In short

Tamga Network will become a foundation, but the foundation has not been established yet. Until then a company runs the network's own services on the network's behalf and provisionally: BROS İNŞAAT SANAYİ VE DIŞ TİCARET LİMİTED ŞİRKETİ. The trust lists still name "Tamga Network" as their operator; the company's name appears only where a legal person is needed (tax number, certificates, contracts, personal data registration). This information is kept in one place and changed in one step when the foundation exists.

Context

• ADR-0009 K5 and D-GOV-5: lists carry operator {name, status: provisional, on_behalf_of}; a handover changes only the operator field. ADR-0037: the network is only a network and sells no services; ADR-0042: the network runs no wallet.
• The network has no legal personality. Registration data (ADR-0024), the organizationIdentifier of issuer and access certificates (ADR-0058), the data controller registration under the Turkish data protection law (KVKK), domain names and participation agreements need a legal person. These places had been filled one by one (the identity service and Tamga Verify records, the framework documents, the privacy notices); there was no written decision and no single source. The pending record of the app-store review signer (ADR-0033) was incomplete for this reason.
• Direction of project management: the network will be a non-profit foundation entirely separate from the operating company; until the foundation exists, the operator chain is fixed in writing and is the same everywhere.

Decision

K1 — The chain

Tamga Network (foundation to be established) ← provisional operator BROS İNŞAAT SANAYİ VE DIŞ TİCARET LİMİTED ŞİRKETİ (tax number 1870632151; the address and other identifiers live only in registry/provisional-operator.json). The provisional operator runs the network's own services (list publication, the registrar role on behalf of the state, the identity service, Tamga Verify, the websites and the domain names) on behalf of Tamga Network. Every act that needs a legal person (registration identifier, certificate subject, KVKK registration, domain name, contract) is made in its name with the words "on behalf of Tamga Network".

K2 — Names

The list operator (operator.name of the LOTL and the national lists, SchemeOperatorName of the ETSI XML and LoTE views) and the scheme owner name stay "Tamga Network" (status: provisional, on_behalf_of). The provisional operator's name appears only in the records of the network's own services (operator block, identifiers, postal_address), in their certificates and in documents that need a legal person. Other products of the provisional operator (for example a wallet the network lists) are a separate participant and gain no privilege (ADR-0037, ADR-0042).

K3 — One value

The provisional operator's name, the body it acts for, its identifier and address are a single configuration value (apps/trust-publisher/registry/provisional-operator.json). The list publisher checks before every publication: every own record whose identifier note says "provisional operator" carries exactly this value, and the list operator name is "Tamga Network"; any difference stops the publication. The JSON lists and the XML and LoTE views (ADR-0066) are produced from these records; certificate subjects and contract templates use the same value.

K4 — Handover

When the foundation acquires legal personality, the handover uses the operator's existing handover tool (dry run) and runbook: the value, the records and certificates that depend on it are renewed with the foundation's name and number (ADR-0058 K5). The list operator name, ca_id, vct and the institutions' permanent identifiers do not change.

K5 — Contracts

Until the foundation exists, the participation agreement, the hosting annex and the data processing agreement are signed by the provisional operator on behalf of Tamga Network; the agreements carry a succession clause: once the foundation exists, rights and obligations pass to it (FW-TF-0001 §5.7).

K6 — Pending records

The record of the app-store review signer (ADR-0033) and every later own record carry the same value.

Options considered

Option	Result	Why
The company's name as the list operator name	rejected	List and scheme ownership belong to the network; the list identity would change at handover; neutrality of the network
Waiting for the foundation for everything that needs a legal person	rejected	The identity service, the verifier record and the app-store review need a legal person today
Keeping the values separately in each record (the previous state)	rejected	Scattered; one could be forgotten at handover; cannot be checked
List name "Tamga Network", legal person the provisional operator, one value + publication check	chosen	Handover from a single point; list identity stable; consistency tested at every publication

Invariants

Code	Rule
OP1	The list operator and scheme owner name is "Tamga Network" (status: provisional until the foundation exists); the provisional operator's name appears only in the records of the network's own services, in their certificates and in documents that need a legal person.
OP2	The provisional operator's name, identifier and address come from a single configuration value; the list publisher does not publish with an own record that carries different information, or with a list operator name other than "Tamga Network".
OP3	The handover to the foundation changes only this value and the records and certificates that depend on it; the list operator name, ca_id, vct and the institutions' permanent identifiers do not change.

Consequences

• Code: list publisher check provisional-operator.ts and registry/provisional-operator.json; the pending record of the app-store review signer was completed with the same value (registration and publication on the operator's computer).
• Documents: FW-TF-0001, FW-RB-0001 RB-OP-01 and the definitions already describe the same chain; no change was needed.

Status

Accepted — 2026-10-30. With the approval of project management (verbatim quote in the private approval record). DECISIONS: D-GOV-10. OP1–OP3 are binding.