Short answer: not without an operating licence. Packaging and selling hotel rooms, airport transfers and tickets for an event is listed as an activity exclusive to licensed travel agencies under Article 5 of the Travel Agencies Regulation, published in the Official Gazette on 5 October 2007, issue 26664. The first sentence of that article leaves no room: services defined as exclusive to travel agency activity cannot be performed by persons or organisations that are not travel agencies. Congress and conference travel and incentive travel are named in the fifth subparagraph, and the sixth covers services a paying company offers free of charge to its guests. A classic dealer incentive trip sits squarely inside that definition. The legal base is Law 1618 on Travel Agencies and the Association of Travel Agencies, whose Article 4 requires an operating licence from the Ministry of Culture and Tourism for any travel agency activity in Turkey. Working without one has two consequences. Article 29 lets the senior civil administrator of the province or district halt the activity immediately, and Article 30 provides for an administrative fine of 2,000 to 5,000 lira imposed by the same authority. The fix is simple. Either route accommodation and transport through an A group licensed agency, or have the hotel and the carrier invoice the client directly. Below: the exclusive activity list, what does not count as agency work, the licence groups, the guide requirement and the invoicing chain.
Why does selling accommodation and transfers need a licence?
Article 1 of Law 1618 defines a travel agency as a commercial organisation authorised, for profit, to give tourists information about tourism, to create package tours and tours, and to provide tourism related accommodation, transport, sightseeing, sports and entertainment services. Accommodation and transport happen to be the two largest lines in most corporate event budgets. Article 5 of the Regulation then lists six exclusive activities: creating and selling domestic or international tours and package tours for individuals or groups, with or without overnight stays; making reservations and selling tickets for land, sea and air carriers; selling another agency's product under written authorisation; providing transfers; organising congress, conference, incentive or support travel; and building services that a paying party offers free to its guests. The Regulation defines a transfer broadly, as non scheduled transport between an airport, station, port or bus terminal and the accommodation facility, in either direction. The minibus taking your guests from the airport to the hotel is a transfer in the legal sense. Article 4 closes the loop in a single line: operating as a travel agency in Turkey requires a licence from the Ministry.
Where do dealer meetings and congresses sit in that list?
The fifth subparagraph names them. Organising, providing, marketing and delivering travel for accommodation, transport, sightseeing, food and beverage, entertainment, sports, congresses and conferences, religious, health, educational, cultural, scientific and professional study, incentive or support purposes belongs to licensed agencies. The sixth subparagraph describes the corporate model even more directly: creating, marketing or selling services that a person or organisation pays for itself in order to offer them free as hospitality, incentive or support. At a dealer meeting nobody at the table pays for their own room. The company pays and the stay is offered to the guest, which is exactly the situation the rule anticipates. One honest caveat: the prohibition sentence refers to services sold to consumers for a fee, and lawyers do argue about whether a sale to a corporate buyer falls inside that wording. The sixth subparagraph, however, explicitly mentions organisations. Settling that argument during an inspection is far more expensive than structuring the contract correctly in the first place.
Which services are not travel agency activity?
Article 6 of the Regulation carves out two exceptions, and both are useful in event planning. The first is vehicle rental: renting out vehicles you own, or operate under the Highway Traffic Law numbered 2918, for commercial purposes and in line with your own sector rules is not agency activity. The second matters more. Accommodation, hospitality, entertainment, transport and licensed yacht businesses may market, reserve and sell their own products where their own legislation allows it. A hotel selling its own rooms is not acting as an agency. Article 4 of the law settles the coach side too: the services of bus operators carrying passengers domestically or abroad are transport services and fall outside this law. That produces the cleanest structure in practice. The hotel invoices the room block in its own name, a licensed carrier supplies the coaches under its own contract, and the event agency invoices stage, sound, lighting, LED screens, decor and content production. Three invoices, three clearly separated liabilities.
A, B or C group: which licence covers your project?
Article 7 of the Regulation splits agencies into three groups. Group A performs every travel agency service. Group B handles reservations and ticket sales for land, sea and air carriers, plus ticket sales for tours organised by group A agencies. Group C promotes, produces, markets and sells domestic tours for Turkish citizens only. A brand gathering its dealers in Antalya needs a group A agency, and for an incentive trip abroad there is no alternative at all. Article 3 of the law adds another limit: foreign owned travel agencies may not organise tours out of Turkey. If subcontracting is involved, read the third paragraph of Article 7. Work handed by a group A agency to a group B or C agency must be documented in writing or by contract, and it cannot amount to the whole of a tour or package tour being organised by the group B or C agency. Renting someone else's licence is not an option the law leaves open.
What should you check in the agency you hire?
Under Article 13 of the Regulation, travel agency status is acquired by two steps: becoming a member of TÜRSAB, the Association of Turkish Travel Agencies, and receiving the operating licence issued by the Ministry. Article 32 of the law makes that membership compulsory, so an agency without it does not exist. The checklist is short. Article 37 requires the operating licence to be displayed where everyone can see it at the head office and branches, and Article 38 requires an embossed TÜRSAB plaque outside, showing the agency title, the licence number and the membership record. Verify that number on the Ministry's online agency query screen. The financial guarantee is reassuring as well. Article 10 of the law sets a guarantee of between 5,000 and 30,000 lira depending on the group, Article 30 of the Regulation sets 7,000 lira for group A, and both figures are applied uplifted by the annual revaluation rate. The guarantee is not decorative: if the agency fails to meet its obligations, the Ministry converts it to cash and pays the creditor. If you are buying a package tour, ask about the compulsory insurance in Article 12 as well. The insurer's liability must be at least equal to the package tour price, and a copy of the policy goes to the Ministry within five business days. One more point, added in 2024: agencies may not market or sell unlicensed accommodation facilities or homes rented out for tourism. That rules out putting your guests in an unregistered villa.
What changes if you add a half day excursion?
The guide requirement kicks in. Subparagraph (a) of Article 10 of the law requires at least one licensed guide per package tour or tour for up to forty five people, and one guide in any single vehicle with a capacity above forty five. The same provision bans anyone other than a licensed guide from giving tourists guiding style information about Turkey's history, nature, culture and tourism. The hotel's public relations manager picking up the coach microphone to narrate the city is a breach. The exception is narrow and precise: package tours that include only accommodation at a single hotel and transport to that hotel sit outside the requirement. A straightforward dealer meeting falls within the exception. The moment you add a Bosphorus cruise or a museum visit, it does not. Article 27 sets the penalty at 1,500 lira as written in the law, again uplifted annually by the revaluation rate. The amount looks small, but an inspection that starts here tends to end up questioning the whole programme.
What does working without a licence actually cost?
Article 29 of the law moves fast: anyone carrying out travel agency activity without a temporary or full operating licence is halted immediately by the senior civil administrator of the place where they operate. That decision comes from the governorship or the district governorship rather than a court, so the risk of being stopped mid event is real. Article 30 handles the money and provides for an administrative fine of 2,000 to 5,000 lira, imposed by the same administrator, on anyone performing activities reserved to licensed agencies. The prison sentence still quoted on many websites is out of date. Article 43 of Law 6352, dated 2 July 2012, replaced the wording covering three to six months of imprisonment and a judicial fine of up to a thousand days with an administrative fine. Administrative fines rise each year with the revaluation rate under the Misdemeanours Law numbered 5326, so the amount applied today is higher than the text suggests. Licensed suppliers carry risk too: under Article 27, failing to take out the compulsory insurance, or being found to perform activities not covered by the law, is grounds for cancelling the operating licence. And remember the chain: subparagraph (ç) of Article 10 makes agencies jointly and severally liable with the other agencies they work alongside.
How should the contract and invoicing chain be built?
Three models work in the field. The first is unbundled: the hotel invoices the room block, a licensed carrier invoices transport, the event agency invoices production, and the client manages three contracts. The second is a consortium: a group A agency takes accommodation and transport while the event agency runs creative and technical production, both working to one project plan. The third is integrated, with a single supplier that holds both the operating licence and the production team. Whichever you pick, put three lines in the contract: who commits to which service, how the cancellation penalty works on the accommodation side, and which party carries the insurance and the guarantee. The market justifies that care. The 2024 rankings published by ICCA, the International Congress and Convention Association, cover more than 11,000 meetings worldwide, with Vienna in first place at 154 events. According to the ICCA figures reported by Anadolu Agency, Istanbul hosted 86 international congresses in 2024, ranking 20th in the world and 15th in Europe and entering the global top twenty for the first time since 2015, with attendance ranging from 50 to 7,300 people. Tales Event is based in Istanbul and delivers dealer meetings, product launches, congresses, gala nights and graduation ceremonies across Turkey, covering stage, sound, lighting, LED screens, decor and content production. Send us the date, the city and the headcount, and we will map the accommodation and transport lines against the licensed side of the chain together with your production plan.
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