Turkey: Turkey’s New Emerging Market: E-Commerce

Co-authored by Inveon

With the developments in technology and increase in number of internet users, the global e-commerce volume continues to expand rapidly. The steady rise of e-commerce is triggered by changes in consumers' habits and shopping trends. According to data provided by the research company eMarketer, the global B2C (i.e. Business to Consumer) e-commerce volume is expected to reach USD 1.5 trillion in 2015.

Turkey's recent economic growth provides a convenient environment for sectors to evolve, parallel with sector-based improvements around the globe. Approximately 12,000 e-commerce websites operate in Turkey1. Three main e-commerce players dominate the Turkish e-commerce market: (i) "pure players" aiming to create their own brands; (ii) private shopping clubs providing discounts or promotions and enabling their consumers to reach designed products; and (iii) platforms putting up products or services for sale with special discounts from time to time.

Four main advantages enable the Turkish e-commerce market to emerge: (i) use of credit cards; (ii) sound logistics infrastructure; (iii) high use of mobile internet; and (iv) social media. 56.8 million credit cards and 100.2 million bank cards are being used in Turkey, which carries Turkey to 2nd tier in Europe in the number of credit cards and to 1st tier in bank cards2. According to research conducted by the Turkish Interbank Card Center3 (BKM), online payments by credit cards exceeded TRY 34.6 billion in 2013. In addition, convenient and rapid logistics services increase the consumers' interest. Another instrument that supports the Turkish e-commerce market is the use of mobile devices. According to Soner Canko, general director of BKM, 6% of online shoppers used their mobile devices for online shopping in 2014, which takes Turkey to 3rd place in use of mobile devices. Increase in use of social media is another factor enabling Turkish e-commerce market to grow. Turkey ranked 7th among countries with the highest number of registered users on Facebook and 10th on Twitter4.

According to BKM, the e-commerce volume of transactions by card have been increasing every year, as shown below. However, these figures do not reflect wire transfers or cash payments at the door.

The potential in Turkey's e-commerce market has also attracted both foreign and local investors. The below table shows some of the investments made in e-commerce companies in recent years5:

Although e-commerce sector grew tremendously in the recent years, its share in the total retail sector is below average in Turkey, as compared to its share in the European markets.

With its growing population and increasing number of internet users, Turkey offers retailers and entrepreneurs a promising future in the e-commerce sector.


The Turkish e-commerce market has been growing in proportion with the increase of Turkey's internet penetration. As of 2013, the ratio of Turkey's internet penetration reached 49%, with 37.5 million internet users. In 2012, Turkey ranked 11th among 20 countries with the highest number of internet users6. This increase in the number of internet users carried Turkey to 9th tier in the list of countries with the highest potential in e-commerce, in emerging markets7.

The rapid increase of internet penetration in Turkey makes the market conditions more favorable for internet based businesses. According to the latest reports published by BKM and data shared by the World Bank, internet penetration of Turkey is at 50% while e-commerce penetration in Turkey is at 15%. This gap provides a great opportunity for e-commerce players, as the market is under-penetrated and still requires improvement.

According to data of year 2013, of the 36 million, 10 million internet users also use e-commerce websites. This change in the commercial trends has resulted in a noticeable growth in Turkey's e-commerce market. According to Focus of Digital Market: E-Commerce (Dijital Pazarın Odak Noktası: E-Ticaret)8, published by the Turkish Industry and Business Association (TÜSİAD), the Turkish e-commerce market grew by 35.5% since 2008 and the market volume reached approximately TRY 14 billion in 2013. If Turkey manages to preserve this continuing rise, the e-commerce market is expected to grow by 15.8% at the end of 20179.


The most commonly used models in the e-commerce market are "B2C" and "C2C" (i.e. Consumer to Consumer). According to the Global and Turkish E-Commerce Market Report10, 70% of the total domestic internet economy is based on consumption. E-commerce websites such as Markafoni, Morhipo and Trendyol have particularly contributed to the increase of female online shoppers.

Turkish internet users are the youngest in Europe and this young group of internet users' interest in e-commerce results in a growth for B2C commerce. In 2012, the total disbursements in B2C model e-commerce operations reached TRY 15.3 billion, corresponding to 51% of the total online disbursements. Travelling and plane ticket purchases constitute 25% of total online shopping disbursements. This is followed by insurance, consumer products, telecommunication and direct marketing11. In 2013, sales in the B2C model increased by 40%12.

According to a survey conducted by the Turkish Statistics Institute13, the product group with the highest volume in online sales in 2012 was clothing and sports equipment, with a ratio of 44.4%. This group of products was followed by electronic devices, with a ratio of 25.5% and furniture with a ratio of 21.2%.

According to the report14 published by TÜSİAD, the "B2B" (i.e. Business to Business) model is not as commonly used in the Turkish e-commerce market as the C2C model. Although well-known companies, such as Migros and Hepsiburada are currently using the B2B model, the use of e-commerce is not common among small and medium sized enterprises. According to the report, the lack of (i) trust in e-commerce; (ii) labor force; (iii) financial resources; (iv) technical infrastructure; (v) know-how and (vi) high application expenses prevent B2B e-commerce from becoming widespread among small and medium sized enterprises. Although progress in the B2B market is slower than expected, according to the data provided by IDC Corporate15, the market grew by 28% within the last four years.


In order to create a legally sound environment, the Law on Electronic Commerce was finally published on 5 November 2014 in the Official Gazette (the "ECL"). Under the ECL, electronic commerce is defined as commercial activities conducted through electronic environment without parties coming face-to-face. The ECL aims to protect consumers and to encourage them to use e-commerce more frequently. The ECL will enter into force on 1 May 2015.

The ECL governs (i) commercial relations; (ii) liabilities of online service providers; (iii) agreements to be executed through electronic devices; (iv) obligation to provide information; and (v) sanctions. Under the ECL, online service providers must provide (i) identical information; (ii) technical information for execution of the agreement; (iii) information on whether or not the agreement will be kept by the service provider and whether it will be accessible; (iv) information on technical instruments for correction of faults that may occur during data submission; and (v) information on confidentiality and alternative dispute resolution, if any, prior to execution of the agreement.

One of the most significant provisions of the ECL governs commercial electronic messages. In practice, electronic messages sent by service providers to purchasers cause problems. The ECL provides options to purchasers such as "opt-in", "negative opt-in" and "double opt-in". Under the ECL, commercial messages can only be sent with prior consents of purchasers. In this regard, service providers' applications to send commercial electronic messages through automatic mail or short message service (SMS) will no longer be applicable. In addition, purchasers are entitled to renounce from delivery of commercial electronic messages at any time and without showing any reason. The ECL also regulates the content of the message to be sent to purchasers. It is worth emphasizing that, these provisions will not be applicable to messages that do not include any commercial purpose.

Following the enactment of the ECL, two regulations are expected to be published by the Ministry of Customs and Trade, regulating the application of the law in general and rights and liabilities of intermediary service providers. Publication of these two regulations within a reasonable time period is crucial for the proper application of the law and for overcoming any potential problems through application process.

Another legislation that applies to e-commerce transactions is the Consumer Protection Law16 (the "CPL"). There is also the Distance Sale Agreements Regulation17 ("Regulation"), which was prepared in accordance with the CPL and will enter into force on 27 February 2015.

Under the CPL, in distance sale agreements, consumers have the right to withdraw from the agreement within 14 days, without presenting any reason and/or paying any penalty. Moreover, under the CPL, the seller or the provider must perform its duties agreed under an electronic agreement, within 30 days following receipt of the order. These consumer protections that the CPL and the Regulation bring along are expected to promote e-commerce in Turkey.


Statistics demonstrate that, with the legislative developments expected in the upcoming years (e.g. enactment of the Draft Law on Data Protection), Turkey's potential in e-commerce will keep increasing and Turkey will have a more sustainable environment for e-commerce investments. With more conscious e-commerce users, supportive market instruments, investments and regulations, Turkey will be able to maintain the increase in the domestic e-commerce sector and may become a noteworthy player in the global market.


1.Global and Turkish E-Commerce Market, Türkiye İş Bankası, April 2013.

2.Digital Bosphorus: The State of Turkish E-Commerce, Sina Afra, 2013.

3. http://www.bkm.com.tr/istatistik

4.Digital Bosphorus: The State of Turkish E-Commerce, Sina Afra, 2013.

5.Deloitte, Annual Turkish M&A Review 2012, 2013.

6.Internet Word Stats, Usage and Population Statistics, http://www.internetworldstats.com/stats.htm

7.Hana Ben-Shabat, Parvaneh Nilforoushan, Mike Moriarty, AT Kearney, E-Commerce Is the Next Frontier in Global Expansion, 2012.

8.Sina Afra, TÜSİAD, June 2014.

9.Focus of Digital Market: E-Commerce, Sina Afra, TÜSİAD, June 2014.

10.Türkiye İş Bankası, April 2013.

11.Digital Bosphorus: The State of Turkish E-Commerce, Sina Afra, 2013.


13.Turkish Statistics Institute, 2012.

14.Sina Afra, TÜSİAD, 2014.


16.Published in the Official Gazette dated 7 November 2013.

17.Published in the Official Gazette dated 27 November 2014

© Kolcuoğlu Demirkan Koçaklı Attorneys at Law & Inveon 2015

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

Pinar Bülent
Some comments from our readers…
“The articles are extremely timely and highly applicable”
“I often find critical information not available elsewhere”
“As in-house counsel, Mondaq’s service is of great value”

Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:
  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.
  • Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.
    If you do not want us to provide your name and email address you may opt out by clicking here
    If you do not wish to receive any future announcements of products and services offered by Mondaq you may opt out by clicking here

    Terms & Conditions and Privacy Statement

    Mondaq.com (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

    Use of www.mondaq.com

    You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about Mondaq.com’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.


    Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

    The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.


    Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

    • To allow you to personalize the Mondaq websites you are visiting.
    • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
    • To produce demographic feedback for our information providers who provide information free for your use.

    Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

    Information Collection and Use

    We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

    We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to unsubscribe@mondaq.com with “no disclosure” in the subject heading

    Mondaq News Alerts

    In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.


    A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

    Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

    Log Files

    We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.


    This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

    Surveys & Contests

    From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.


    If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.


    From time to time Mondaq may send you emails promoting Mondaq services including new services. You may opt out of receiving such emails by clicking below.

    *** If you do not wish to receive any future announcements of services offered by Mondaq you may opt out by clicking here .


    This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to webmaster@mondaq.com.

    Correcting/Updating Personal Information

    If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to EditorialAdvisor@mondaq.com.

    Notification of Changes

    If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

    How to contact Mondaq

    You can contact us with comments or queries at enquiries@mondaq.com.

    If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at problems@mondaq.com and we will use commercially reasonable efforts to determine and correct the problem promptly.

    By clicking Register you state you have read and agree to our Terms and Conditions