Your data flows in a single architecture compliant with both regimes at once.

What did the new regime change?

After the 2024 amendments, KVKK's transfer regime settled onto three tiers: an adequacy decision; appropriate safeguards (binding corporate rules, a standard contract announced by the Board, a written undertaking); and limited incidental circumstances. In practice, the busiest route is the standard contract — and the most critical detail is the obligation to notify the Board within five business days of signing. A contract without notification is, in itself, grounds for a sanction.

Transfer compliance is not a document-collection exercise but an architectural one: a data-flow map is drawn up, the right mechanism is assigned to each flow, the contracts are signed as a single set, and notification/recording obligations are put on a schedule. In group structures, the goal is that every new subsidiary or tool can be added to the existing architecture — not a project from scratch each time.

Transfer compliance is tested in two places: a Board review, and the investigation that follows a data breach. The evidence you will be asked for is predictable — a current inventory of flows, the reasoning behind the mechanism chosen for each one, signed contracts and notification records, and assessment notes on the risk in the receiving country. On the GDPR side, post-Schrems II practice requires that where the standard contractual clauses are not enough on their own, the supplementary measures — encryption, access architecture, transparency reports — are documented. Enforcement cuts two ways: alongside an administrative fine there is the risk that the transfer itself is suspended, and for the business that is the real cost. The EU end of the regime is summarised in our GDPR record.