Half-Year Publication Competition Law Updates – Türkiye

July 2026 – The first half of 2026 confirmed that the Turkish Competition Authority (“TCA”) has no intention of slowing down when it comes to enforcement. From its real test of algorithmic pricing to interim measures against global tech platforms, the Turkish Competition Board (“Board”) covered remarkable ground in just six months.

Policy developments

• Updated merger control regime: Sweeping amendments to the Merger Control Communiqué took effect on 11 February 2026, raising filing thresholds and revising the technology-undertaking exception. The previous no-threshold regime for tech targets was replaced by a TRY 250 million (EUR 5.6 million) threshold, applicable only where the target technology undertaking has activities in Türkiye. The TCA also updated its merger control guidelines. Read our analysis of the Communiqué amendments here, and of the updated guidelines here.
• Digital markets under the spotlight: The TCA intensified its focus on digital markets through a new Digital Competition Policy Study and a sector inquiry into the AI ecosystem, signalling continued attention to emerging competition issues in technology-driven markets.¹

Enforcement trends

• Algorithmic pricing gets its first real test: In its Amazon decision, the Board found no infringement in the “buybox” mechanism, citing voluntary participation, the absence of seller-to-seller contact, and a rule-based (not machine-learning) design. The most sensitive feature—"match the buybox price”—was flagged as capable of increasing price rigidity; Trendyol and Hepsiburada removed it via commitments, while Amazon shut its automatic pricing system in Türkiye entirely.² Further analysis is available here.
• “On-site” goes online. In its Spotify decision, the TCA treated the failure to provide access to devices used by employees located abroad but responsible for Türkiye-related operations as an obstruction of an onsite inspection. The decision confirms that the Authority may seek remote access to data and devices of personnel outside Türkiye where they are involved in activities affecting the Turkish market, significantly expanding the practical reach of dawn raids in digital investigations.³ More on the decision can be found here.
• Interim measures gain momentum: The TCA Board ordered Unilever to reserve 30% (up to 50% on request) of freezer space for competitors in small retailers, in a clearly labelled single block.⁴ Echoing the European Commission, it required Meta to allow third-party generative-AI chatbots to operate as a primary service on WhatsApp without technical or economic obstacles.⁵ Further details are available here.
• Commitments reshape payments:⁶ The Mastercard/Visa investigation closed with commitments: more transparent, objective and proportionate discounts and incentives, improved cross-border interchange rates, and—for Mastercard’s Masterpass—fairer product placement and campaign terms. The commitments are expected to improve conditions for alternative digital-wallet providers. More on the commitments can be found here.
• Labour markets stay in the spotlight:⁷ Recent decisions continued to refine the Board’s approach by introducing safe harbours for certain salary/benefit information-sharing, confirming that communicated wage increases are effectively public, and clarifying that competitor salary data obtained from job applicants tracks market levels rather than restricting competition. Nevertheless, grey areas remain. Further analysis is available here.
• Executives back in the firing line:⁸ The Board revived a rarely used power and imposed a personal fine on an executive found to have decisively influenced a price-fixing cartel. More on the decision can be found here.

New investigations in focus

Late 2025 and early 2026 brought a dense pipeline of new investigations:

• Digital & technology: Google faces a fresh antitrust probe over alleged de facto exclusivity for its search and browser services within its mobile ecosystem,⁹ plus a separate investigation into whether its Ireland-vs-Türkiye billing structure creates discriminatory cost effects.¹⁰ Meta’s integration of Meta AI into WhatsApp is being examined for foreclosing third-party AI providers.¹¹
• Vertical restraints under continued scrutiny: Numerous investigations target alleged RPM, online sales restrictions, exclusivity, and distribution restraints.¹²
• Labour markets: 26 undertakings across banking, insurance and IT/fintech are under investigation for alleged no-poach agreements and the exchange of sensitive labour-market information.¹³
• Sector-wide conduct: Cartel and info-exchange probes target 19 private schools (fees and related ancillary services)¹⁴, 19 health insurers (premium-setting)¹⁵, 65 audit and accounting firms including the “Big Four” (price-fixing, customer and employee allocation)¹⁶, and 29 orthopaedics/neurosurgery suppliers and four trade associations (alleged restriction of supply to the public sector)¹⁷.

Looking ahead, digital markets, labour-market restrictions and vertical restraints are likely to remain among the TCA’s key enforcement priorities for the remainder of 2026.

Footnotes

1. Competition Policies in the Digital Age Study (14.04.2026), Artificial Intelligence Ecosystem Sector Inquiry (07.04.2026).

2. Amazon (18.04.2025, 25-15/348-164).

3. Spotify (17.07.2025, 25-26/634-392).

4. Unilever Interim Measure (22.04.2026, 26-15/434-162).

5. Meta AI Interim Measure (14.05.2026, 26-18/536-193).

6. Mastercard – Visa (02.04.2026, 26-11/351-133).

7. Menarini (31.10.2024, 24-44/1030-440).

8. True Danışmanlık (06.11.2025, 25-41/1016-582).

9. Google Android (08.01.2026, 26-01/2-M).

10. Google Billing Practices (05.03.2026, 26-08/233-M).

11. Meta AI (14.05.2026, 26-18/536-M).

12. Carex (18.12.2025, 25-48/1164-M), Hobi Kozmetik (02.04.2026, 26-11/335-M), May-Agro (31.12.2025, 25-50/1235-M), EssilorLuxottica (20.11.2025, 25-43/1037-M), Haribo (05.03.2026, 26-08/238-M).

13. Banking, Insurance and IT Sectors Labour Market (29.01.2026, 26-03/75-M).

14. Private Schools (29.01.2026, 26-03/73-M).

15. Health Insurance Market (16.03.2026, 26-10/298-M).

16. Independent Audit and Accounting Sector (29.01.2026, 26-03/91-M).

17. Orthopaedics and Neurosurgery Products Producers (12.03.2026, 26-09/285-M).