New Development
The Turkish Competition Authority (“TCA”) published its 2025 Annual Report (“Report”) on its official website on 4 March 2026. The Report provides an overview of the TCA’s activities in 2025. The key highlights are summarized below.
The full text of the Report is available here (in Turkish).
Overview
The Report notes that the current period is marked by accelerated economic, technological, and structural transformations on a global scale. In this context, it emphasizes that digitalization, the data economy, artificial intelligence applications, and platform‑based business models have fundamentally reshaped market structures, thereby necessitating the continuous development of competition law to adapt to these new dynamics.
The Report indicates that the TCA had a notably busy agenda in 2025. According to the Report, the TCA issued a total of 530 final decisions throughout the year, including 416 merger and acquisition decisions, 104 competition law violation decisions, and 10 individual exemption/negative clearance decisions. The number of on‑site inspection assignments also surged by approximately 50% compared to 2024. As a result of the investigations completed and decisions adopted in 2025, the amount of administrative monetary fines imposed totalled approximately TRY 12.1 billion.
The Report highlights that the TCA continued to apply the settlement and commitment mechanisms effectively in 2025 and addressed competitive concerns through obligations imposed on undertakings, thereby contributing to the creation of healthier market structures.
Regulatory Efforts
In 2025, the TCA amended the Communiqué on Block Exemption for Specialization Agreements and the Communiqué on the Regulation of the Right to Access the File and the Protection of Trade Secrets (for further details, you may refer to our legal bulletin here). The Report notes that secondary legislation efforts continue for the following: Guidelines on General Principles of Exemption, the Communiqué on Acquisitions through Privatization, the Block Exemption Communiqué on Vertical Agreements, Guidelines on Vertical Agreements, Guidelines on Horizontal Cooperation Agreements, the On‑Site Inspection Regulation, On‑Site Inspection Guidelines, the Regulation on Active Cooperation for Detecting Cartels, Guidelines on Exclusionary Conduct by Dominant Undertakings, and Sustainability Guidelines.
Statistics in the Report
Compared to 2024, the number of the TCA’s decisions increased by approximately 9%. While 487 files were concluded in 2024, the TCA rendered final decisions in 530 files in 2025. 78% of the files concluded in 2025 concerned merger and acquisition transactions, 20% concerned competition violations, and 2% concerned individual exemption/negative clearance assessments.
- Competition Law Violations: Comparing 166 cases concluded by the TCA under Articles 4 and 6 in 2024 with 104 cases concluded in 2025, the number of finalized cases appears to have sharply fallen. Of the 104 decisions adopted in 2025, 89 were rendered following the full-fledged investigations, while the remaining 15 decisions were adopted at the end of the preliminary investigations. Key details are as follows:
- Of the 104 cases, 82 concerned anticompetitive agreements under Article 4, while 8 cases were of a mixed nature, involving both anticompetitive agreement concerns under Article 4 and abuse of dominance concerns under Article 6. Of these, 56 were related to agreements between competitors (horizontal agreements), and 33 concerned agreements between undertakings operating at different levels of the supply chain (vertical agreements). One case examined under Article 4 involved agreements of both a horizontal and a vertical nature.
- 14 decisions concerned abuses of dominance under Article 6.
- The sectors most frequently subject to competition‑infringement reviews were listed as: (i) agriculture and agricultural products, (ii) machinery, (iii) labour markets, (iv) food industry, and (v) construction.
- Of the 89 investigation files, administrative monetary fines were imposed in 23 cases as a result of ordinary investigation procedures, 12 cases were closed through commitments offered during the preliminary investigation or investigation processes, and 47 cases were closed through settlement. The Report notes that no violation was identified in 7 investigations under the ordinary investigation procedure.
- Mergers and Acquisitions: In 2025, the TCA reviewed 416 transactions, indicating an increase of approximately 34% compared to 311 transactions in 2024. Key details in 2025 are as follows:
- The TCA reviewed a total of 416 transactions: 286 acquisitions, 107 joint ventures, 19 privatizations, and 4 mergers.
- In the 391 notifiable transactions, the TCA granted unconditional clearance in 381 cases and conditional clearance in 10 cases. It concluded that 25 notified transactions were either out of scope or not subject to notification.
- The TCA initiated a Phase II review in two cases in 2025. One of these was cleared, while the other remains under review.
- The top three sectors among merger and acquisition decisions were (i) information technologies and platform services, (ii) automotive and vehicles, and (iii) chemicals and mining.
- For further details regarding the status of merger and acquisitions in Türkiye, you may refer to our legal bulletin on the 2025 Merger and Acquisition Outlook Report here.
- Exemption and Negative Clearance Decisions: The TCA handed down 8 individual exemption and 2 negative clearance decisions in 2025.
- These decisions concerned (i) banking, capital markets, financial and insurance services; (ii) the machinery industry; (iii) automotive and vehicles; (iv) construction; and (v) logistics, warehousing, and postal services sectors.
- The TCA, out of 8 individual exemption files, granted individual exemption in 5 cases and conditional individual exemption in 2 cases, and rejected 1 individual exemption application.
- Administrative Monetary Fines: 2025 witnessed significant administrative monetary fines. Key details are as follows:
- The TCA imposed approximately TRY 7.5 billion in administrative monetary fines in 2024, whereas this amount rose to approximately TRY 12.1 billion in 2025.
- In 2025, the food sector was subject to the highest total administrative monetary fine for competition law violations, amounting to approximately TRY 4.7 billion, followed by the chemicals and mining sector with fines totaling approximately TRY 670 million, and the infrastructure services sector with approximately TRY 659 million.
- Total administrative monetary fines imposed for anticompetitive agreements and concerted practices (Article 4 violations) amounted to approximately TRY 7.3 billion in 2025, while total fines imposed for abuse of dominance (Article 6 violations) accounted for approximately TRY 460 million.
- No administrative monetary fines were imposed in 2025 for providing incorrect or misleading information in response to information requests and/or during on‑site inspections.
- Approximately TRY 478 million in administrative monetary fines were imposed in 2025 for obstructing or hindering on‑site inspections.
- Approximately TRY 12 million in administrative monetary fines were imposed in 2025 for failure to notify a merger or acquisition within the statutory period.
Conclusion
Based on the data presented in the Report, it may be concluded that 2025 was an intensive year for the TCA. Indeed, the amendments to the Communiqué on Mergers and Acquisitions Requiring the Approval of the Competition Board adopted in 2026 significantly increased the turnover thresholds and the exception concerning the acquisition of technology undertakings was narrowed down. The relevant amendment is expected to reduce, to some extent, the number of mergers and acquisitions subject to the TCA’s approval, allowing the TCA to place a greater focus on investigations conducted under Articles 4 and 6 of Law No. 4054. Another conclusion that may be drawn from the Report is that the TCA’s trend of scrutinizing labour markets has continued, as the labour market is listed among the sectors most frequently subject to competition law violation reviews in 2025.
