Overview of the 2025 Annual Report of the Turkish Competition Authority

The Turkish Competition Authority (the “TCA“) published its 2025 Annual Report (the “Report”) on its website on 4 March 2026. The Report includes the TCA’s activities for 2025 and related statistical data, changes in legislation and the TCA’s goals and policies.

2025 IN NUMBERS

Compared to 2024, the total number of decisions finalised by the Turkish Competition Board (the “Board”) in 2025 increased by approximately 9%, from 487 cases in 2024 to 530 cases in 2025. Of these, 416 were related to mergers and acquisitions, 104 to infringement decisions and 10 to individual exemptions and negative clearances.

Infringement Decisions:

• Out of the 104 infringement decisions taken by the Board, 89 came at the end of an investigation process and 15 came after a preliminary investigation. By comparison, out of the Board’s 166 infringement decisions in 2024, 139 decisions came at the end of an investigation process and 27 after a preliminary investigation. In this respect, it can be said that 2025 represents a significant increase compared to 2024.
• Looking at the outcomes of the infringement decisions, we note that, out of the 89 investigation files, administrative fines were imposed on undertakings in 23 cases following the ordinary investigation procedure, while 47 cases were concluded through a settlement, resulting in administrative fines. In 11 cases, investigations were concluded with commitments without the imposition of fines, whereas in 7 cases the ordinary investigation process established there had been no infringement.
• The infringement decisions mostly concerned five sectors: (i) agriculture and agricultural products, (ii) machinery industry, (iii) the labour market, (iv) food industry, and (v) construction.
• As a result of the infringement decisions, a total of TRY 8.26 billionin administrative fines were imposed in 2025. The sectoral distribution of the administrative fines is as follows:

Mergers and Acquisitions:

• The Board decided on a total of 416 applications, including 4 mergers, 286 acquisitions, 107 joint ventures and 19 privatisations in 2025. This represents an approximately 34% increase compared to the 311 transactions in 2024.
• Out of the 416 mergers and acquisitions reviewed by the Board, 381 were granted unconditionally and ten with conditional permissions. Twenty-five of the transactions were not permitted, as the Board concluded that they were out of its scope or not subject to permission.
• The highest number of merger and acquisition decisions relate to the following sectors: (i) information technologies and platform services, (ii) automotive and vehicles, (iii) chemicals and mining, (iv) health services, and (v) infrastructure services. Decisions in these sectors account for a significant share of all merger and acquisition decisions.
• Although the duration of the merger and acquisition transactions notified to the TCA varies, depending on the scope of the file and the volume of the transaction, the TCA announced that the applications are finalised after an average of 10 days from the last notification date (the last day of information sharing).
• In 162 of the 416 mergers and acquisitions reported, the target companies were established in Turkey, with 55 transactions involving foreign investors investing in Turkish companies.
• With nine transactions, Germany-based investors ranked first place in terms of transactions involving target companies originating from Turkey. According to the Report, for mergers and acquisitions where the target company is based in Turkey, the reported transaction value is approximately TRY 466.1 billionand the total foreign investment envisaged mergers, acquisitions and privatisation transactions involving Turkish companies amount to TRY 574.1 billion.

Exemptions and Negative Clearances:

• In 2025, the Board issued a total of ten decisions in exemption and negative clearance files, including two negative clearance decisions and eight exemption decisions. Of the exemption decisions, five granted individual exemptions, two granted conditional individual exemptions and one rejected the request for exemption.
• The 2025 exemption and negative clearance decisions related to: (i) banking, capital markets, finance and insurance services, (ii) automotive and vehicles, (iii) machinery industry, (iv) construction and (v) logistics, warehousing and postal services.

CHANGES IN LEGISLATION

Legislation Amendments in 2025

• Regulation Amending the Regulation on Promotion and Title Change of the Competition Authority Personnel
• Regulation on the Organisation of the Competition Authority
• Communiqué Amending the Communiqué on Block Exemption for Settlement Agreements (Communiqué No: 2025/2)
• Draft Guidelines on the Examination of Digital Data in On-Site
• Communiqué on the Regulation of the Right of Access to the File and the Protection of Trade Secrets
• Amendment to Article 23 of Law No. 4054 on the Protection of Competition

ONGOING STUDIES

• Guidelines on the General Principles of Exemption
• Communiqué on the Procedures and Principles to be Followed in Pre-Notifications and Authorisation Applications to be Submitted to the Competition Authority for Acquisitions through Privatisation to Gain Legal Validity
• Communiqué on Block Exemption for Vertical Agreements (No. 2002/2)
• Guidelines on Vertical Agreements
• Guidelines on Horizontal Cooperation Agreements
• Regulation on On-Site Inspections
• Guidelines on On-Site Inspections
• Regulation on Active Cooperation for Detecting Cartels
• Guidelines on the Exclusionary Conduct of Dominant Undertakings
• Sustainability Guidelines

CONSIDERATIONS

• The 2025 Report shows that the TCA has further intensified its sector inquiries and market studies, with a view to identifying and addressing behavioural and/or structural competition concerns in key sectors and markets, including those affected by digitalisation and post‑earthquake reconstruction.
• In 2025, economic analysis and research activities continued to play a central role in the TCA’s enforcement practice. Econometric and data‑driven assessments were increasingly relied upon in investigations, merger control and policy work, as reflected in the 2025 Merger and Acquisition Outlook Report and the ongoing 2025‑2026 impact assessment study.
• According to the report, the TCA’s ongoing work on the forthcoming Sustainability Guidelines – which is expected to clarify how sustainability-driven cooperation between undertakings will be assessed under Turkish competition law – confirms that the Authority will continue to align its enforcement and policy tools with global trends, while also seeking to provide greater legal certainty for businesses pursuing green and sustainability objectives.
• The TCA is likely to remain very active in the coming years and we will continue to see the repercussions of global competition law developments and trends in Turkey.