Major Transformation in Ship Agency Services

The ship agency sector has been operating under the Regulation on Ship Agencies published in the Official Gazette dated 5 March 2012 and numbered 28224 for approximately 14 years. This regulation essentially adopted an approach that was "encouraging and outlined general principles." However, the new Regulation on Ship Agencies, published in the Official Gazette dated 14 May 2026 and numbered 33253, fundamentally changes this approach. The new regulation introduces a system based on digital infrastructure, with clearly defined standards, financial adequacy requirements, higher personnel qualifications, and deterrent sanctions. With these changes, the sector stands on the threshold of a fundamental transformation after 14 years.

Most provisions of the regulation will enter into force three months after its publication, namely on 14 August 2026. Existing ship agencies are granted a transition period, and their current certificates will remain valid until their expiry dates. However, this period is limited to a maximum of one year from the regulation's effective date, meaning that all agencies must transition to the new system no later than 14 August 2027. For the issuance of new certificates, both existing and newly established agencies will be required to comply with all conditions, including capital requirements, personnel qualifications, and office standards.

As the regulation has only recently been introduced, these changes currently constitute one of the main topics on the sector's agenda.

The Scale of the Sector: How Many Agencies Will Be Affected?

To understand the extent of the regulation's impact, it is sufficient to examine the records of the Ship Agencies Information System (GABS) maintained by the Administration (Directorate General of Maritime Affairs). According to the current data, there are a total of 1,677 registered ship agencies across Türkiye, of which 1,399 are headquarters and 278 are branch offices.

The geographical distribution of agencies reveals a significant concentration. Istanbul alone accounts for 623 registrations, representing approximately 37% of the entire sector. It is followed by Muğla (207), İzmir (192), Mersin (162), and Hatay (119). Together, these five provinces account for approximately 72% of all registered agencies. At the same time, the remaining registrations spread across Türkiye's four surrounding seas demonstrate that the sector truly operates through a nationwide network.

When examined on a port basis, the picture becomes even more striking. The Port of Istanbul ranks first with 434 registered agencies, while Tuzla, known as Türkiye's principal shipbuilding region, ranks second with 170 registrations. Mersin (154), İzmir (122), and İskenderun (119) complete the ranking. These figures clearly illustrate how the new regulation's requirements regarding personnel, capital thresholds, and mandatory office standards may have a particularly significant impact on small-scale agencies operating in major port centres.

The concentration of branch offices also presents a remarkable picture. Approximately 56% of the country's 278 branch offices are concentrated in only three provinces: İzmir, Mersin, and Hatay. Under the new regulation, any suspension imposed on a headquarters will automatically apply to its branches as well, making this provision a critical risk for agencies operating extensive branch networks in these regions.

**“End of the “Open Access License” Era: A, B and C Class Agencies**

Under the previous regulation, there was a single type of authorization certificate. Although there were geographical limitations, there was no classification defining the scope or quality of services. The most visible change in the new regulation is the introduction of three separate classes.

A Class agencies hold the widest authorization, allowing them to provide services to all ships and yachts, including those operating in the Turkish Straits. B Class agencies are excluded from the Turkish Straits but are authorized to serve commercial vessels in territorial waters and all yachts, including those in the Straits. C Class agencies are limited exclusively to yacht agency services.

This classification also establishes a framework that directly determines capital requirements, mandatory personnel qualifications, and certificate fees. Choosing which class to operate under has now become a matter of business strategy.

This alphabetical naming system also creates a sense of hierarchy among agencies, especially outside the Straits. For example, two agencies operating in the Port of İzmir—one A Class and one B Class—actually have the same authority in terms of commercial vessels in that region, yet one can still present itself as an “A Class” agency.

Capital Requirements and Certificate Fees: A New Financial Threshold for the Sector

Under the previous regulation, there was no concept of minimum capital requirement. Under the new framework, paid-in capital is now mandatory: 5 million TL for A Class, 1 million TL for B Class, and 500,000 TL for C Class agencies. Agencies wishing to open branches must additionally maintain capital per branch: 100,000 TL for A Class, 75,000 TL for B Class, and 50,000 TL for C Class. These amounts will be updated annually in line with the revaluation rate under the Tax Procedure Law, and updated capital certificates must be submitted to the Administration during inspections. This creates an additional administrative burden and cost for agencies.

Certificate fees have also been increased, set at 300,000 TL for A Class, 200,000 TL for B Class, and 150,000 TL for C Class, while renewal fees are set at 50% of the original certificate fee.

This regulation aims to improve financial transparency in the sector and eliminate low-capital entities often referred to as “briefcase agencies.” It is clear that the threshold creates a significant entry barrier, particularly for small-scale entrepreneurs. It appears that the Administration now expects a more responsible and competent level of representation in this critical field.

Office Standards: The End of Home Office and Virtual Address Era

The new regulation introduces strict rules regarding office requirements. Agencies must operate from a separate and exclusive office, and multiple agencies are not allowed to operate from the same premises. Residential or virtual addresses are no longer accepted. In addition, the use of a Registered Electronic Mail (KEP) address has become mandatory.

Agency Manager and Personnel Qualifications: Advantage for Graduates, Exception for Experience

The role previously defined as “agency representative” has been redefined as “agency manager” in the new regulation, with significantly expanded responsibilities. Each agency is required to appoint an agency manager, who is directly accountable to the Administration and cannot hold the same position in more than one agency simultaneously.

For A and B Class agencies, the agency manager must have graduated from one of the maritime-related programs listed in the Higher Education Council’s (YÖK) Undergraduate and Associate Degree Atlas and have at least one year of professional experience. An important exception is granted for those who have worked in the agency registry for at least five years: they may be appointed as agency managers without holding a maritime-related degree. This provides a partial safeguard for experienced professionals who have built their careers in the sector from the ground up. The reason this safeguard is only partial will be explained in the next section.

There is another notable detail regarding education requirements: individuals holding a master’s degree, whether thesis or non-thesis, in maritime-related fields are not included in this exemption framework. The system clearly prioritizes undergraduate and associate degree programs and does not separately recognize postgraduate qualifications. The Administration’s acceptance of programs requiring at least two years of formal education suggests a reluctance toward non-thesis master’s programs, which can often be completed more quickly and with relatively less academic effort.

There is also a major change regarding personnel training: under the previous regulation, maritime high school graduates were exempt from both training and examinations. In the new regulation, training exemption is granted only to university (bachelor’s and associate degree) graduates. However, these individuals are still required to take the examination.

Status of Experienced Personnel Without Maritime Education

On the other hand, there is another very critical detail. Under the previous regulation, there was only a requirement for “at least one ship agency staff member.” However, the new regulation now introduces the requirement for a ship agency manager and, in A and B class agencies, at least two agency staff members who have graduated from associate or bachelor’s degree programs in maritime-related fields. In C class agencies, at least one staff member with secondary education in maritime-related fields is required.

Now, let’s assume you have been working in an agency for five years. Under this regulation, you can become an agency manager; however, in other positions, you may not be able to be employed as a regular staff member because you do not meet the criteria mentioned in the previous paragraph. This is because in small-scale agencies with 3 or 4 employees, the employment of these experienced individuals who do not come from a maritime education background becomes quite difficult after the mandatory positions are filled.

It is very clear that the purpose of the regulation is to improve the process; however, during this transition period, an exception could have been made regarding existing and experienced personnel. For example, a ship agency employee with 10 years of experience could have been considered equivalent to someone with an associate degree.

The Third Option in the Requirements to Become an Agency Manager

In A and B class agencies, one of three conditions must be met to become an agency manager. I have already mentioned two of them: graduating from a university in the maritime field or having five years of experience. However, the third condition is somewhat confusing. According to this provision, individuals who are the owner of the agency or hold at least 10% partnership (with Turkish citizenship and a clean criminal record) can become agency managers without any education or experience requirement. This creates a contradiction in terms of the intended qualification standards.

The 30% Sub-Agency Rule

In the maritime sector, a large main agency may appoint local agencies (sub-agencies) in different ports in order to manage numerous port calls across Türkiye. These local agencies operate on the ground and carry the entire operational workload. However, the invoice is issued to the main agency, which then issues a single invoice to the shipowner or charterer. In this chain, an imbalance may arise between “those who actually perform the work” and “those who receive the payment.”

The new regulation requires that the appointing agency must pay at least 30% of the total fee determined by the tariff to the sub-agency. In case of non-payment, an administrative fine equal to three times the amount owed to the sub-agency will be imposed.

There is another interesting detail regarding sub-agency authorization. According to the regulation, licensed agencies may receive sub-agency services; however, an agency cannot appoint a sub-agency for a service that it is not authorized to provide within its own class. To explain with an example: according to the regulation, a B class agency in İzmir cannot appoint an A class agency as a sub-agency for a service related to the Straits. Therefore, in such cases, the agency is excluded from national and global competition.

Digitalization: The End of the Paper Era with GABS

The most important tool driving the systemic transformation of the new regulation is the Ship Agency Information System (GABS). In recent years, all applications, document processes, personnel assignments, disciplinary procedures, and administrative sanction decisions were already being handled through this electronic platform. Thus, this process has now been formally incorporated into the regulation.

Online training has also been introduced. Certification and renewal training can now be conducted online via GABS. In other words, the traditional obligation of physical training has been removed.

The introduction of mandatory KEP (Registered Electronic Mail) addresses and the prohibition of residential/virtual offices are also parts of this digital transformation. In an environment where electronic notifications are legally valid, these steps can be seen as an effort to establish an integrated infrastructure.

Discipline and Sanctions

The discipline and sanction provisions show that the Administration now expects correct information and documentation to be submitted at the right time and through the correct procedures. The previous regulation only provided general measures such as suspension or revocation in case of violations, but did not define in detail which violation corresponded to which penalty. The new regulation eliminates this ambiguity. A disciplinary commission is also being established. While the inclusion of NGOs in the Ship Agency Disciplinary Commission (GADK) is positive, it would have been more inclusive if long-established associations such as İzmir or İskenderun Maritime Transporters, Mersin Shipowners and Agencies, and Kocaeli Ship Agencies had also been included.

A staged sanction system has been introduced. For example, in the case of a false declaration, the first violation results in a warning; the second violation leads to suspension of up to three months; the third repetition results in suspension of up to six months; and the fourth violation results in revocation of the authorization certificate.

Fines and suspension periods are defined in detail for each type of violation. For example, an agency that does not comply with the tariff will face a fine of 200,000 TL for the first violation, 400,000 TL for the second. On the third repetition, operations are suspended for 5 to 45 days, and on the fourth, the authorization certificate is revoked. For acts that threaten system security, such as sharing passwords, a fine of 100,000 TL is imposed on personnel for the first violation.

The most severe innovation applies to those who obtain authorization with misleading documents. Under the old regulation, this resulted in a two-year ban; under the new regulation, it has become a permanent ban, meaning that reissuance of an authorization certificate is no longer possible.

According to another critical provision, suspension of the main agency for any reason automatically affects all its branches. However, the reverse does not apply; issues at a branch do not affect the headquarters. For multi-branch structures, this asymmetry represents a new risk factor in operational risk management.

The Ethics Principles Commitment is no longer a formality. The declaration signed during application is now directly linked to penalties: 50,000 TL for violation and 100,000 TL for repetition.

Regulation or Monopoly? A Two-Sided Debate

The strongest argument in favor of the new regulation is that the sector finally gains a proper legal framework. Standards are clearly defined, responsibilities are explicit, and inspection mechanisms are functional. Educational requirements are raised, which may strengthen the link between maritime universities and the sector. The sub-agency protection also provides a tangible benefit for small agencies working in the field but having limited voice in decision-making.

However, capital thresholds, certificate fees, and strict office requirements create serious entry barriers for new entrepreneurs. A university graduate with one year of experience can establish an agency, but upon doing so, they face 5 million TL in paid-in capital requirements, 300,000 TL certificate fees, employment obligations, and exclusive office requirements. This combination significantly restricts entrepreneurial activity.

The main concern lies in competition. In ship agency services, price margins are already relatively narrow; what differentiates agencies is service quality. Regulations that make market entry more difficult may strengthen the market share of existing large agencies, potentially reducing competitive pressure on service quality in the long term. For small but experienced agencies, the regulation presents both opportunities and risks. Meeting capital and fee requirements is more difficult, but those who manage the transition or form partnerships may operate in a more structured and reliable environment.

Another detail is that while the regulation covers competitive agency services, it does not include provisions regarding port and factory agencies, which are also known in the market.

Transition Period: Who Should Do What?

The regulation was published on 14 May 2026, and most provisions will enter into force three months later, on 14 August 2026.

Agencies whose authorization certificates expire within six months from the effective date will retain validity until their expiration date without any additional procedure. However, for the new five-year certificate, applications must be made via GABS at least one month before expiration, and all requirements including capital must be fulfilled.

Agencies whose certificates are valid for more than six months at the effective date will wait until their expiration date, but this period cannot exceed one year from the effective date under any circumstances.

At this point, it is critical for existing and new operators to decide under which class (A, B, or C) they will operate and to plan their capital and personnel structure accordingly.

Final Word

The authority to issue regulations is granted to administrations by law, and raising professional standards should always be welcomed. This regulation is positive in terms of both content and objectives. In a profession that interacts with more than 30 institutions in its operational processes, a qualified regulation, qualified agencies, and qualified personnel are essential. A structured and standards-based framework will ultimately create a more reliable working environment for all parties.

On the other hand, it is clear that there are some controversial points, and therefore legal challenges and possibly more comprehensive requests for suspension are expected.

Moreover, a similar evaluation regarding personnel qualifications can also be made for other maritime regulations. In ports, shipyards, and maritime supervision services, personnel standards are not yet defined at this level. Extending this approach—while protecting existing personnel during transition—to other regulations would strengthen the quality of human resources in the sector.

This process has also revealed a critical need once again: a single, unified, and strong professional organization representing all ship agencies in Türkiye. If such an umbrella organization existed, the regulatory process would have been more participatory and sectoral objections could have found a much stronger platform.