Associé
Analyses & décryptages
Türkiye Newsletter No.23 | 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") and as well as decisions issued by the Competition Board (the "Board") in September 2025.
ANNOUNCEMENTS
Recently Initiated Investigations
- Agriculture and Organic Food: The Board has launched an investigation into certain undertakings engaged in the production and sale of milk and dairy products. It is trying to determine whether there has been a violation of Article 4 of the Law by pressuring livestock farms that sell raw milk through a feed-for-milk scheme.
- Media & Technology: The Board has initiated an investigation against Spotify Dijital Yayıncılık Hizmetleri A.Ş., Spotify Yönetim Destek Hizmetleri A.Ş. and Spotify AB to determine whether there has been a violation of Law No 4054 through practices that hinder the activities of competitors in the online music streaming market, affect the distribution of royalties paid to various counterparties under licensing relationships, and/or discriminate against artists and content creators on the platform, particularly in terms of visibility.
- Meal Ticket & Electronic Payment: The Board has initiated an investigation against Edenred Kurumsal Çözümler A.Ş., Multinet Kurumsal Hizmetler A.Ş., Pluxee Çalışan Deneyimi Danışmanlık ve Pazarlama Hizmetleri A.Ş. and Set Kurumsal Hizmetler Ticaret A.Ş., to determine whether there has been a violation of Article 4 Law No 4054 through practices in market conduct, customer sharing and/or the exchange of competitively sensitive information
Other Industries
- The Board has initiated an investigation against certain undertakings, an association of undertakings and a consulting firm operating in the construction industry. It is aimed at determining whether there has been a violation of Article 4 of Law No 4054 through exchanging sensitive information, colluding on employee wages and conducting no-poaching agreements.
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. | Beypi Beypazarı Tarımsal Üretim Paz. San. ve Tic. A.Ş. | Exchanging Competitively Sensitive Information
|
244,655,573.31 |
| 2. | Ege-Tav Ege Tarım Hayvancılık Yatırım Tic. ve San. A.Ş. | 41,164,149.12 | |
| 3. | Keskinoğlu Tavukçuluk ve Damızlık İşl. San. Tic. A.Ş. | 107,981,782.50 | |
| 4. | Abalıoğlu Lezita Gıda Sanayi A.Ş. | 277,866,357.92 | |
| 5. | Şenpiliç Gıda Sanayi A.Ş. | 357,687,454.48 | |
| 6. | Akpiliç Tic. Ltd. Şti. | 28,968,741.06 | |
| 7. | As Ofis Damızlık Yumurta Yem Gıda San. ve Tic. A.Ş. | 118,167,698.22 | |
| 8. | Bakpiliç Entegre Tavukçuluk A.Ş. | 104,712,821.98 | |
| 9. | Banvit Bandırma Vitaminli Yem Sanayi A.Ş. | 947,305,871.90 | |
| 10. | Bupiliç Entegre Gıda San. Tic. A.Ş. | 129,817,126.85 | |
| 11. | Erpiliç Entegre Tavukçuluk Üretim Pazarlama ve Tic. A.Ş. | 817,157,021.41 | |
| 12. | Gedik Tavukçuluk ve Tarım Ürünleri Tic. San. A.Ş. | 419,548,478.85 | |
| 13. | Hastavuk Gıda Tarım Hayvancılık Sanayi ve Ticaret A.Ş. | 108,983,792.58 |
SUMMARY OF KEY DECISIONS
Novonesis A/S and its Affiliates Decision[1]
The Board initiated an investigation against Novonesis A/S (formerly Novozymes A/S) and its affiliates — including Novozymes Enzim Dış Ticaret Ltd. Şti., Novozymes Berlin GmbH, Novozymes France S.A.S., Novozymes Switzerland AG, and Novozymes North America — based on allegations of violating Article 6 of the Law by abusing their dominant position in the industrial enzyme market.
During the course of the investigation, it was found that the undertakings in question failed to fully comply with information and document requests issued under Article 14 of the Law. In particular, Novonesis A/S and its affiliates submitted incomplete, inaccurate and misleading information regarding their contractual relations and commercial activities, and failed to provide certain requested documents within the prescribed time limits. These findings were evaluated as acts that hindered the proper execution of the investigation and violated the undertakings’ duty to cooperate with the Authority.
Based on its assessment, the Board concluded that Novonesis A/S and its affiliates had breached their obligations under the Law by providing incomplete and misleading information, as well as by failing to submit information within the specified deadlines. Accordingly, the Board decided to impose an administrative fine on Novonesis A/S and its affiliates pursuant to Article 16(1)(c) of the Law — for submitting inaccurate or misleading information, and Article 17(1)(c) of the Law — for failing to provide the requested information within the specified period.
Acquisition of TYG Turkey Elektronik Ticaret Hizmetleri ve Yatırımları A.Ş. by Uber International Holding BV [2]
The Board authorised the acquisition of sole control over TYG Turkey Elektronik Ticaret Hizmetleri ve Yatırımları A.Ş. (“Trendyol Go”) by Uber International Holding BV (“Uber”). The Board decided to authorise the transaction as there was no horizontal or vertical overlap between the parties’ activities in Turkey. Trendyol Go primarily operates in the online food and market delivery services market, while Uber’s activities in Turkey are limited to mobility services through the Uber Rides platform, with no operations in the delivery of food or market products. As such, the transaction was not expected to result in a significant restriction of effective competition on the relevant markets.
In its assessment, the Board also considered the potential effects on competition arising from the parties’ digital ecosystems. Despite Uber acquiring sole control of Trendyol Go, the existing market structure includes several strong and well-established competitors in online delivery services, ensuring that effective competitive pressure remains. Furthermore, structural and behavioural safeguards, including separate management and operational independence of Trendyol Go, as well as restrictions on data sharing and cross-promotion, reduce the risk of the transaction leading to anti-competitive effects.
Kognivia Yazılım A.Ş. decision[3]
The Board authorised the proposed change in control over Midas Technology Corporation and its affiliates by Egem Eraslan, Portage Ventures III Investments LP and Spark Capital VII, LP under the scope of a negative clearance review. The Board concluded that the transaction does not constitute a transfer of control under the relevant legislation and, under the current circumstances, is not expected to restrict effective competition on the brokerage services market in Turkey. Midas’ activities are limited to the Turkish market, while the other parties’ operations are primarily global and do not overlap with Midas in Turkey.
In its assessment, the Board also considered the post-transaction governance structure. The management of Midas will continue to require the consent of multiple shareholders for key decisions, including the appointment of the Joint Director, ensuring that no single party can unilaterally control the company. This structure, combined with Midas’ operational independence, mitigates the risk of anti-competitive effects arising from the transaction.
Eureko Sigorta A.Ş. and Garanti Emeklilik ve Hayat A.Ş. decision [4]
The Board authorised the proposed collaboration among Eureko Sigorta A.Ş., Bupa Acıbadem Sigorta A.Ş., and Garanti Emeklilik ve Hayat A.Ş. regarding framework agreements and associated Kotpar Reinsurance and Closed Co-insurance Contracts under the scope of an individual exemption review. The Board concluded that the contracts, in their current form, are considered to have restrictive effects on competition under Article 4 of the Law. Therefore, they cannot be granted a negative clearance under Article 8 of the Law. However, subject to the modification of the non-compete and active sales restrictions in certain clauses of the framework agreement between Garanti Emeklilik ve Hayat A.Ş. and Bupa Acıbadem Sigorta A.Ş. to be limited in duration, the contracts meet the conditions for an individual exemption under Article 5 of the Law.
In its assessment, the Board also considered the structure of the agreements and the operational safeguards. By limiting the non-compete and active sales obligations to the duration of the agreement, the risk of anti-competitive effects is mitigated, ensuring that the parties’ independent operations continue to maintain competitive pressure on the relevant health insurance markets. Consequently, the Board granted an individual exemption to all the contracts and associated agreements.
GLOBAL ANTI-TRUST LAW UPDATES
The European Commission Imposes a €2.95 Billion Fine on Google for Anti-Competitive Conduct in the AdTech Sector[5]
The European Commission has imposed a fine of €2.95 billion on Google for breaching EU antitrust rules in the advertising technology (“AdTech”) sector. The Commission found that Google had abused its dominant positions on the markets for publisher ad servers and programmatic ad buying tools by favouring its own ad exchange, AdX, over competing providers. This conduct distorted competition, to the detriment of advertisers and online publishers.
The Commission ordered Google to end these self-preferencing practices and to implement measures to address inherent conflicts of interest along the adtech supply chain. Google now has 60 days in which to inform the Commission about the measures it intends to take. The Commission will assess whether these measures effectively eliminate the conflicts, and, if not, may impose additional remedies.
The fine was determined based on the duration and gravity of the infringement, the relevant EEA turnover of AdX and Google’s previous record of abusing its dominance. The Commission’s decision follows its investigation, which began in June 2021, and a Statement of Objections sent to Google in June 2023, to which Google responded in December 2023.
The Commission’s findings under Article 102 of the Treaty on the Functioning of the European Union also provide a key reference point for related proceedings in the United States, where a trial on remedies was scheduled to start on 22 September 2025.