Quick Read: Competition Law Updates In Türkiye – November 2025

December 2025 – November marked another dynamic month for the Turkish Competition Authority ("TCA"), showcasing its unwavering commitment to robust enforcement. From high-profile cases in the TV series market to gaming, and mobile device sales, the TCA continued to make its presence felt across diverse industries. In addition, three new gun-jumping rulings underscored the TCA's heightened scrutiny of merger control compliance.

Coupled with significant fines for obstructing on-site inspections, these developments send a clear signal: procedural and transactional compliance remain at the forefront of the TCA's enforcement priorities. This issue of Quick Read provides a concise, high-impact summary of the most notable competition law developments in Türkiye.

Dive into November Case Updates

1. Structural shake-up: Distribution of TV series reshaped

The TCA has concluded its investigation into Med Yapım and Ay Yapım, two leading TV series producers in Türkiye, concerning (i) competition concerns arising from the joint international distribution of Turkish TV series through MA Distribution (MADD), and (ii) the exchange of competitively sensitive information in labour markets. The case was closed through commitment and settlement procedures.

Under the settlement procedure, the Turkish Competition Board ("Board"), the TCA's decision-making body, found that Ay Yapım and Med Yapım infringed competition law by exchanging up-to-date, competitively sensitive information on employee wages and imposed administrative fines of TRY 75.7 million (approx. EUR 1.52 million)¹ on Ay Yapım and TRY 47.8 million (approx. EUR 963,174) on Med Yapım.²

The concerns relating to the joint international distribution of TV series through MADD were resolved through commitments.³ Specifically, the parties committed to dissolve MADD, which the Board viewed as potentially facilitating a restrictive agreement. They further committed not to engage in any other joint distribution activities. During the divestiture period, which is expected to last around 12 months, MADD will be converted into a fully functional joint venture managed by independent professional managers. Until MADD is transferred to a suitable buyer, Ay Yapım and Med Yapım will implement strict measures to eliminate any flow of competitively sensitive information among MADD's employees. If the commitments are not fulfilled within the prescribed timeframe, either Ay Yapım or Med Yapım will be required to transfer all of its shares in MADD to the other shareholder or proceed with MADD's liquidation.

In addition to these structural remedies, the parties offered a set of behavioural commitments that are binding on Ay Yapım and Med Yapım for an indefinite period. These include:

• Rights-based distribution only: They will distribute only content they own; otherwise, their titles will be distributed exclusively via independent distributors.
• No intertwined production–distribution setups: As long as they are active as both producers and distributors, they will avoid having any interlocking shareholders, managers, employees, or control links with other producer-distributor companies.
• No exclusivity deals: They will not enter into exclusive agreements with TV channels, talent, creators, or independent distributors.
• Creative mobility preserved: Writers, directors, and actors can join other projects—no lock-ins, except where an active production could be harmed.
• No foreign exclusivity clauses: International buyers will remain free to contract with other Turkish producers — no exclusivity provisions.
• Transparent, separable catalogues: All content will be offered openly and title-by-title, ensuring buyers can license each work independently.

2. Hefty fines for obstructing on-site inspections

The TCA has sent a strong message regarding cooperation during dawn raids by imposing significant fines on companies whose employees interfered with on-site inspections.

Coca-Cola faces TRY 282 million penalty: The most notable case involves Coca-Cola, which was issued an administrative fine of TRY 282.4 million (approx. EUR 5.6 million) after the Board concluded that an on-site inspection had been obstructed. The obstruction occurred when a Coca-Cola employee was found to have deleted personal messages after the on-site inspection had officially commenced.⁴

Escalating consequences for digital interference: Several other recent decisions published in November further underscore the serious consequences of interfering with TCA dawn raids. In four cases,⁵ the TCA imposed fines on companies where employees deleted either individual WhatsApp messages or entire chat contents after inspectors had arrived.

These recent actions clearly illustrate the TCA's zero-tolerance stance on digital interference during inspections.

3. Modern Times Group fined for failing to notify three acquisitions

The Board imposed fines on Modern Times Group, an international gaming group, for acquiring the mobile game developers Plarium, Snowprint, and AutoAttack without securing competition approval first.⁶ The transactions fall within the TCA's jurisdiction, as mobile games qualify as "technology undertakings" for which a more restrictive turnover threshold regime applies, and therefore a transaction can be notifiable irrespective of local turnover in Türkiye. While Modern Times Group argued that it was unaware of the technology undertaking exemption, the Board emphasised that lack of awareness of the exemption cannot justify failing to notify the transaction. As a result, the Board imposed administrative fines equal to 0.1% of Modern Times Group's turnover for each transaction separately, while also granting approval to them retrospectively.

4. Take-Two acquires "Color Block Jam" amid dissent

The Board approved the acquisition of sole control over the mobile game "Color Block Jam" by Take-Two (a video games publisher that owns major game development studios Rockstar, Zynga, and 2K) by a majority vote.⁷

The dissenting opinion highlighted several concerns. According to the dissent, the transaction clearly affected both horizontal and vertical markets, yet the review report relied solely on generic data from the notification form, citing the absence of affected markets and low market shares as justification for not conducting a deeper analysis. The dissenting member noted that the vertical supply chain, the gaming ecosystem, and the dominance of incumbent players were not properly considered, nor were the pre- and post-transaction competitive effects analysed. The dissenting member warned that the deal could constitute a potential "killer acquisition" and concluded that the report did not adequately address theories of harm, resulting in an incomplete and non-holistic assessment.

5. Datagate and Arena receive individual exemption for contract transfer

The Board granted an individual exemption for the planned Commercial Contract Transfer Protocol between Arena Connect, active in the sale of telecommunications products, and Datagate, active in the distribution of IT and telecom products.⁸

The Protocol provides for the transfer to Datagate of Arena's rights and obligations to provide device distribution services within a defined region for Vodafone Türkiye. Under the agreement, Arena undertakes a non-compete obligation for a period of three years from the effective date of the contract. The Board concluded that the non-compete obligations are reasonable, as they enable Datagate to effectively acquire Arena's customer portfolio, operational know-how, and distribution infrastructure and recover its investment. The restrictions are limited to the products and product groups covered by the Protocol and do not exceed three years, justifying the granting of an individual exemption.

New Investigations and Oral Hearings Announced

New Investigations:

• Dyson under investigation:⁹ The TCA has launched an investigation into Dyson Turkey, which is active in the home appliances and vacuum cleaner markets, on the grounds that its practices may have aimed to restrict parallel imports and interfered with resale conditions. The investigation will also scrutinise Dyson's selective distribution system and the mechanisms it employs to preserve that system's integrity.
• Muya faces competition probe:¹⁰ The TCA has opened an investigation into Muya, a company active in the production and distribution of slippers and footwear, over allegations that Muya fixed the resale prices of both brick-and-mortar retailers and online distributors and restricted distributors' passive sales.

Oral Hearings:

• Chlor-Alkali sector investigation: The oral hearing in the investigation concerning seven undertakings operating in the chlor-alkali sector, launched on allegations of anti-competitive agreements, will be held on 16 December 2025.
• Koruma Klor Investigation: The oral hearing in the abuse of dominance investigation against Koruma Klor Alkali San. ve Tic. AŞ, also active in the chlor-alkali sector, will be held on 16 December 2025.

Stay tuned for our next issue of Quick Read, where we will continue to bring you the latest in competition law developments in Türkiye.

Footnotes

1 EUR figures throughout this document have been converted at the exchange rate EUR 1 = TRY 49.64.

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

3 Ay Yapım – Med Yapım Commitment (20.11.2025, 25-43/1043-595).

4 Coca-Cola (25.11.2025).

5 Uğur Beton (28.08.2025, 25-32/755-447), Tekyol Beton (28.08.2025, 25-32/756-448), IWALLET (14.08.2025, 25-31/726-431), Tahsildaroğlu (30.04.2025, 25-17/409-190).

6 MTG/Plarium (25.09.2025, 25-36/856-504), MTG/Snowprint (25.09.2025, 25-36/857-505), MTG/AutoAttack (25.09.2025, 25-36/858-506).

7 Take-Two/Color Block Jam (31.07.2025, 25-28/665-403).

8 Datagate/Arena (31.08.2025, 25-28/674-406).

9 Dyson (06.11.2025, 25-41/1007-M).

10 Muya (02.10.2025, 25-37/891-M).

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.