Quick Read: Competition Law Updates In Türkiye – July 2026

August 2026 – The Turkish Competition Authority (“TCA”) placed significant emphasis on both market structure and procedural enforcement in July. Two major retail and food-sector transactions received conditional clearance, with the TCA requiring A101 and Cargill Türkiye to implement extensive commitments addressing concerns ranging from store concentration and supplier access to pricing, supply, and cross-subsidisation.

The TCA also maintained its strict approach to procedural compliance, as reflected in the reasoned decisions published this month concerning TEMU, MLP, Allianz, and Mapfre, which involved obstruction of onsite inspections and failures to provide requested information. In addition, the TCA concluded its investigation into Avixa and Avigem through settlement and commitment procedures, imposing fines alongside commitments concerning the availability and reimbursement status of a nasal spray.

This issue of Quick Read provides a concise overview of the most notable developments shaping the Turkish market throughout July.

pe into July case updates

1. A101 acquires Carrefour SA, but the Board writes the fine print: Stores, jobs, and local suppliers

The Turkish Competition Board (“Board”) has conditionally cleared the acquisition of CarrefourSA by A101, Türkiye’s largest discount retailer, A101.¹ In its review, the Board found that the transaction could significantly impede effective competition in the FMCG organised retail market. A101 offered structural and behavioural commitments, including:

• pestment of 48 stores: A101 will pest 10 of its own stores and 38 CarrefourSA stores in locations where the TCA identified competition concerns.
• Separate organisation: CarrefourSA will continue to operate under an organisational structure independent of A101, with separate management and employees responsible for the companies’ day-to-day operations.
• Employment protection: A101 will maintain, and where reasonably possible increase, the combined employment level of A101 and CarrefourSA for three years following closing.
• Support for SMEs and local suppliers: For three years, A101 will support at least 75 SMEs or local producers and suppliers each year through a dedicated support program covering areas such as in-store visibility, marketing, digital channels, data analytics.
• Support for regional products and domestic agricultural products: A101 will implement a comprehensive communication and positioning strategy under an “umbrella brand” approach to preserve regional products, support the sustainability of domestic agricultural products, and increase their visibility among consumers.

2. Sweet deal, strict conditions: Board clears Cargill/PNS acquisition subject to commitments

The Board has conditionally approved Cargill Türkiye’s acquisition of PNS, a starch producer, subject to a package of behavioural commitments offered by the parties.² The Board concluded that the transaction could significantly impede effective competition in the market for glucose syrup and glucose syrup mixtures. Nevertheless, it found that the proposed commitments were sufficient to address its concerns and therefore granted conditional clearance. The commitments address three main areas:

• Pricing practices: Cargill Türkiye will limit price increases for quota-regulated products sold in the domestic market to specified cost elements. For five years, it will provide the TCA with reports enabling it to monitor pricing and cost data. Cargill Türkiye must also notify the TCA of any price adjustments made in response to extraordinary economic conditions, and the TCA may require such adjustments to be reversed.
• Risk of supply restrictions: Cargill Türkiye will ensure continuity of supply to customers. It may terminate existing contracts only on objective grounds and must apply objective commercial criteria to spot sales. It must also notify the TCA if it suspends supply due to extraordinary economic conditions, and the TCA may require it to reverse the relevant decision.
• Risk of cross-subsidisation: Cargill Türkiye will not use revenues generated from domestically sold quota-regulated glucose syrup and glycose syrup mixtures to subsidise other product groups.

3. TCA fines Avixa for withholding a nasal spray from the market

The TCA has concluded its investigation into the economic unit comprising Avixa İlaç and Avigem İlaç (collectively, “Avixa”) through commitment and settlement procedures and imposed an administrative fine of TRY 23.8 million (approximately EUR 0.43 million)³ on Avixa.⁴

The investigation concerned Avixa’s decision not to market one of the two nasal sprays it distributes, thereby preventing competitors from entering the market for dual-active-ingredient nasal sprays. According to the Board, this conduct had exclusionary effects and resulted in public harm.

• The Board found that, although one of the products was subject to a higher reimbursement discount under Türkiye’s Social Security Institution reimbursement scheme, it was kept at a market availability level of below 1%. The Board considered this practice both exclusionary and exploitative and concluded that it constituted an abuse of dominance.
• In addition, the Board accepted Avixa’s commitments concerning the suspension and cancellation of the product’s marketing authorisation and its removal from the Social Security Institution’s reimbursement list.⁵

4. No entry, no cooperation: Board fined TEMU for obstructing inspection and withholding information

The TCA has published its reasoned decisions imposing two separate administrative fines on TEMU in connection with an onsite inspection conducted as part of a preliminary investigation into whether TEMU restricted competition by intervening in the prices set by sellers on its platform.

• Obstructing the onsite inspection: The Board found that TEMU obstructed and hindered the inspection by failing to provide access to its offices, its organisational chart, or a designated employee to act as a point of contact for the inspection team. The Board imposed a fine corresponding to 0.5% of TEMU’s annual gross revenue.⁶
• Failing to provide information: In a separate decision, the Board fined TEMU for failing to provide its 2025 Turkish revenue within the prescribed deadline, which the TCA had requested in order to calculate the above fine. The Board imposed an additional fine corresponding to 0.1% of TEMU’s annual gross revenue, together with a daily fine of 0.05% for each day of continued non-compliance. TEMU provided the requested information two days after the deadline, triggering the daily fine for those two days.⁷

After completing its preliminary investigation, the Board concluded that there were insufficient grounds to initiate a full-fledged investigation.

5. Three more dawn raid penalties: Board fines MLP, Allianz, and Mapfre

The TCA has published its reasoned decisions imposing administrative fines on MLP, Allianz, and Mapfre for obstructing onsite inspections conducted as part of the same preliminary investigation into potential competition law violations in the health insurance market. The three decisions once again highlight the TCA’s strict approach to data deletion during onsite inspections:

• MLP (the owner/operator of Medical Park and Liv Hospital chains):⁸ The TCA found that more than 1,000 emails were deleted from an employee’s email account during the inspection. The company could not provide evidence supporting the employee’s explanation regarding the deleted folder, and the deletion ultimately disrupted the inspection process.
• Allianz:⁹ The TCA treated the deletion of messages from a WhatsApp group and inpidual chats after the inspection had started as an attempt to destroy evidence. The fact that the employees used company phones and the deleted communications concerned business matters supported the TCA’s finding that the conduct hindered access to potentially relevant evidence.
• Mapfre:¹⁰ The TCA found that an employee deleted messages from a Microsoft Teams group after the inspection had started. The deleted data could not be restored during the inspection, preventing the inspection team from examining the relevant group. The TCA therefore considered the deletion sufficient to constitute obstruction or hindrance of the inspection.

These decisions reinforce the TCA’s established position that deleting data after an onsite inspection has commenced may itself constitute an obstruction, regardless of whether the deleted content can ultimately be recovered or whether it concerns business or personal matters.

6. May Tohum commits to reshaping its distribution model

The TCA has published its reasoned decision concluding its investigation into May-Agro Tohumculuk (“May Tohum”), an undertaking active in seed production, marketing, and R&D, concerning alleged territorial and customer restrictions imposed on its resellers.¹¹ The investigation followed an earlier proceeding concerning resale price maintenance, which May Tohum had previously resolved through settlement.

The Board accepted May Tohum’s commitments addressing the identified competition concerns. Under the new model, May Tohum will:

• Revise its distribution agreements: May Tohum will implement a combination of exclusive and non-exclusive dealership arrangements, with exclusive territories established only where permitted under applicable competition rules.
• Respect passive sales: May Tohum will not restrict active or passive sales in non-exclusive territories and will not interfere with passive sales in exclusive territories.
• Reorganise dealer categories and agreements: May Tohum will restructure its dealer agreements and distinguish between wholesale and retail arrangements, with exclusive territories and/or customer allocations no longer being granted under retail agreements.
• Strengthen competition compliance: May Tohum will provide annual competition law training to its employees to maintain awareness of competition law requirements.

7. Sharing future prices comes at a cost: Parex settles for TRY 8.4 million

The TCA has published its reasoned decision concluding, in relation to Parex, its investigation into Koroplast, Parex, and Vindex, undertakings active in the household cleaning products sector, concerning the alleged exchange of competitively sensitive information.¹²

Parex accepted the allegations that it had exchanged information with Koroplast regarding current and future market prices, as well as the timing and magnitude of planned price increases, and settled with the TCA. Following the settlement procedure, the Board imposed an administrative fine of TRY 8.4 million (approx. EUR 153,000) on Parex, reflecting a 25% settlement discount.

New Investigations Announced

• Nuclear medicine market under scrutiny:¹³ The TCA has initiated an investigation into 11 undertakings operating in the nuclear medicine market over allegations of bid rigging and/or concerted practices, particularly in relation to public procurement tenders organised by public hospitals. The investigation focuses on whether the undertakings coordinated their conduct in tenders concerning certain tomography devices and whether such conduct may have restricted competition. In particular, the TCA will examine the parties’ bidding behaviour, the competitive conditions prevailing in the relevant tenders, and the potential impact of the alleged conduct on competition in the market.

Footnotes

1. A101/CarrefourSA (30.07.2026, 26-27/789-331).

2. Cargill/PNS (30.06.2026, 26-23/685-275).

3. The exchange rate of EUR 1 = TRY 55.08 is used throughout this document.

4. Avixa Settlement (23.07.2026, 26-26/748-308).

5. Avixa Commitment (23.07.2026, 26-26/748-308).

6. TEMU Obstruction of on-site inspection (03.02.2026, 26-04/115-44).

7. TEMU Failure to provide information (05.02.2026, 26-04/116-45).

8. MLP Sağlık (16.03.2026, 26-10/301-116).

9. Allianz Sigorta (16.03.2026, 26-10/299-114).

10 Mapfre (16.03.2026, 26-10/300-115).

11. May Tohum Commitment (04.06.2026, 26-20/604-240).

12. Parex Settlement (11.12.2025, 25-46/1150-645).

13. Nuclear Medicine Market (30.04.2026, 26-16/481-M).