What the Information and Communication Security Guide requires of institutions
The scope of Circular No. 2019/12 and the Information and Communication Security Guide, asset groups, criticality levels, the audit obligation, and what must be required of the contractor in software procurement.
- Cybersecurity
- Legislation
- Public sector
IN SHORT
- 01The Guide covers public institutions that have an IT unit or receive this service from third parties, and critical infrastructure operators; its current version is 1.1, dated March 2026.
- 02Institutions group their assets under six main headings, determine the criticality level of each group, and carry out a compliance audit at least once a year.
- 03In software procurement, security requirements, a no-backdoor undertaking, security testing, domestic hosting, and log management must be stated explicitly in the specification.
The minimum security measures that public institutions must take in their information systems have been set out by a Presidential Circular published in 2019 and the Information and Communication Security Guide prepared on the basis of that Circular. The Guide directly concerns both the institution's own infrastructure and the software it procures or has developed externally.
This article addresses the current status of the Circular and the Guide, the implementation process expected of institutions, and the matters that must be required of the contractor in software procurement, based solely on the provisions contained in the official texts.
The basis of the Circular and the current version of the Guide
Presidential Circular No. 2019/12 on Information and Communication Security Measures was published in the Official Gazette dated 6 July 2019 and numbered 30823. In addition to a list of 21 measures, the Circular provides for the preparation of a Guide containing different security levels, for compliance with the Guide in information systems newly established at all public institutions and enterprises providing critical infrastructure services, and for existing infrastructure to be brought into compliance gradually.
The first version of the Guide was published by the Digital Transformation Office in July 2020. The Siber Güvenlik Başkanlığı, established by Presidential Decree No. 177, took over the Office's duties in the field of cyber security; with the Cyber Security Law No. 7545, published on 19 March 2025, the Office's implementation and inventory in this field were transferred to the Directorate. The current version of the Guide is version 1.1, dated 1 March 2026. The version notes give the reason for the change as the design and institutional changes made to the document owing to the transfer of authority. The Guide and the Audit Guide are now published on the website of the Siber Güvenlik Başkanlığı.
Scope, asset groups, and criticality levels
The Guide covers institutions and organisations within the state structure that have an IT unit or receive IT services from third parties under contracts, and enterprises providing critical infrastructure services. Institutions group their assets under six main headings defined in the Guide: Network and Systems, Applications, Portable Devices and Media, Internet of Things (IoT) Devices, Physical Premises, and Personnel.
The criticality level of each asset group is determined through a questionnaire that takes into account the importance of the data processed in terms of confidentiality, integrity, and availability, as well as dependent assets, the number of people affected, and institutional, sectoral, and societal consequences. A questionnaire score below 18 is treated as Level 1, between 18 and 28 as Level 2, and 28 or above as Level 3. Measures also come in three levels: basic, intermediate, and advanced. Level 1 groups receive basic measures, Level 2 groups receive basic and intermediate measures, and Level 3 groups receive all three levels.
Based on this rating, the institution carries out a current-state and gap analysis, prepares an implementation roadmap to remedy deficiencies, and, with senior management approval, may apply compensating controls with the same purpose and effect for measures that cannot be met due to technical constraints.
Audit obligation
Except for activities falling within the scope of national security and the protection of confidentiality, the Circular requires institutions to establish audit mechanisms and to audit the implementation of the Guide at least once a year. The Guide states that audits will be carried out on the basis of the Information and Communication Security Audit Guide.
According to the frequently asked questions document of the Siber Güvenlik Başkanlığı, institutions submit audit results to the Directorate through the Information and Communication Security Compliance and Audit Monitoring System (BİGDES) within two months of the date the audit report is signed. The relevant sections of the report are signed with a secure electronic signature by the senior executive or personnel authorised by them.
What must be required of the contractor when procuring or having software developed
Articles 12 and 13 of the Circular, together with the Guide's headings on application security, cloud computing, and procurement, directly determine the matters that the institution must require of the contractor in software procurement. The following items must be written into the technical specification and the contract, and checks must also be carried out against these items at the acceptance stage.
METHOD NOTE
- Security requirements
- Security requirements must be included in the technical specifications of procured applications or applications developed through service procurement (Measure 3.2.6.1).
- No-backdoor undertaking
- An undertaking should be obtained, as far as possible, from the manufacturer or supplier stating that the software does not contain any feature or backdoor inconsistent with its intended purpose (Circular Article 12, Measure 3.2.6.3). A sample undertaking is included in Annex C.6 of the Guide.
- Security testing
- Procured or developed software must undergo security testing before use (Circular Article 13). Penetration testing must be carried out on procured applications (Measure 3.2.6.6), and applications whose source code the institution holds must undergo source code analysis before going live (Measure 3.2.6.7, medium level).
- Test verisi
- Real data must not be used in development and test environments; test data suited to the purpose must be generated (Measure 3.2.6.2).
- Hosting and data location
- Critical data such as population, health and communication records and genetic and biometric data must be stored securely within the country (Circular Article 1). Institutional data may not be stored in cloud storage services other than the institution's own dedicated systems or domestic service providers under the institution's control (Circular Article 3). Where a cloud service is used, the domestic storage of critical data must be guaranteed, and encryption keys must be managed by the institution (Measures 4.3.1.1 and 4.3.1.7).
- Log management
- For authorisation and user changes and for authentication operations, the application must generate audit logs containing the user who performed the operation, the time of the operation, the source and destination system, and a summary of the operation; it must not allow these logs to be altered or deleted, and must not generate logs containing special categories of personal data (Measures 3.2.8.2, 3.2.8.3, 3.2.8.5).
- Supply chain and acceptance
- Information security requirements must be added to contracts, a written document on supply chain security must be obtained, acceptance criteria must be agreed with the contractor in advance, and if a subcontractor is used, responsibilities must be documented (Measures 3.5.3.3, 3.5.3.4, 3.5.3.5, 3.5.3.8).
In addition, the Guide requires that client and server technologies whose technical support has ended, or that contain security vulnerabilities, not be used (Measure 3.2.6.5), and that Turkish language support be provided in the interface of developed applications (Measure 4.6.1.4). Carrying out penetration testing and security audits on institutional systems at least once a year is defined as an intermediate-level measure (Measure 3.1.11.8).
Sequence to follow in preparing the specification
Which of the measures in the Guide are mandatory depends on the criticality level of the relevant asset group. Preparation of the specification should therefore begin by determining which asset group the software to be procured falls under and the level of that group. The measures corresponding to that level, together with the headings relating to application and technology areas (such as personal data security, cloud computing security, new developments, and procurement), should then be carried over into the specification and the acceptance test plan.
“Compliance with the procedures and principles set out in the Guide is mandatory for new information systems to be established in all public institutions and organisations and in enterprises providing critical infrastructure services.”
Tracking the current version
The Guide is updated as a living document; it is stated that both its past and current versions can be accessed from the website of the Siber Güvenlik Başkanlığı. When the Guide is referenced in specifications, it is recommended that the version number be stated and that the version in force on the tender date be taken as the basis.
Sources
- Presidential Circular No. 2019/12 on Information and Communication Security Measures (Official Gazette, 06.07.2019, No. 30823)
- Information and Communication Security Guide, Version 1.1 (Siber Güvenlik Başkanlığı, March 2026)
- Information and Communication Security Activities: Frequently Asked Questions (Siber Güvenlik Başkanlığı, 2026)
- Information and Communication Security Guide and Other Requirements (Siber Güvenlik Başkanlığı)
- Cyber Security Law No. 7545 (Mevzuat Bilgi Sistemi)
This article has been prepared for general information purposes only and does not constitute legal, financial, technical or other professional advice. Legislative and technical information reflects the position as at the date of publication. Short extracts may be quoted provided that the source is cited and a link to the article is given; publication of the article in full or of a substantial part of it is subject to written permission. Terms of use
