Quick Read: Competition Law Updates In Türkiye – May 2026

June 2026 – The Turkish Competition Authority (“TCA”) experienced a highly active month in May, marked by a broad spectrum of enforcement activity spanning artificial intelligence applications, labour markets, review of compliance with past commitments, abuse of dominance, distribution networks, and vertical restraints.

Among the key developments were the initiation of an investigation into Meta’s integration of its WhatsApp AI service, as well as interim measures extending the scope of Unilever’s existing obligation to open its ice cream freezers to competitors. Alongside these interim measures and new investigations, the publication of the reasoned decision underlying the settlement in the investigation into the TV series production sector also stood out.

Another notable development was the Kyocera–Geskokipit decision, which combined settlement and commitment mechanisms in a multi-layered case involving parallel import restrictions, territorial and customer limitations, and resale price maintenance. In the CHI Kozmetik case, which was reassessed following a court ruling, debates on the application of the more favourable regulation for the calculation of fines came to the forefront. This issue of Quick Read provides a concise overview of the most notable competition law developments shaping the Turkish market throughout May.

Dive into May case updates

1. A new era for ice cream freezers: Unilever’s obligation to open freezer space to competitors expanded

Within the scope of an investigation initiated to assess Unilever’s compliance with the obligations imposed under the 2021 infringement decision—particularly regarding access to ice cream freezers for competitors, as well as alleged infringements of Articles 4 and 6 of Law No. 4054 through exclusivity and discounting practices—the Turkish Competition Board (“Board”) decided to impose interim measures on Unilever.¹ Under the interim measures, Unilever is subject to the following obligations:

• Allocation of freezer space at small retailers: In points of sale with a closed sales area of 100 m² or less, where no additional competitor freezer is available other than Unilever’s own freezer, 30% of the total freezer capacity must be allocated to competing products in a single block. This section must be clearly labelled with the statement “This area is reserved for competing products”, and no Unilever or Magnum products may be placed in this allocated space.
• Empty space requirement: Where no competing products are available at the point of sale, the allocated 30% space must remain empty.
• Flexibility upon request: At the request of the retailer, the allocated share for competitors may be increased from 30% up to 50%.

2. Structural remedies across the sector: Separation of casting agencies, casting direction, and production activities

The TCA’s extensive investigation into the Casting Agencies Association (Kast Ajansları Derneği) and undertakings operating in the Turkish casting and talent management sector concluded in May. The Board found that the parties had violated competition through the joint determination of agency commission rates and service conditions, as well as the exchange of competitively sensitive information. Accordingly, administrative fines totalling TRY 42.1 million (approx. EUR 790,320)² were imposed on 36 undertakings and the Casting Agencies Association.³

Beyond the administrative fines, the most striking aspect of the decision lies in the comprehensive behavioural and structural remedies aimed at restoring competitive conditions in the sector. In this context, the undertakings and the Casting Agencies Association are required to take the following steps within three months:

• Separation of business activities: Casting direction and casting agency/talent management activities must not be carried out within the same economic entity. One of these activities must be removed from the company’s articles of association and brought to an end in practice.
• Separation from production activities: Production activities and casting agency/talent management activities must not be conducted within the same economic entity, and where they are currently combined, one activity must be discontinued.
• Restriction on ancillary services: Casting agencies and talent managers must not provide additional services such as consultancy, accounting, supervision, or public relations on behalf of producers in productions where they supply talent.
• Termination of package casting practices: The participation of one actor or talent in a production must not be made conditional upon the participation of other actors or talents in the same production.
• Reorganisation of association membership: Membership of the Casting Agencies Association must be limited to undertakings active solely in casting agency and talent management services.
• Sector-wide compliance communication: Members must be informed of their obligations regarding activity separation and package casting practices under competition law.
• Public compliance notice: The Casting Agencies Association must publish a notice on its website addressing the relevant competition concerns.

3. AI competition on WhatsApp: Interim measures imposed on Meta

Following the European Commission’s probe, the TCA has also initiated an investigation into Meta’s AI strategy on WhatsApp, focusing on whether the integration of Meta AI and potential restrictions on third-party artificial intelligence providers’ ability to offer services through the platform may constitute a limitation of competition. Pending its final decision, the Board has imposed interim measures.⁴ Under these interim measures, Meta is required to comply with the following obligations within one month of notification of the reasoned decision:

• Access enablement requirement: Meta must establish the necessary conditions enabling third-party general-purpose generative AI chatbots and assistants to offer their AI services as a primary service through WhatsApp.
• Equal and effective access: The provision of such services via WhatsApp must not be made technically or economically more difficult or less accessible.

The TCA’s extensive investigation into Ay Yapım and Med Yapım, leading players in the film production and distribution sector, concluded in November 2025 with settlements in relation to allegations of competitively sensitive information exchange in labour markets. Following the undertakings’ admissions, administrative fines of TRY 75.8 million (approx. EUR 1.4 million) and TRY 47.8 million (approx. EUR 896,195) were imposed on Ay Yapım and Med Yapım, respectively.⁵ The reasoned decision underlying this settlement, which resulted in significant fines for both undertakings, was published in May.

The decision is particularly noteworthy as it stems not from the initial complaint, but from evidence uncovered during onsite inspections carried out by the TCA. WhatsApp correspondence revealed that the parties exchanged forward-looking information on salary increase rates and discussed maintaining employee remuneration at certain levels. The TCA concluded that these exchanges clearly constituted an exchange of competitively sensitive information between Ay Yapım and Med Yapım. In particular, the mutual disclosure of planned wage increases was found to compromise independent decision-making in wage setting and to facilitate coordination in the labour market. This conduct was considered capable of exerting downward pressure on wages and weakening competition between employers.

5. From parallel imports to pricing intervention: The Kyocera – Geskokipit decision

The investigation concerning Kyocera, active in the photocopier and laser printer markets, and its distributor Geskokipit concluded with a combination of settlement and commitment procedures. The investigation concerned allegations of competition infringements through restrictions on parallel imports, territorial and customer restrictions imposed on sellers, and resale price maintenance practices. Both undertakings opted for settlement in relation to the resale price maintenance allegations and thereby benefited from a reduction in fines. In this context, the Board imposed administrative fines of TRY 14.5 million (approx. EUR 271,545) on Kyocera⁶ and TRY 3.9 million (approx. EUR 73,981) on Geskokipit.⁷

In addition to the settlement, Kyocera submitted commitments addressing broader competition concerns identified in the case. In this context, Kyocera undertook not to impose restrictions on the territories or customer groups to which its dealers may sell, not to hinder parallel imports, and to eliminate competition concerns arising from non-compete and single-branding obligations included in its agreements.⁸ Similarly, Geskokipit committed not to impose restrictions on the territories or customer groups of its sub-distributors and not to engage in practices that could restrict parallel imports, thereby bringing the investigation to an end.⁹

6. The “More Favourable Regulation” test in fines: The CHI Cosmetics decision

The Board’s decision imposing an administrative fine on CHI Cosmetics for resale price maintenance was annulled by the administrative court on grounds relating to the calculation of the fine. In its 2024 decision, the Board found that CHI Cosmetics had infringed competition by fixing its buyers’ resale prices and imposed an administrative fine of approx. TRY 94,000 (approx. EUR 1,757).¹⁰

In the annulment lawsuit brought by CHI Cosmetics, the undertaking did not raise any specific objection regarding the methodology used to calculate the administrative fine. Nevertheless, the administrative court examined not only the existence of the infringement but also the calculation method applied to the fine. While the court upheld the finding that resale price maintenance had been established, it annulled the Board’s decision on the basis that, in light of the new fining regulation that entered into force after the date of the decision, the Board was required to compare the former and the new regulatory frameworks and apply the more favourable provisions to the undertaking.¹¹

Following the judgement, the Board reassessed the case under both the repealed and the new regulations on fines. It carried out separate calculations under each framework and found that the starting fine rate, duration of the infringement, and absence of aggravating or mitigating factors led to the same outcome under both regimes. As no difference arose between the two calculations, and in light of the principle prohibiting reformatio in peius, the Board confirmed that the administrative fine would remain unchanged.¹²

7. Settlement in the raw milk investigation

Within the scope of the TCA’s broad raw milk investigation, the examination concerning Konya-based dairy producer Ayca Süt concluded with a settlement in relation to allegations of resale price maintenance.¹³ The investigation concerned claims that Ayca Süt had fixed the resale prices of its buyers, imposed territorial and customer restrictions on its dealers, and introduced open-ended non-compete obligations. The undertaking admitted the resale price maintenance allegations and opted for the settlement procedure. An administrative fine of TRY 38 million (approx. EUR 713,327) was imposed on Ayca Süt. In determining the fine, the Board took into account the undertaking’s export activities as a mitigating factor, resulting in a 37.1375% reduction in the penalty.

The investigation remains ongoing with respect to the allegations concerning territorial and customer restrictions and the open-ended non-compete obligation, for which no published decision has yet been issued.

New investigations announced

• Comprehensive competition investigation into Unilever:¹⁴ As part of a sector inquiry into the industrial ice cream market, the TCA has initiated an investigation into whether Unilever complied with a previous decision concerning the abuse of a dominant position¹⁵ and the behavioural obligations imposed on the undertaking. The investigation also covers alleged anti-competitive conduct in the industrial ice cream market involving Unilever’s subsidiary, Magnum.
• Meta’s AI integration under scrutiny: The TCA launched an investigation into allegations that Meta abused its dominant position by integrating its Meta AI service into WhatsApp and by restricting third-party artificial intelligence providers from offering services through the platform.¹⁶

Footnotes

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

2 For the purposes of this document, the exchange rate of EUR 1 = TRY 53.35 has been used for currency conversion.

3 Casting Agencies (21.05.2026, 26-19/585-225).

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

5 Ay Yapım – Med Yapım Settlement (20.11.2025, 25-43/1044-596).

6 Kyocera Settlement (30.04.2026, 26-16/490-179).

7 Geskokipit Settlement (12.03.2026, 26-09/267-95).

8 Kyocera Commitment (09.04.2026, 26-13/369-145).

9 Geskokipit Commitment (12.03.2026, 26-09/267-95).

10 CHI Cosmetics – I (21.05.2025, 24-23/549/232).

11 Ankara 9. Administrative Court, decision dated 05.11.2025, Case No. E. 2025/279, Decision No. K. 2025/1591.

12 CHI Cosmetics – II (23.12.2025, 25-49/1200-679).

13 Ayca Süt Settlement (26-01/4-3).

14 Unilever – II (22.04.2026, 26-15/434-M).

15 Unilever – I (18.03.2021, 21-15/190-80).

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