issued along with another decision within the jurisdiction of administrative judiciary, a lawsuit is filed in the administrative court. The authority specified in the notification document must be checked.

If I pay the fine, do I lose my right to object?

No. According to the Misdemeanor Law, even if a discounted payment is made within 15 days from the notification, an objection can still be filed within the period. If the objection is accepted, a refund of the paid amount can be requested.

Can a new retroactive fine be issued for my boat whose license has not been renewed for years?

Calculating the monthly late payment penalty based on the new and heavier amount for months prior to July 31, 2026, is debatable due to the principle of non-retroactivity of laws to the detriment of the individual. The absence of a specific transitional provision in the law in this regard is an important ground for objection.

Have penalties issued under the old regulation been canceled?

Not automatically, no. Constitutional Court (AYM) annulment decisions are not retroactive. However, the date of the act, the basis of the penalty, the finalization status, and a comparison with favorable regulations should be evaluated separately for each case.

Is the Green Port penalty unlimited?

No. 5,000 TL is applied for every hour each moored vessel remains, but the total penalty that can be imposed on a coastal facility in a calendar year cannot exceed 10 million TL.

What is the highest maritime penalty in the law?

The range of 850,000 – 8,250,000 TL stipulated for unauthorized or rule-breaking dredging activities in seas and inland waters is among the highest amounts.

How is the penalty amount between the lower and upper limits determined?

The administration must evaluate the content of the wrongdoing, the fault, and the economic situation of the perpetrator together and state the reasons in its decision. Imposing a penalty close to the upper limit without justification within broad ranges is a ground for objection.

Why is Expert Lawyer Support Necessary?

Maritime administrative fines introduced by Law No. 7590 can result in hundreds of thousands, sometimes millions of liras, with a single report. The appeal period being only 15 days necessitates a swift review of which provision, to whom, and on what date the fine was issued. Issues such as recipient error, unsubstantiated discretion, application of new amounts to months prior to enforceability, or a regulation exceeding the law, only emerge when the report, ship documents, and legislation are read together.

2M Hukuk Law Office, based in Tuzla, operates in the field of maritime trade law around ports, shipyards, and marinas in Tuzla, Pendik, Kartal, and Maltepe on Istanbul’s Anatolian Side; and in Gebze, Çayırova, Darıca, Dilovası, Körfez, and İzmit in Kocaeli. We manage administrative fine appeals, administrative court cases, and compliance audit processes on behalf of shipowners, ship operators, agents, shipyards, marina operators, and private boat owners.

A document and process review conducted before the fine report is served can also significantly reduce risks. You can request a consultation via our contact page to jointly evaluate your business’s situation regarding Article 28/A under headings such as minimum equipment, registry of vessels, Green Port, and agency tariffs.