1.What is the current legal landscape for merger control in your jurisdiction?

The Turkish Competition Authority is an active enforcer across every limb of competition law, and merger control is no exception. Turkish merger control is built on Article 7 of the Law on the Protection of Competition No. 4054 (“Competition Act”), implemented through Communiqué No 2010/4 on Mergers and Acquisitions Requiring the Approval of the Competition Board, as amended by Communiqué No 2017/2, Communiqué No 2022/2 and, most recently, Communiqué No 2026/2. The regime is mandatory and suspensory. A notifiable transaction closed without the Competition Board’s approval is legally invalid with all of its consequences, and an administrative fine follows automatically. There is no filing fee, no statutory filing deadline and no formal pre-notification mechanism: The filing is a one-shot submission, and the characteristics of that submission determine the timetable.

The market in numbers

The Authority’s 2025 Merger and Acquisition Outlook Report, published on 7 January 2026, gives an unusually clear picture of the workload. The Competition Board reviewed 416 mergers, acquisitions and privatisations in 2025, against 311 in the preceding year, an increase of roughly a third. Excluding privatisations, 162 of those transactions involved a Türkiye-based target, with an aggregate notified value of approximately TRY 466.11 billion (USD 11.81 billion and EUR 10.42 billion[1]), which is the highest figure recorded in either currency since the reports began in 2013. Adding the 19 privatisations reviewed, at TRY 108.05 billion (USD 2.74 billion and EUR 2.41 billion), the total value attributable to Türkiye-based undertakings reached approximately TRY 574.16 billion (USD 14.54 billion and EUR 12.8 billion). A further 226 transactions concerned targets established abroad, with an aggregate notified value of TRY 18.88 trillion (USD 478.31 billion and EUR 422.27 billion), and nine transactions were found to fall outside the regime for want of a change of control. Among Türkiye-based targets, computer programming, consultancy and related activities led by transaction count with 25 deals, while the activities of monetary intermediaries produced the highest aggregate value.

Reviews increasingly resolved through commitments

What the statistics do not convey is the depth of the substantive analysis. The Board examines foreclosure of supply sources, the prospect of price increases, the narrowing of customer choice and the dynamic effects of a transaction on innovation and entry, and a growing proportion of complex cases is now resolved through commitments.

A clear pattern emerges from the Board’s recent decisional practice: the primary purpose of commitments is to preserve the competitive structure that existed before the transaction. Structural changes, particularly divestitures, are preferred because they produce sustainable results without requiring ongoing monitoring; yet in practice the Board has demonstrated a sophisticated readiness to accept purely behavioural remedies where structural solutions are neither feasible nor proportionate.

Where a transaction creates or strengthens dominance through direct horizontal overlap, the Board has consistently required structural divestiture. The Petrol Ofisi / BP decision[2] exemplifies this approach: PO committed to divesting at least 65 stations from a list of 220 identified as creating concentration issues, plus 50 further stations in catchment areas with local-level concerns, with a minimum volume threshold of 94,500 tonnes to ensure meaningful competitive impact. Divested stations would not be party to a dealership agreement with PO for five years.

The same structural logic applies in EssilorLuxottica[3], where Essilor was required to divest its entire stake in Merve Optik, and in A101 / CarrefourSA[4], where 48 stores were divested in markets with identified competition concerns.

Two features are consistent across structural remedy cases. First, divestitures are calibrated by reference to explicit market share or HHI thresholds. Second, structural remedies are almost invariably accompanied by behavioural commitments targeting residual concerns — in Petrol Ofisi / BP, a three-year cap on ATAŞ storage capacity (50% of total licensed capacity) and a gas oil distribution volume freeze; in A101 / CarrefourSA, requirements for organisational separation and employment maintenance.

Turning to behavioural remedies, the most recurring commitment is the non-discrimination or FRAND-access obligation, designed to prevent leveraging of a bottleneck position. In DP World / Evyap Port[5], terminals were required to be managed on a common-user basis, open to all stakeholders without discrimination. In CEVA / Borusan[6], CEVA committed to providing distribution network services to competitors on FRAND terms for two years. In Kariyer.net / Brotek[7], KARİYERNET committed to maintaining integration processes for third-party HR software providers without discrimination. In CoreX / Polisan[8], the Common-User obligation was particularly detailed, requiring transparent, objective, and non-discriminatory port services with no priority to group companies in capacity allocation or vessel berthing.

A distinct and increasingly prominent category of behavioural commitment addresses data security and information barriers. The Param / Kartek[9] decision provides the most detailed illustration. All accepted commitments were behavioural, given that no structural remedy was capable of addressing the vertical input-foreclosure and data-transfer concerns.  The technical architecture was unprecedented: no Acquirer Group employee would access Target Group systems; access would require two-factor authentication with immutable SIEM audit trails; separate database servers housed in different cabinets;  and a DLP application blocking bulk transmission of customer card to Acquirer Group employees. In CoreX / Polisan, a parallel information barrier prohibited any direct or indirect information exchange between the two competing companies, which will be under the same control structure via the transaction.

Pricing and contract continuity obligations constitute a further consistent strand of behavioural remedy. In DP World / Evyap Port, a 36-month price cap tied to US CPI was imposed.  In CEVA / Borusan, existing contracts were required to remain in force for one year without modification, with price increases frozen at existing contractual limits.  In Cargill / PNS[10], price increases were limited to specific cost components for five years with independent monitoring and a Board right of reversal.  In Honeywell / Civitanavi[11], continuation of supply and adherence to existing pricing methodologies was committed. Price commitments have become notably sophisticated, converging on foreign-index linkage — US CPI in Evyap, a USA-PPI / TR-ÜFE / FX formula in Polisan, cost-item caps in Cargill.

The Board has also required formal governance and management separation to prevent information leakage and joint decision-making. In Param / Kartek, simultaneous board membership across the Acquirer and Target Groups was prohibited.  In CoreX / Polisan, where the transaction brought two direct horizontal competitors under common control pending divestiture of one, the separation was far more comprehensive: the ultimate controlling shareholder would assume no decision-making role in the entity to be divested;  he would not attend its general assembly meetings; and the board members and senior management of one entity would be entirely different persons from those of the other.

A hallmark of the Board’s current practice is the requirement for third-party-audited compliance monitoring. Practice has evolved from a divestiture trustee reporting monthly (EssilorLuxottica, 2018), through bare self-reporting (Evyap, Honeywell), to a settled model of a KGK-listed (Public Oversight, Accounting and Auditing Standards Authority) independent auditor approved by the Board, six-monthly reporting, internal compliance officers, and customer notification (CEVA, Polisan). Commitment durations have anchored on three years.

The Board has demonstrated that this monitoring architecture is not merely procedural. In EssilorLuxottica decision[12], a total administrative fine of TRY 492,191,132 (approximately USD 12.5 million and EUR 11 million) was imposed for breaching the behavioural commitments attached to its 2018 conditional clearance, which was calculated at 0.05% of annual gross turnover per day of non-compliance under Article 17(1)(a) of Law No. 4054. The Board treats the commitment period as a live supervisory relationship, not a one-time filing exercise.

The most novel and up-to-date development is the emergence of investment commitments as a distinct remedy category. In Tofaş / Stellantis TR[13], the parties’ initial commitment package was rejected; a substantially expanded second package secured clearance, comprising an investment plan centred on a light commercial vehicle project with 150,000-unit annual capacity, intended to reduce imports and support domestic production, together with distribution measures. The Board accepted the investment commitment as capable of eliminating the restrictive effects of the transaction, expressly framing its assessment as an application of a welfare standard broader than static price and output analysis, taking account of the dynamic effects of competition.

That approach was repeated in June 2026, when the Board cleared Uber Technologies Inc.’s acquisition of Getir’s online food ordering and delivery and online FMCG ordering and delivery businesses[14], on the basis of a commitment package including an undertaking to invest USD 500 million in Türkiye, expected to support high-skilled employment, strengthen local engineering capability, and contribute to digital infrastructure. The same acquirer had entered the Turkish market a year earlier through its unconditionally cleared acquisition of Trendyol GO, underscoring the rapidity with which investment-based conditionality has become a standard feature of the Board’s toolkit.

Beyond commitments directed at conventional competition concerns such as pricing, access, and market structure, the Board has recently accepted obligations pursuing broader public-interest objectives. In CoreX / Polisan, Poliport’s current employment structure may not be altered, and the number of blue-collar workers performing hazardous liquid chemical and petroleum port services may not be reduced, with all acquired employee rights, including wages, fringe benefits, and seniority entitlements, fully preserved.  In A101 / CarrefourSA, at least 75 SMEs or local producers and suppliers are to be supported annually under a dedicated SME and Local Supplier Support Programme including store visibility, marketing, digital and social media, and online sales channel priority.  Taken together, these commitments signal that the Board now conceives of conditional merger clearance not solely as a mechanism to preserve pre-merger market structure, but increasingly as a lever to extract tangible, forward-looking economic contributions, in manufacturing capacity, R&D employment, supply-chain deepening, workforce protection, and SME development, from transactions that carry sufficient strategic weight to warrant such conditions. Investment commitments are, on this evidence, becoming an established and increasingly sought-after category of remedy in Türkiye, accepted by the Board as capable of eliminating the restrictive effects of a concentration, and parties to transactions raising competitive concerns should expect the question to be raised.

Thresholds, technology undertakings and the February 2026 reform

The same focus has shaped the jurisdictional rules. The problem of below-threshold acquisitions in digital markets (the killer acquisition debate that has occupied authorities worldwide) was addressed in Türkiye in 2022 through a distinctively local solution. Rather than adopting a transaction value threshold on the German and Austrian model, the Authority introduced the concept of the technology undertaking into Communiqué No 2010/4, capturing undertakings active in digital platforms, software and gaming software, financial technologies, biotechnology, pharmacology, agricultural chemicals and health technologies. The device reflected a deliberate policy of not allowing potentially anti-competitive acquisitions of nascent competitors to escape review.

Communiqué No 2026/2, published in the Official Gazette and in force on 11 February 2026, has relaxed that framework without abandoning it. The revision reflects the Authority’s assessment that a significant proportion of the filings reaching it concerned transactions with no competitive effect, or with a low likelihood of affecting the Turkish market at all. The principal changes are as follows.

• Thresholds: The aggregate Turkish turnover threshold rose from TRY 750m (approx. USD 19 million and EUR 16.8 million) to TRY 3 billion (approx. USD 76 million and EUR 67 million); the individual Turkish turnover threshold from TRY 250m (approx. USD 6.3 million and EUR 5.6 million) to TRY 1 billion (approx. USD 25.3 million and EUR 22.4 million); and the worldwide turnover threshold from TRY 3 billion to TRY 9 billion (approx. USD 228 million and EUR 201.3 million). A transaction is notifiable where the aggregate Turkish turnover of the parties exceeds TRY 3 billion and the Turkish turnover of at least two parties each exceeds TRY 1 billion; or where the Turkish turnover of the transferred assets or business in an acquisition (or of any party in a merger) exceeds TRY 1 billion and the worldwide turnover of at least one other party exceeds TRY 9 billion.
• Technology undertakings: The definition is unchanged and the concept survives as a distinctly Turkish feature of the regime. What has changed is the local nexus, which is now a qualifying condition: The reduced TRY 250m threshold applies only where the target technology undertaking is established in Türkiye. The Authority’s proactive stance towards acquisitions in technology and innovation-driven markets therefore remains intact, applied to targets with a genuine Turkish presence.
• Definitions and the notification form: The definitions of undertaking concerned, transaction party and technology undertaking have been set out more clearly, and the criteria for identifying the target-side party clarified. Information requirements have been reduced where, in any affected market in Türkiye, the parties’ combined market share is below 15% in horizontal relationships or the market share of a party is below 20% in vertical relationships. Filings involving venture capital investment trusts, venture capital investment funds, private equity investment vehicles and angel investors (other than the target) benefit from a streamlined information set: For those parties, it is sufficient to provide the Türkiye-related information under the activity sections of the form, and, where the worldwide turnover threshold is declared to be exceeded, only the Türkiye-related turnover information. Points of long-standing confusion in the form itself have been resolved through additional explanatory notes.
• Technical clarifications and transition: The Communiqué clarifies turnover calculation in asset transfers and establishes a clearer framework for assessing the risk of coordination between the parent undertakings of a joint venture, which the Board may examine separately under Articles 4 and 5 of the Competition Act. The transitional clause requires the Board to terminate, by decision, ongoing reviews of transactions that no longer meet the revised thresholds or conditions.

The substantive test and the guidelines

Substantively, the regime has operated on the Significant Impediment to Effective Competition (SIEC) test since the amendment of the Competition Act in June 2020; six years of application, with the secondary legislation aligned accordingly. The guidelines are, in practice, the most useful source of guidance for parties, and they are revised as experience accumulates. The 2022 package, which accompanied the threshold revision and the introduction of the technology undertaking concept, added to the Guidelines on the Assessment of Horizontal Mergers and Acquisitions material on potential competition, closeness of competition analysis, theories of harm specific to digital and innovation-driven markets, the killer acquisition theory of harm and the competitive significance of consumer data, with parallel additions to the Guidelines on the Assessment of Non-Horizontal Mergers and Acquisitions. Following the February 2026 amendment, the Authority updated four core guidelines in May 2026, addressing the calculation of turnover for technology undertakings on an activity basis, the economic unity approach to identifying transaction parties and undertakings concerned, the scope of the undertakings concerned in cases of joint control, the starting point of the three-year period for aggregating successive transactions, and the assessment of coordination effects in joint ventures. The pattern is one of continuous calibration: The Authority takes its experience of thresholds, assessment criteria and applicants’ filing practice and feeds it back into the rules.

Review periods and enforcement

When it comes to the timetable, Phase I is 30 calendar days from a complete filing, with tacit approval under Article 10(2) of the Competition Act if the Board does not respond. Phase II remains genuinely exceptional: Only two transactions were taken into a final investigation during 2025, one of which was cleared on the basis of commitments while the other remained pending at the time of the Authority’s 2025 Merger and Acquisition Outlook Report. It is worth emphasising that a considerable number of files raising competitive concerns, including cases resolved through commitments or measures, are concluded within Phase I rather than escalated to Phase II.

Enforcement of the suspension requirement is correspondingly firm. The Competition Act establishes a layered penalty architecture specific to merger control. Under Article 16(1)(b), implementation of a notifiable transaction without the Board’s prior approval attracts an administrative fine of 0.1% of the undertaking’s annual gross revenue generated in the financial year preceding the decision (or, where that figure cannot be calculated, the nearest available financial year), imposed on each party in a merger and on the acquirer alone in an acquisition; the Board has no discretion to waive the fine once the violation is established. In Elon R Musk/Twitter[15] the Board opened an own-initiative review on the basis of press reports, cleared the transaction on the merits and nonetheless fined the acquirer 0.1% of his 2022 Turkish gross revenue; the parties’ argument that the Turkish turnover thresholds had been assessed before the technology undertaking regime entered into force did not save them. In Param/Kartek[16] the Board found that the acquirer had assumed de facto control before clearance, appointing managers, taking the final decisions on salaries and promotions and involving itself in marketing and day-to-day management. Three separate decisions concerning MTG’s acquisitions[17] in the video game sector in September 2025 confirm that the Board’s attention to gun jumping has, if anything, intensified. The corollary for deal teams is that pre-clearance conduct, and in particular the exchange of competitively sensitive information during diligence and integration planning, requires close attention in its own right.

Article 16(1)(a) imposes the same 0.1% fine where incorrect or misleading information or documents are submitted in a merger or acquisition notification. In Akzo Nobel / Rohm and Haas[18], the TCA found that Akzo Nobel had submitted false and misleading information in its merger clearance application, specifically by failing to disclose the liquid metal coatings revenues generated by its Turkish subsidiary Akzo Nobel Kemipol A.Ş., despite being asked to do so on multiple occasions. Similarly, in Lotte Chemical Corporation[19], the Board established that Lotte Chemical had falsely stated in responses to information requests issued in two separate merger pre-examination proceedings that its Istanbul liaison office conducted no sales activity in Türkiye.

Finally, Article 17(1)(a) addresses post-clearance non-compliance: Where an undertaking fails to observe the obligations imposed by a final decision or breaches commitments accepted by the Board, a periodic penalty of 0.05% of annual gross revenue accrues for each day of non-compliance, running from the expiry of the time limit set in the relevant decision or, where no time limit is specified, from the day following notification of that decision. The EssilorLuxottica decision illustrates the practical consequence of this provision: an administrative fine calculated on a daily basis was imposed for breaching the behavioural commitments attached to the undertaking’s 2018 conditional clearance.

2. What three essential pieces of advice would you give to clients involved in merger control matters?

i. Notify: the consequences of not doing so are not negotiable

This remains the single most important point, and the case law shows why. Turkish law treats an unnotified notifiable transaction as invalid until cleared, and the fine under Article 16 is imposed automatically once the violation is established: The Board has no discretion to waive it, and a clean substantive outcome provides no protection, as Elon R Musk/Twitter demonstrates. Nor does the absence of a Turkish nexus offer comfort. The regime contains no affected market requirement and no market share threshold; foreign-to-foreign transactions are caught on the effects doctrine under Article 2 of the Competition Act whenever the thresholds are met; and full-function joint ventures can be notifiable even where the joint venture will never sell into Türkiye. The Board monitors the press and the decisional practice of other authorities, opens own-initiative reviews, and examines the notifiability of past transactions when a new filing arrives, so the passage of time does not make an unnotified deal safe. Two rules deserve standing attention in the analysis: Transactions between the same parties, or concerning assets in the same relevant market, completed within three years may be aggregated and treated as a single concentration, with the period now expressly running from the date the first notification entered the Board’s records; and the reduced TRY 250m threshold for technology targets established in Türkiye continues to catch transactions that ordinary revenue tests would not.

ii. Assume a searching substantive review, and think about remedies early

The Board’s analysis in contested cases is thorough and commercially specific. It examines whether the transaction will foreclose or degrade access to supply sources, whether it creates the conditions for price increases, whether customer choice will narrow, and how the merged entity will behave in the distribution chain. Parties should satisfy themselves before filing that these outcomes will not arise, and, where they may, should design commitments capable of addressing them rather than waiting for the Board to identify the problem. The remedies toolkit is broader than it was. Structural remedies retain formal precedence under the Guidelines on Remedies Acceptable in Mergers and Acquisitions, behavioural remedies have been accepted with increasing frequency where they are effective and capable of monitoring, and the investment commitment has emerged in Tofaş/Stellantis and Uber/Getir as a distinct category directed at the dynamic and welfare effects of a transaction.

iii. Observe commitments in full: the penalty regime is active and the consequences are material

Commitments accepted by the Board are not aspirational undertakings; they are binding obligations whose breach carries automatic financial consequences. Under Article 17(1)(a) of the Competition Act, each day of non-compliance attracts a periodic penalty of 0.05% of annual gross revenue, running from the expiry of the time limit set in the relevant decision or, where none is specified, from the day following notification of that decision. The risk is not theoretical. The commitment period is accordingly a live supervisory relationship, not a one-time filing exercise, and parties should build internal compliance monitoring, reporting calendars and escalation protocols from the date of the conditional clearance decision rather than treating them as an afterthought.

Bonus: Prepare the form as if it were the whole case and keep it consistent, in this filing and the next

Incorrect or misleading statements in the notification form attract an administrative fine under Article 16 of the Competition Act, and where the Authority establishes that a clearance was obtained on the basis of inaccurate information, the decision itself may be reopened. Incomplete information carries a different but equally material cost: The notification is deemed filed only when the missing information is supplied, and every written request for information restarts the 30-day clock. Since there is no pre-notification mechanism and no fast-track procedure, the only lever the parties control is the quality of the initial submission. A form that explains the transaction, the relevant markets and the realistic effects on those markets fully and in one pass reduces the risk of inaccuracy, forecloses requests for information and shortens the timetable, and it should be prepared with that ambition even though the form has been simplified, because complex transactions still generate complex disclosure. Two further disciplines follow. Responses to subsequent requests for information must be consistent with the form; inconsistency is precisely what invites scrutiny. And because the Board can and does revisit information supplied in a company’s earlier filings when a later transaction comes before it, sometimes years apart, previous submissions should be retained and treated as part of the record against which new filings will be read.

3. What are the greatest threats and opportunities in merger control in the next 12 months?

Opportunities

• A significantly narrower jurisdictional net: The fourfold increase in thresholds takes a substantial volume of mid-market and foreign-to-foreign transactions out of mandatory notification altogether, removing conditions precedent, shortening timetables and reducing execution cost. Combined with the simplified form for low-overlap transactions and the streamlined information set for venture capital and private equity vehicles, the compliance burden of transacting in Türkiye has fallen appreciably for the first time in several years.
• Real predictability for technology transactions: Attaching an establishment requirement and a local turnover threshold to the technology undertaking regime resolves most of the uncertainty that surrounded early-stage and pre-revenue acquisitions between 2022 and 2026. Buyers of global software, gaming and financial technology businesses can now answer the filing question at triage rather than carrying it as a residual risk to signing.
• A market that rewards entry: Türkiye is a growing market, and the Authority’s decisional practice reflects a settled view that new entry intensifies competition. Investments in smaller or maverick players, and acquisitions that bring a new competitor into a concentrated Turkish market, are assessed against that background. For strategic buyers and sponsors, the entry rationale is worth articulating explicitly in the filing rather than leaving it to be inferred.
• Commitments as a route through, not a dead end: The willingness to accept behavioural packages and, now, investment undertakings means that transactions raising genuine concerns are not automatically facing prohibition.

Threats

• Scrutiny of efficiency-enhancing but concentrative transactions: The transactions that most reliably attract the Board’s attention are those that increase market share while promising efficiency gains. The Board does not accept efficiency claims at face value: The gains must be specific, verifiable and merger-specific, and the burden of demonstrating them sits with the parties.
• Nominal thresholds in an inflationary environment: The thresholds are expressed in Turkish lira and Türkiye has been dealing with severe inflationary pressures. The relief delivered in February 2026 will therefore erode, and the population of notifiable transactions will widen again over time without any change of policy.
• The aggregation rule as a hidden trap: Because transactions between the same parties, or in the same relevant product market, over a three-year period may be treated as a single concentration, a series of individually non-notifiable acquisitions can become notifiable in aggregate. Serial acquirers need a standing record of prior Turkish transactions rather than a deal-by-deal analysis.

4. How do you ensure high client satisfaction levels are maintained by your practice?

Merger control is judged on two things: Whether the answer to the filing question was right, and whether the clearance arrived when we said it would. We organise the practice around those two tests, and around a client-focused way of working in which the client is never the last to know.

We are very experienced working with the Authority over many years, and we manage expectations accordingly. Timing assumptions in a transaction agreement should be set against the realistic distribution of outcomes for a deal of the relevant profile, not against the statutory 30 days read in isolation. We explain at the outset what the process will look like, where the discretionary points lie and what could extend it, so that long-stop dates and financing arrangements are built on a defensible view rather than an optimistic one.

We inform the client fully and we interrogate what we are given. Information supplied for a filing is reviewed closely rather than passed through, because an inaccuracy or a gap is not a presentational problem in this jurisdiction; it is a fine, a reopened decision or a restarted clock. A complete and internally consistent form assembled once is the shortest route to clearance, and it is where the bulk of our effort goes.

Where a file is likely to raise concerns, we say so early. Clients are told what a possible extension would mean commercially, what the Authority is likely to look for and what shape a commitment package might take, well before the question is put to them. Managing that process depends on maintaining an open and constructive dialogue with the Authority throughout, which in our experience produces better outcomes than a defensive posture.

Finally, we treat merger control as one part of a wider competition picture. Transactions routinely surface information exchange, distribution or labour market issues in the target that have nothing to do with the concentration but everything to do with what the buyer is acquiring. A practice that clears the deal and ignores those findings has done half the job, so post-closing work like competition trainings is planned during diligence rather than proposed afterwards.

5. What technological advancements are reshaping merger control and how can clients benefit from them?

The technology that matters here is not principally drafting software. Two developments are doing the reshaping: The Board’s own record has become analysable at scale, and its remedies have themselves become technical.

The most valuable application is systematic analysis of the Board’s decisional practice: The reasoned decisions are published, and the accumulated body is now large enough, and machine-readable enough, to support genuine quantitative analysis. Structured mapping of that case law, including how the decisions cite one another, identifies which of them the Authority itself treats as authoritative in a given area and shows how its reasoning on control, market definition, efficiencies and remedies has shifted. The account of commitment practice set out above, from divestiture towards behavioural packages and now investment undertakings, is a reading of that record. Performed by hand, such a reading is necessarily anecdotal and backward-looking. Performed systematically, it becomes prospective: Which precedents a given theory of harm will attract, which remedy shapes have survived in comparable markets, and what the Authority has actually required rather than what the guidelines permit. It already yields usable results: Market definition is the ground on which the Board most often reaches for its own precedent, and its reliance on European precedent, having fallen as domestic case law accumulated, has risen again since 2016 with digital-market questions.[20] For clients, this converts questions that were historically answered qualitatively, such as how the Board has treated veto rights of a particular kind or how long a filing of this profile actually takes, into calibrated estimates grounded in the Authority’s own record.

Turnover analysis is the second area where automation repays the investment. Threshold assessment across a group with multiple Turkish entities, several currencies and a three-year acquisition history is a data exercise before it is a legal one, and building that dataset once, in structured form, answers the notifiability question on each successive transaction in minutes rather than days. What matters is maintenance. February 2026 moved every figure in the test, and nominal thresholds never stay still for long: A system that stores the rule is a liability where one that re-verifies it on each run is an asset. A tool encoding last year’s numbers does not fail visibly; it produces confident, wrong answers.

The second development belongs to the Authority. Recent commitment packages have specified access controls, audit logging and data-loss prevention as the substance of the remedy itself, verified by an independent auditor on a fixed reporting cycle. Remedy compliance is accordingly an engineering exercise as much as a legal one: The obligations must be implemented in systems, evidenced continuously, and demonstrable to a third party years after clearance. Parties who treat a conditional clearance as a document rather than a configuration discover the gap at the first audit.

In the filing itself, model-assisted drafting and review shorten the assembly of the notification form and of responses to requests for information, particularly the extraction of market data, product descriptions and corporate structure from source material. The constraint is verification, and for the reasons set out under the penalty regime above it is no formality: Every machine-generated figure or characterisation is checked by a lawyer before it goes into a filing. Client confidential material is processed only in tools with appropriate contractual and security assurances, and data-room personal data in line with applicable data protection laws.

None of this displaces judgement. Whether a veto right confers joint control, whether a market definition is defensible and whether a commitment will satisfy the Board are questions that turn on experience of how this Authority reasons. The value of the technology is that it leaves more time to exercise that judgement, and better evidence on which to exercise it.

 

Footnotes: 

[1] The calculations from here on are based on the CBRT’s 2025 annual average buying exchange rates of EUR 1 = TRY 44.71 and USD 1 = TRY 39.48.

[2] Board’s Petrol Ofisi / BP decision dated 12.09.2024 and numbered 24-37/885-379.

[3] Board’s EssilorLuxottica / Merve Optik decision dated 01.10.2018 and numbered 18-36/585-286.

[4] https://www.rekabet.gov.tr/en/Guncel/the-acquisition-of-carrefoursa-by-a101-c-095dbf376e91f11194000050568585c9

[5] Board’s DP World / Evyap Port decision dated 2023 and numbered 23-54/1075-379.

[6] Board’s CEVA / Borusan decision dated 2025 and numbered 25-40/967-560.

[7] Board’s Kariyer.net / Brotek decision dated 2024 and numbered 24-24/556-236.

[8] Board’s CoreX / Polisan decision dated 03.04.2026 and numbered 26-12/357-137.

[9] Board’s Param / Kartek decision dated 27.12.2024 and numbered 24-56/1241-531.

[10] Board’s Cargill / PNS decision dated June 2026 and numbered 26-23/685-275.

[11] Board’s Honeywell / Civitanavi decision dated 2024 and numbered 24-33/808-342.

[12]Board’s EssilorLuxottica enforcement decision dated 17.08.2023 and numbered 23-39/749-259.

[13] Board’s Tofaş / Stellantis TR decision dated 18.04.2025 and numbered 25-15/359-172.

[14] https://www.rekabet.gov.tr/en/Guncel/acquisition-of-some-business-lines-of-ge-5dcf42bb3d6bf11193eb0050568549fa

[15] For more detail, please see: https://www.rekabet.gov.tr/en/Guncel/the-examination-about-the-acquisition-of-d384a31c4ebfed118eb0005056850339

[16] Please find the decision dated 04.04.2024 and numbered 24-16/390-148 here in Turkish: https://www.rekabet.gov.tr/Karar?kararId=2300bafc-f3fe-4423-806a-c62670b26993

[17] Three separate administrative monetary fines were imposed on Modern Times Group MTG AB (“MTG”) for completing three acquisitions of gaming companies, namely Plarium Global Ltd. (“Plarium”), Snowprint Studios AB (“Snowprint”) and AutoAttack Games Ltd. (“AutoAttack”), without prior notification to the Turkish Competition Authority (the “Authority”). For more detail, please see Board’s MTG/ Plarium decision dated 25.09.2025 and numbered 25-36/856-504, MTG/Snowprint decision dated 25.09.2025 and numbered 25-36/857-505, MTG/AutoAttack decision dated 25.09.2025 and numbered 25-36/858-506.

[18] Board’s Akzo Decision dated 18.3.2010 and  numbered 10-24/339-123.

[19] Board’s Lotte Chemical’s Decision dated 30.6.2022 and numbered 22-29/470-189.

[20] Emin Köksal, Cansu Peker and Melih Üyer, ‘The Intellectual DNA of the Turkish Competition Board: Mapping Three Decades of Case Law Through Citation Networks’ (10 July 2026), available at http://dx.doi.org/10.2139/ssrn.7094258.