EU Data Residency / MAM-ZDR eligibility for a Turkey-based company — is Turkey considered "Europe"?

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Hi all,

We’re building a SaaS product (dental/health-tourism CRM, processing sensitive health data) and are evaluating OpenAI’s EU Data Residency project before sending any real customer data. Our company is incorporated in Turkey. A few questions we couldn’t fully resolve from the public docs — would appreciate input from anyone who has been through this process, or from OpenAI staff:

  1. Region eligibility: The docs define the EU Data Residency region as “Europe (EEA + Switzerland).” Turkey isn’t listed. Has anyone with a Turkey-incorporated entity successfully enrolled in EU Data Residency / applied for Modified Abuse Monitoring (MAM) or Zero Data Retention (ZDR)? Is eligibility based on the contracting entity’s country, the data subjects’ location, or something else?

  2. Approval process/timeline: Does anyone have real-world experience with how long MAM/ZDR + the “Modified Retention” amendment approval takes, and whether it requires a minimum spend or a separate enterprise agreement?

  3. Batch API + ZDR: We understand /v1/batches is not currently ZDR-eligible and retains state until deleted, even under EU Data Residency. Has anyone found a workaround (e.g., using a project with retention set to “None”) that’s been accepted for production use with sensitive data?

  4. Regional pricing uplift: The docs mention a possible 10% uplift for models released after March 5, 2026 under regional processing. Does this apply broadly, or only to specific models/endpoints? Any confirmed examples?

  5. Billing for non-EU/non-US entities: For a company outside the US/EU (e.g., Turkey), is invoiced/contracted billing available, or is self-service limited to prepaid card billing?

Any pointers, especially from people who went through Sales for this, would be really helpful. Thanks!