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Türkiye Newsletter February 2026 | Competition market overview
This competition law newsletter provides an overview of the latest developments in relation to the Turkish competition market and the implementation of Law No 4054 on the Protection of Competition (the “Law”) in light of recent announcements and publications by the Competition Authority (the “Authority”), as well as decisions issued by the Competition Board (the “Board”) during November and December 2025.
ANNOUNCEMENTS
Recently Initiated Investigations
- Rubber and Plastic: The Board has initiated an investigation into Muya Poliüretan Kauçuk Sanayi ve Ticaret AŞ (MUYA) to determine whether the company violated Article 4 of the Law by setting resale prices for its authorised dealers and prohibiting passive sales. At a meeting on 2 October 2025, the Board reviewed information, documents and findings regarding these allegations. It found the evidence to be serious and sufficient and decided to initiate a direct investigation against MUYA under the first paragraph of Article 40 of the Law (Decision 25-37/ 891-M).
- Durable Goods: The Board has initiated an investigation into Dyson Turkey Elektrikli Ürünler Tic. Ltd. Şti. (“Dyson”) following allegations that it prevented parallel imports and intervened in resale conditions, thereby potentially violating Article 4 of the Law. At a meeting on 6 November 2025, the Board reviewed information, documents and findings obtained during the preliminary inquiry. It found the evidence to be serious and sufficient and decided to initiate an investigation against Dyson pursuant to Article 41 of the Law (Decision 25-41/1007-M).
- Medicine: The Board has initiated an investigation into Orzaks İlaç ve Kimya San. Tic. AŞ (“Orzaks”) to determine whether it has violated Articles 4 and 6. This follows a suspicion that it abused its dominant position through purchasing obligations imposed on pharmacies, the requirement to keep certain product groups together, and by various discounts it applied. There are also claims that it restricted resellers’ online sales by using contractual provisions.
- Seedling: The Board has initiated an investigation into 18 undertakings operating in the seedling sector and into the association Fide Üreticileri Alt Birliği, to determine whether there has been a violation of Article 4 of the Law.
Other Industries
- The Board has initiated an investigation into Kyocera Bilgitaş Turkey Document Solutions Inc. and Kyocera Document Solutions Europe Management B.V. (together “Kyocera”), as well as the distributor Geskopikit Digital Copying Inc. (“Geskopikit”)/ The investigation is to determine whether they have violated Article 4 of the Law by restricting parallel imports, imposing limitations on customers and territories to which resellers may sell without distinguishing between active and passive sales, and fixing resale prices. The Board will also assess whether the non-compete obligation and exclusive purchasing requirements in Kyocera’s dealership agreements are compatible with competition law.
- The Board has initiated an investigation into Mettler-Toledo TR Ölçüm Aletleri Ticaret Satış ve Servis Hizmetleri AŞ to determine whether there has been a violation of Article 6 of the Law by restricting the supply of spare parts to competitors in the after-sales service market and by failing to share passwords necessary for various technical operations on devices.
- The Board has launched investigations into seven undertakings operating in the field crop seed market on the grounds that they violated competition through regional/customer sharing and the exchange of competitively sensitive information. Four more undertakings were included in the scope of this investigation. In connection with this, there are also ongoing investigations into the hybrid industrial gherkin and hybrid vegetable and fruit seed markets.
Completed Investigations
Here is a summary of concluded investigations that resulted in administrative fines, specifying the nature of the violation and the administrative fines imposed:
| No | Name of the Undertaking | Type of Violation | Administrative Fine (TRY) |
| 1. | Novonesis A/S, Novozymes Berlin GmbH., Novozymes Enzim Dış Ticaret Ltd. Şti., Novozymes France S.A.S., Novozymes North America, Inc., Novozymes Switzerland AG, Synergia Life Sciences Pvt. Ltd., CHR Hansen A/S ve CHR Hansen Gıda San. ve Tic. AŞ – The economic unity formed by their companies (NOVONESIS) | Abuse of a Dominant Position | 284,509,319.04 |
SUMMARY OF KEY DECISIONS
Decision on Certain Undertakings Operating in The Production and Sale of Ready-Mix Concrete[1]
The Board initiated an investigation into certain undertakings operating in the production and sale of cement, ready-mix concrete and aggregates in the province of Malatya to determine whether the undertakings violated Article 4 of the Law by jointly fixing prices, allocating territories/customers and entering into agreements that restrict competition in labour markets.
During the investigation, the Board examined allegations that the undertakings coordinated ready-mix concrete and aggregate prices, exchanged competitively sensitive information, allocated customers and jointly determined wages of certain employee groups working in the ready-mix concrete sector, thereby restricting competition both in product markets and labour markets.
Based on its assessment obtained during on-site inspections – including WhatsApp correspondence and internal communications documenting price coordination meetings, customer allocation and wage-fixing arrangements – as well as evidence demonstrating the existence of concerted practices among competitors, the Board concluded that several undertakings had engaged in anti-competitive agreements constituting an infringement of Article 4 of the Law, while determining that no violation could be established with respect to certain other undertakings.
Mars Entertainment Group AŞ and Cj Enm Medya Film Yapım ve Dağıtım AŞ Decision[2]
The Board concluded its investigation into Mars Entertainment Group AŞ and CJ ENM, which operates in the film distribution market.
During the assessment, the Board examined whether Mars’s strong position in the cinema exhibition market could lead to the preferential treatment of CJ ENM’s films. To address these concerns, Mars submitted commitments aimed at ensuring the continued structural and operational separation of Mars and CJ ENM, including independent management structures, limitations on information exchange, and restrictions on coordination beyond ordinary commercial relations.
Following its review, the Board found that the proposed commitments were sufficient to eliminate potential competition concerns and decided to accept the commitments, thereby closing the investigation without imposing an administrative fine.
Motor Vehicle Drivers operating in Aydın Decision[3]
The Board concluded its investigation into multiple motor vehicle driving schools operating in Aydın concerning allegations of price fixing.
During the investigation, the Board found that several driving schools jointly determined course fees for different certificate categories and agreed to implement these prices collectively through the MEBSİS system. The evidence showed that the undertakings also put in place mechanisms to monitor compliance with the agreed prices, effectively restricting competition in the market.
As a result of its assessment, the Board determined that the coordinated pricing practices constituted a competition law infringement and imposed administrative fines on the undertakings involved.
Acquisition of Aposto Teknoloji ve Medya A.Ş. by , Paribu Holding A.Ş.[4]
The Board authorised the acquisition of sole control of Aposto Teknoloji ve Medya A.Ş. by Paribu Holding A.Ş.
In its assessment, the Board found horizontal overlap between the parties’ online news sites activities in Türkiye. It was deemed that this horizontal overlap between parties’ activities did not mean the transaction would create or strengthen a dominant position or significantly lessen competition in online news site market. In this regard, the Board took into account the competitive structure of the market and the presence of strong competitors in both segments.
Acquisition of Drivee Teknoloji Oto Filo Kiralama Ticaret A.Ş. Decision[5]
The Board authorised the acquisition of sole control over Drivee Teknoloji Oto Filo Kiralama Ticaret A.Ş. by Tera Yatırım Menkul Değerler A.Ş.
In its assessment, the Board found no horizontal or vertical overlaps between the parties’ activities in Türkiye. This lack of overlap meant that the transaction would not create or strengthen a dominant position or significantly lessen competition in any relevant market. In this regard, the Board took into account the competitive structure of the market and the presence of strong competitors in both segments.
FläktGroup Holding GmbH Decision[6]
The Board authorised the acquisition of sole control over FläktGroup Holding GmbH by Samsung Electronics Co.
In its assessment, the Board found horizontal overlap between the parties’ HVAC systems activities in Türkiye. It was deemed that this horizontal overlap between the parties’ activities meant that the transaction would not create or strengthen a dominant position or significantly lessen competition on the HVAC systems market. In this regard, the Board took into account the competitive structure of the market and the presence of strong competitors in both segments.
Establishment of indirect joint control by Anthos Capital V, L.P. and Anthos Tribe, L.P. over Good Job Games Bilişim Yazılım ve Pazarlama AŞ[7]
The Board authorised the establishment of indirect joint control over Good Job Games Bilişim Yazılım ve Pazarlama A.Ş. (“Good Job Games”) by Anthos Capital V, L.P. and Anthos Tribe, L.P. through Good Job International Limited. Prior to the transaction, Good Job Games was jointly controlled by Nazif İlker Ilıcalı and Menlo Ventures. Following the transaction, Anthos joins the existing shareholders and acquires joint control through veto rights attached to certain share classes, resulting in a change in the control structure of the target company.
In its assessment, the Board examined whether the transaction constitutes the creation of a full-function joint venture. It concluded that Good Job Games operates as an independent economic entity with sufficient resources, autonomous management and the ability to carry out its activities on a lasting basis, independent from its parent companies. Accordingly, the transaction was qualified as a notifiable concentration within the meaning of Communiqué No. 2010/4. The Board found no horizontal or vertical overlaps in Türkiye, as Anthos and its controlling entities do not generate turnover or conduct activities on the Turkish market. Given the absence of affected markets and competitive links between the parties, the transaction was not expected to result in a significant restriction of effective competition. On this basis, the Board cleared the transaction.
Acquisition of Prothya Biosolutions Belgium B.V. by Accord Plasma B.V.[8]
The Board authorised the acquisition of sole control over Prothya Biosolutions Belgium B.V. (“Prothya”) by Accord Plasma B.V. (“Accord”), which is wholly owned by Intas Pharmaceuticals Limited. The transaction involves the transfer of 100% of Prothya’s share capital and voting rights from Stichting Administratiekantoor Prothya Holding to Accord. The Board assessed the transaction and concluded that it constitutes a notifiable concentration resulting in a permanent change of control.
In its assessment, the Board examined the parties’ activities in the pharmaceutical sector, particularly with regard to plasma-derived medicinal products. It found no horizontal or vertical overlaps between the parties’ activities in Türkiye, as Intas does not currently engage in plasma-derived product activities on the Turkish market, while Prothya operates through an independent distributor. Although a potential overlap could theoretically arise in the future, due to Intas’s licensing arrangements, that remains uncertain and subject to regulatory approvals. Considering the competitive structure of the relevant markets and the presence of strong competitors, the Board concluded that the transaction would not lead to a significant restriction of effective competition and therefore granted clearance.
GLOBAL ANTI-TRUST LAW UPDATES
European Commission Unconditionally Approves Omnicom’s Acquisition of IPG
The European Commission approved unconditionally, under the EU Merger Regulation, the acquisition of Interpublic Group of Companies, Inc. (“IPG”) by Omnicom Group Inc. (“Omnicom”), concluding that the transaction would not raise competition concerns in the European Economic Area (“EEA”).
Both Omnicom and IPG are active in advertising, marketing and communication services, including marketing communication services (“MCS”) and media buying services (“MBS”), across multiple EEA countries and globally. The Commission assessed the effects of the transaction on national markets for MCS and MBS.
The Commission found that the merged entity would hold only moderate market positions and would continue to face effective competition from several large international advertising groups, such as WPP, Dentsu-Aegis, Publicis and Havas. Customers would retain the ability to switch agencies due to the bidding-based nature of the market, short contract durations and relatively low switching costs.
In addition, the Commission concluded that media owners would maintain sufficient countervailing bargaining power, even if the merged entity attempted to leverage its position in media buying services, due to the high level of concentration among media owners in the relevant markets.
On this basis, the Commission determined that the transaction was unlikely to significantly impede effective competition in any of the markets examined and cleared the merger without conditions.
European Commission Conditionally Approves ADNOC’s Acquisition of Covestro under the Foreign Subsidies Regulation
The European Commission conditionally approved the acquisition of Covestro AG (“Covestro”) by Abu Dhabi National Oil Company PJSC (“ADNOC”) under the EU Foreign Subsidies Regulation (“FSR”), subject to full compliance with binding commitments.
Following an in-depth investigation, the Commission found that ADNOC and Covestro had received foreign subsidies from the UAE, including an unlimited state guarantee to ADNOC, a committed capital increase into Covestro and certain favourable tax measures. These subsidies were considered capable of distorting competition both in the acquisition process and in the EU internal market after the transaction.
To address these concerns, ADNOC undertook to remove the unlimited State guarantee by amending its articles of association and to grant access to Covestro’s sustainability-related patents to certain market participants on transparent and pre-defined terms. The Commission concluded that these commitments would effectively remedy the identified distortions
European Commission Approves Unconditionally Mars Acquisition of Kellanova
The European Commission approved unconditionally, under the EU Merger Regulation, the acquisition of Kellanova by Mars, Incorporated (“Mars”), concluding that the transaction would not raise competition concerns in the European Economic Area (“EEA”).
Both Mars and Kellanova are global suppliers of branded food products. Mars is active in several food categories, including chocolate, sugar confectionery, chewing gum, snack bars, rice and pet food, while Kellanova is primarily active in savoury snacks and ready-to-eat cereals in the EEA, notably through brands such as Pringles and Kellogg’s. The Commission assessed the effects of the transaction on multiple food product markets across several Member States.
The Commission examined in particular whether the addition of Kellanova’s brands to Mars’ existing product portfolio would significantly increase Mars’ bargaining power towards retailers, potentially allowing it to leverage its broader portfolio in negotiations and extract higher prices. While the investigation confirmed that both parties already enjoy a degree of market power in certain product markets, the Commission found no evidence that the transaction would materially strengthen Mars’ bargaining position.
In particular, the Commission found that the characteristics of the parties’ products, including their long shelf life and the impulsive and infrequent nature of consumer purchases, would limit any portfolio or “basket effect”. Consumers were also found to be unlikely to switch retailers in response to the absence of both Mars’ and Kellanova’s products, thereby constraining any potential increase in retailer dependency.
On this basis, the Commission concluded that the transaction was unlikely to significantly impede effective competition in any of the markets examined and cleared the merger without conditions.
European Commission Conditionally Approves Vandemoortele’s Acquisition of Délifrance
The European Commission approved conditionally, under the EU Merger Regulation, the acquisition of Délifrance by Vandemoortele Group (“Vandemoortele”), subject to full compliance with binding commitments.
Following an in-depth investigation, the Commission found that both Vandemoortele and Délifrance are active in the production and supply of frozen bakery products, and that the transaction, as initially notified, would have significantly reduced competition in the markets for frozen laminated dough products supplied to retail and foodservice customers, particularly in France and to retail customers in Italy. The Commission identified that the merged entity would have held significant market shares in already highly concentrated markets and would have faced limited competitive constraints from alternative suppliers.
To address these competition concerns, Vandemoortele committed to divest two Délifrance production sites dedicated to frozen laminated dough products, including all necessary tangible and intangible assets, personnel and customer contracts. The Commission concluded that these structural commitments would enable a suitable buyer to exert effective competitive pressure on the merged entity and would preserve competition in the affected markets.
On this basis, the Commission determined that the commitments would effectively remedy the identified competition concerns and approved the transaction subject to the full implementation of the remedies.