Quick Read: Competition Law Updates In Türkiye – April 2026

May 2026 – April was another exceptionally active month for the Turkish Competition Authority (“TCA”), marked by a broad enforcement agenda, from global technology giants to investigations in the healthcare sector, as well as important policy and guideline developments regarding digital market strategies. Global payment system leaders Mastercard and Visa secured the closure of the investigations against them through commitments, while the cartel fine imposed on MediaMarkt—and the newly launched investigation extending to Dassault Systèmes distributors—signalled the TCA’s continued close scrutiny of digital and retail markets.

On the other hand, the comprehensive investigation into the orthopaedics and neurosurgery sector, together with bid-rigging cases involving panel manufacturers, demonstrated the TCA’s increasing focus on public tenders and the healthcare industry. On the policy front, the TCA updated its merger control guidelines to address long-standing practical uncertainties and launched its “Competition Policies in the Digital Age” initiative, offering important clues as to the future direction of Turkish competition law enforcement. Meanwhile, resale price maintenance remained firmly at the top of the enforcement agenda, reaffirming the TCA’s uncompromising approach towards vertical restraints. This issue of Quick Read provides a concise overview of the most notable competition law developments shaping the Turkish market throughout April.

TCA updated merger control guidelines

Following the amendments made to Communiqué No. 2010/4 on Mergers and Acquisitions Requiring the Approval of the Competition Board in February 2026, the TCA has now aligned its merger control guidelines with the revised framework. Far from being a purely technical update, the amendments provide important clarifications aimed at resolving several practical uncertainties in merger control practice. Among the most notable changes, the TCA clarified that the three-year pre-transaction turnover calculation rule will also apply to joint-venture transactions. The updated guidelines further confirm that Turkish sales must be included in the calculation of worldwide turnover and introduce specific criteria for determining Turkish turnover in transactions involving the acquisition of technology undertakings. The revised guidelines also provide additional explanations and practical examples regarding the definition of “undertakings concerned” in joint ventures. In parallel, the guidelines on horizontal and non-horizontal mergers now offer greater insight into how potential coordination effects between parent companies arising from joint ventures will be assessed by the TCA.

These developments are likely to have a direct impact on notification obligations and turnover calculation methodologies, particularly for undertakings that frequently engage in M&A activity in the technology sector and other innovation-driven markets. You can read our detailed analysis of the implications of these updates for merger notification processes here.

Dive into April case updates

1. New rules in the card payments and digital wallet markets: Mastercard and Visa commitment decision

The investigation into global payment system giants Mastercard and Visa initiated in October 2024 was concluded through commitments.¹ The investigation identified competition concerns in the scheme services market, where both undertakings were found to be creating hindrances for rivals, and in the digital wallet services market in relation to Mastercard’s activities through Masterpass. To address these concerns, Mastercard and Visa committed to making the discounts and incentives they offer to their customers more transparent, objective, and proportionate, and to improving the interchange fee rates applied to cross-border transactions. Mastercard also submitted additional commitments regarding product placement and campaign conditions in its contractual and de facto relationships with merchants using Masterpass, thereby addressing the competition concerns in the digital wallet services market as well.

In its announcement, the TCA noted that the commitments are expected to increase the diversity of digital wallet options available to consumers in e-commerce markets and improve the visibility of alternative payment service providers on payment screens. The TCA also underlined the broader positive impact that these measures may have on the Turkish banking system and the overall card payment ecosystem.

2. New competition standards in the pharmacy channel for Orzaks

The investigation conducted against pharmaceutical and food supplement producer Orzaks İlaç ve Kimya Sanayi Ticaret A.Ş. (“Orzaks”) was concluded through settlement and commitment procedures. Under the settlement, Orzaks accepted a monetary fine of TRY 35.7 million (approx. EUR 667,815)² for restricting online sales by pharmacies in violation of competition rules.³ In addition, Orzaks submitted binding five-year commitments and is subject to annual reporting aimed at addressing competition concerns arising from purchasing obligations imposed on pharmacies, requirements to stock certain product groups together, and various discounts used to foreclose competitors from the pharmacy channel.⁴ The binding commitments are as follows:

• D3/D3K2 promotion ban: No shelf support or meal voucher (ticket) support will be provided for D3 and D3K2 vitamin products, and these products will be excluded from holiday campaigns targeted at pharmacists.
• Objective criteria for purchase support: Where purchase support is provided to pharmacies, the support amounts will be determined based on objective criteria, with a distinction drawn between pharmacies at specific locations and other pharmacies.
• Discount restriction: No discount other than free goods may be applied to products other than D3 and D3K2.
• Periodic campaign option: Apart from free goods schemes, uniform periodic campaigns targeting end consumers, such as promotional materials, extra products, or discounted products, may be organised.
• Freedom of choice notice on product lists: The statement “Dealers are free to choose any product they wish” will be included at the end of product lists in a clearly and easily readable format.
• Shelf freedom guarantee in contracts: Contracts will include an express statement that pharmacies may use their shelves as they wish, including to display and feature competing products.

3. Hub-and-spoke cartel in household appliances market: The MediaMarkt decision

The investigation concerning allegations of indirect information exchange among major technology retailers Teknosa İç ve Dış Ticaret AŞ (“Teknosa”), Vatan Bilgisayar San. ve Tic. AŞ (“Vatan”), and Media Markt Turkey Tic. Ltd. Şti. (“MediaMarkt”) through Fakir Elektrikli Ev Aletleri Dış Ticaret AŞ (“Fakir”), active in the small household appliances sector, has concluded. Following its assessment, the Turkish Competition Board (“Board”) found that MediaMarkt violated Article 4 of Law No. 4054 by participating in a hub-and-spoke cartel arrangement and/or concerted practice in which Fakir functioned as the “hub”. Accordingly, the TCA imposed an administrative fine of approximately TRY 330 million (approx. EUR 6.2 million).⁵ The other parties named in the same investigation—Vatan,⁶ Teknosa⁷ and Fakir⁸—opted to settle with the TCA, allowing the proceedings against them to be terminated at an earlier stage.

4. Bid-rigging in electricity distribution tenders: 10 panel manufacturers resolve investigation through settlement

The investigation into alleged bid-rigging and market allocation by ten undertakings active in the production and sale of control and command panels in tenders organised by certain electricity distribution companies was concluded through settlement.

As part of the settlement process, all undertakings benefited from a 25% reduction in their administrative fines. The Board also applied different mitigating factors for each undertaking and, notably, relied on the principle of applying the more favourable provision when determining the applicable administrative fine regime. Accordingly, the former regulation on fines was applied to AFB, Aksan, Altınsoy and Panobel, while the new regulation was applied to ATCE, BAB, Biçer, Çağdaş, Etien and LMS, depending on which framework resulted in a more favourable outcome for each undertaking. The Board further recognised several mitigating factors in its assessment. For AFB, Aksan and Panobel, the relatively limited share of the infringing activities within their annual gross revenues was considered. For Altınsoy, Biçer, Çağdaş and Etien, the inclusion of export revenues in the turnover used as the basis for the fine calculation was considered a mitigating factor. Meanwhile, for ATCE and BAB, the limited scope of participation in the infringement resulted in additional reductions.

5. Parex settlement decision: RPM and application of the new regulation on fines

The Board has published its reasoned decision concerning Parex, which was fined approximately TRY 10.5 million (approx. EUR 197,385) for resale price maintenance (“RPM”).⁹ The decision is significant both in terms of the concrete evidence of infringement and the application of the more favourable regulation on fines.

• Infringement findings: Internal communications reportedly contained explicit instructions aimed at setting minimum shelf prices (“do not go below TRY 990”), intervening in the timing of price changes (“lower the price in the evening, keep it unchanged during the day”), and threatening non-compliant distributors with sanctions, including the “suspension of support”
• Application of the more favourable regulation on fines: The Board considered the removal of the 60% cap on mitigating factor reductions under the new regime on fines to be more favourable for the undertaking compared to the former regulation. Accordingly, by accepting export revenues as a mitigating factor in the fine calculation, Parex was able to benefit from a higher reduction rate without being subject to the former 60% ceiling.

New Investigations, Sector Inquiries and Oral Hearings Announced

New investigations and sector inquiries:

• Dassault SolidWorks distributors under scrutiny:¹⁰ The investigation launched against Dassault Systèmes in December 2025 has now expanded to include its authorised distributors in Türkiye following the findings obtained during the preliminary stages of the proceedings. In this context, the Board decided to initiate investigations against Yenasoft, ABK, Metropolsoft, Tekyaz, Armada, and Ses3000. The investigation reportedly focuses on several serious competition law concerns, including (i) alleged coordination of prices and payment terms, (ii) customer allocation practices among distributors, and (iii) potential no-poach agreements restricting employee transfers between market players.
• Comprehensive investigation in orthopaedics and neurosurgery products:¹¹ The Board launched a comprehensive investigation into 29 undertakings operating in the orthopaedics and neurosurgery product market, as well as four trade associations. The findings at the preliminary investigation suggest suspicions that market players artificially inflated prices by restricting the supply of products to the public sector. Within the scope of the investigation, it will be assessed whether (i) prices in fields such as arthroplasty and arthroscopy were jointly determined and imposed across the entire market without distinction between public and private customers, (ii) the supply of products to the public sector was co-ordinately restricted based on the prices set under the Health Implementation Communiqué (SUT), and (iii) the supply of products to the public sector was co-ordinately restricted based on SUT prices.
• RPM investigation into Hobi:¹² The Board has initiated an investigation into Hobi Kozmetik and RA Pazarlama (together, the “Hobi” economic unity), subsidiaries of Dabur International, one of the key players operating in the personal care sector. The investigation focuses on allegations that Hobi interfered with retail-level pricing and engaged in resale price maintenance. The examination covers the sales and distribution practices of a broad portfolio comprising more than 200 products, including shampoos, shower gels, and various hair care items.
• Digital competition policy study:¹³ The TCA launched a comprehensive study aimed at analysing the impact of digitalisation on market dynamics and developing a new policy framework in this area. The study seeks to transform the TCA’s accumulated experience in digital markets into a strategic report. The key focus areas are:

— Global comparison: A comparative assessment of ex-ante regulatory approaches and ex-post enforcement tools based on examples from the EU, the United Kingdom, and Germany.

— Effectiveness of digital tools: Evaluation of the applicability of enforcement mechanisms such as sanctions, interim measures, and commitment procedures in digital markets.

— Policy update: Identification of areas where traditional tools are insufficient in addressing digital dynamics such as data ownership and network effects, and development of an updated roadmap for Türkiye.

The report to be prepared is expected to serve as an expanded continuation of the TCA’s previously published digital transformation studies and to strengthen Türkiye’s policy framework for digital markets.

Oral Hearings:

• Casting agencies investigation:¹⁴ The oral hearing in the investigation into alleged violations of Law No. 4054 by the Casting Agencies Association and casting agencies and managers was held on 6–7 May 2026.
• Koroplast-Vindex investigation:¹⁵ The oral hearing in the investigation into alleged violation of Article 4 of Law No. 4054 through the exchange of competitively sensitive information by Koroplast and Vindex was held on 12 May 2026.

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

2 For the purposes of this document, the exchange rate of EUR 1 = TRY 53.43 has been used for currency conversion.

3Orzaks Settlement (16.04.2026, 26-14/401-156).

4Orzaks Commitment (16.04.2026, 26-14/402-157).

5 MediaMarkt (02.04.2026, 26-11/343-130).

6 Vatan Settlement (28.05.2025, 25-21/517-341).

7 Teknosa Settlement (28.05.2025, 25-21/509-338).

8 Fakir Settlement (28.05.2025, 25-21/508-337).

9 Parex Settlement (11.12.2025, 25-46/1151-646).

10 Dassault Distributors (16.04.2026, 26-14/399-M).

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

12 Hobi Kozmetik (02.04.2026, 26-11/335-M).

13 Competition Policies in the Digital Age Study (14.04.2026).

14 Casting Agencies (12.12.2024, 24-53/1175-M).

15 Koroplast-Vindex (20.12.2024, 24-54/1189-M).