Turkish Competition Board Concludes Preliminary Investigation into Preferential Visa Appointment Practices Through Commitments
The Turkish Competition Board (the “Board”) has concluded its preliminary investigation into VF Vize Danışmanlık Hizmetleri Tic. Ltd. Şti. (“VF Vize”), Gateway Management Lojistik AŞ (“Gateway”) and Camelot Air Travel Tur. ve Tic. AŞ (“Camelot”) through commitments.
The proceedings concerned allegations that Camelot received preferential access to visa appointment slots through Gateway’s relationship with VF Vize, thereby making it more difficult for competing travel agencies to obtain appointments for their customers. The Board accepted separate commitment packages submitted by VF Vize and by Gateway and Camelot. The commitments became binding and the Board decided not to open a full investigation against the relevant parties.
1. BACKGROUND
The Board’s preliminary investigation focused on the relationship between the parties. VF Vize operates visa application centers on behalf of diplomatic missions and has appointed Gateway as its subcontractor for various operational activities. Camelot, which is within the same economic unit as Gateway, provides visa consultancy services to employees of corporate clients and, where applicable, their first-degree relatives.
According to the Board’s assessment, visa appointment quotas are determined by the relevant diplomatic missions and subsequently opened for applications through the visa application centers. Diplomatic missions do not allocate these quotas to specific travel agencies. Therefore, travel agencies should have equal access to the available appointment quotas.
2. THE BOARD’S COMPETITION CONCERNS
The evidence obtained during the preliminary investigation indicated that Camelot had received preferential treatment when obtaining visa appointments for its customers. In particular, the evidence suggested that Gateway had allocated specific appointment quotas to Camelot, arranged appointments for Camelot’s customers upon request and prioritized Camelot’s customers at VF Vize’s visa application centers.
The Board also found indications that Camelot was informed about the timing of the release of appointment slots, allowing it to reserve appointments for its customers more easily than competing agencies. Internal communications further suggested that the parties attempted to avoid creating the perception that Camelot was consistently receiving preferential treatment.
The Board considered that these practices could make it more difficult for competing travel agencies to obtain appointments for their customers and could therefore restrict competition in the market for visa consultancy services.
The Board also considered the market position of VF Vize. In 2025, VF Vize provided visa application center services for 28 countries and accounted for 75.6% of the countries for which visa applications were accepted through visa application centers in Türkiye. The Board therefore considered VF Vize to have significant market power and to be an important business partner for travel agencies offering visa consultancy services.
The Board assessed the alleged preferential treatment under Article 4 of Law No. 4054 on the Protection of Competition (“Law No. 4054”). The Board considered that the conduct reflected a common intention between VF Vize and Gateway and could give Camelot an advantage over competing travel agencies. The Board therefore considered that the conduct raised competition concerns under Article 4 of Law No. 4054.
3. COMMITMENTS SUBMITTED BY VF VIZE
VF Vize submitted two main commitments aimed at eliminating the risk of preferential treatment and improving the security of its appointment system.
- No preferential treatment
VF Vize committed not to grant preferential treatment to any visa consultancy agency. It will introduce a central appointment management system, restrict Gateway’s access to the system and ensure that appointment quotas are managed exclusively by authorized VF Vize personnel.
- Increased security of the appointment system
VF Vize also committed to maintaining and strengthening measures against bots and other abusive access methods, including IP and e-mail restrictions, VPN limitations, waiting lists, foreign credit card restrictions and enhanced OTP verification. An API rate-limiting system was to be fully implemented by 31 March 2026. VF Vize further undertook to work with third-party technical providers and establish an internal team to monitor and improve system security.
The Board considered these commitments sufficient and proportionate to address the identified competition concerns.
4. COMMITMENTS SUBMITTED BY GATEWAY AND CAMELOT
The commitments were designed to eliminate Camelot’s preferential position. Camelot committed to terminating its visa consultancy activities, while Gateway committed that its economic unit would not provide visa consultancy services through any travel agency and would not grant preferential treatment to any travel agency.
- Camelot’s exit from visa consultancy
Camelot committed to terminating its visa consultancy activities within 30 days of notification of the Board’s short-form decision. Ongoing applications initiated before that date may be completed. Camelot must also notify its customers and corporate clients in writing.
- Removal of related content
Within the same 30-day period, Camelot must remove all visa consultancy-related content from its website, social media accounts, call center, promotional materials and other communication channels.
- Restrictions on Gateway’s activities
Gateway committed that its economic unit would not provide visa consultancy services through any travel agency. Gateway also undertook not granting any travel agency preferential treatment in relation to visa appointments.
CONCLUSION
The decisions highlight the Board’s increasing use of commitments to address discriminatory access concerns. They also confirm that preferential treatment granted to a related undertaking may raise concerns under Article 4 of Law No. 4054 where it gives that undertaking an advantage over competitors.
In this case, the Board accepted commitments including Camelot’s exit from the visa consultancy business, independent management of appointment quotas, restrictions on system access, enhanced technical safeguards and the appointment of compliance officers. By its decisions dated 26 February 2026 and numbered 26-07/217-78 and 26-07/216-77, the Board made these commitments binding and decided not to open a full investigation.
