A Comparative Analysis of Insurance Protection Strategies Against Cyber Threats in Türkiye and the European Union

The purpose of this study is to investigate insurers' legal responsibilities under cyber risk insurance policies in the event that cyberattacks violate personal data. It contrasts EU regulations (like GDPR and the German AVBC framework) with Turkish laws, especially the Turkish Commercial Code and the Turkish Personal Data Protection Law (PDPL). According to the study, the insured company's compliance with PDPL regulations determines the insurers' liability. These include implementing appropriate administrative (like staff training) and technical (like encryption) measures. Claims may be partially or completely rejected if the business fails to fulfill these responsibilities, which is viewed as negligence. In contrast to the EU's more transparent documentation (such as KID), Türkiye faces a number of major issues, including inconsistent policy terms, a lack of actuarial data, unclear coverage of indirect damages (such as reputational harm), and regulatory gaps.