Turkcell (NYSE: TKC) posts ITRA/Section 13(r) disclosure in 2025 20-F

Rhea-AI Filing Summary

Turkcell İletişim Hizmetleri A.Ş. submitted a notice that it included a disclosure required by the Iran Threat Reduction and Syria Human Rights Act of 2012 (Section 219) and Section 13(r) of the Exchange Act in its Annual Report on Form 20-F for the year ended December 31, 2025. The Company states the disclosure appears in "Item 4. Information on the Company—B. Business Overview" under the heading for ITRA disclosure. The notice was filed on April 17, 2026.

Key Figures

Filing date: April 17, 2026 Reporting period: year ended December 31, 2025 Statutory citations: Section 219; Section 13(r)

3 metrics

Filing date April 17, 2026 Notice of disclosure filed with the SEC

Reporting period year ended December 31, 2025 Annual Report on Form 20-F

Statutory citations Section 219; Section 13(r) Disclosure pursuant to ITRA and Exchange Act provision

Key Terms

Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRA), Section 13(r), Form 20-F

3 terms

Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRA) regulatory

"under the heading “—XII. Disclosure Pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (“ITRA”)”"

Section 13(r) regulatory

"Pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act ... and Section 13(r) of the Securities Exchange Act"

Form 20-F regulatory

"included ... in its Annual Report on Form 20-F for the year ended December 31, 2025"

Form 20-F is the standardized annual disclosure that non-U.S. companies must file with the U.S. securities regulator when their shares are traded in the U.S.; it contains audited financial statements, a plain-language description of the business, management discussion, governance details and key risk factors. It matters to investors because it provides a consistent, comparable company “report card” and rulebook, helping buyers assess financial health, governance and risks before investing.

Turkcell İletişim Hizmetleri A.Ş.

Turkcell Küçükyalı Plaza

Aydınevler Mahallesi İsmet İnönü Caddesi

No:20 Küçükyalı Ofispark B Blok Maltepe

İstanbul, ‌Türkiye

April 17, 2026

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

United States of America

Re: Notice of disclosure filed in Annual Report on Form 20-F under Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 and Section 13(r) of the Exchange Act

Ladies and Gentlemen:

Pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 and Section 13(r) of the Securities Exchange Act of 1934, as amended, notice is hereby provided that Turkcell İletişim Hizmetleri A.Ş. has made disclosure pursuant to those provisions in its Annual Report on Form 20-F for the year ended December 31, 2025, which was filed with the Securities and Exchange Commission on April 17, 2026. Such disclosure is located in “Item 4. Information on the Company—B. Business Overview” under the heading “—XII. Disclosure Pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (“ITRA”)” of the Annual Report on Form 20-F.

Sincerely,

Turkcell İletişim Hizmetleri A.Ş.

By:	/s/ Özlem Yardım
Name:	Özlem Yardım
Title:	Investor Relations and Corporate Finance Director

FAQ

What did Turkcell (TKC) disclose under Section 219 (ITRA)?

Turkcell disclosed information required by Section 219 (ITRA) in its Annual Report on Form 20-F for the year ended December 31, 2025. The disclosure is located in Item 4, Business Overview, under the specific ITRA heading.

When was the ITRA/Section 13(r) disclosure filed by Turkcell (TKC)?

The company filed the notice on April 17, 2026. It states the related disclosure appears in the Form 20-F for the year ended December 31, 2025 under the Business Overview section.

Where in Turkcell's filings can I find the full Section 13(r) disclosure?

The full disclosure appears in the Annual Report on Form 20-F within Item 4, "Information on the Company—B. Business Overview," under the heading for the ITRA disclosure for the year ended December 31, 2025.

Does the notice state any financial impact or transactions related to the disclosure?

The notice only confirms the statutory disclosure was included in the Form 20-F and does not state financial impacts or specific transactions. The content provided lists where the disclosure appears rather than quantifying effects.