Law No. 4054 on the Protection of Competition (“Competition Act”) provides the cases that serve as a ground for competition damages claims. Pursuant to Article 57 of the Competition Act, (i) conducts, decisions, contracts and agreements that infringe the Competition Act, and which prevent, distort or restrict competition, or (ii) abuse of dominance in a market constitute the causes of action for competition damages claims.

In this context, conduct, decisions, contracts and agreements that infringe the Competition Act typically include:

• restrictive agreements, concerted practices and decisions of undertakings or association of undertakings (Article 4); and
• anti-competitive mergers and acquisitions (Article 7).

Abuse of dominance practices are described and exemplified in Article 6 of the Competition Act.

Article 56 adds a further consequence: agreements and association decisions that infringe Article 4 are void, and performance under them cannot be demanded. Restitution of amounts already paid follows the Code of Obligations’ general unjust-enrichment rules but Article 56 disapplies Article 65 of that Code, the general in pari delicto bar on reclaiming what was given for an unlawful purpose. This nullity-and-restitution route is thus available as a further cause of action, distinct from a damages claim under Article 57.

The Competition Act does not limit the claimants of competition damages claims. Any party, including natural or legal persons that are deemed as an undertaking or not, suffering from the cases mentioned in Question 1 can claim their damages.

If both the claimant and the respondent of a competition damages case are deemed merchants under the Turkish Commercial Code No. 6102 (“Commercial Code”), a mediation process is mandatory and a prerequisite for initiating the lawsuit. If the parties fail to reach a settlement during the mediation process, the claimant may subsequently file a lawsuit. According to Article 5/A(2) of the Commercial Code, the mediation process should be concluded in 6 weeks, and can be extended up to 8 weeks in cases of force majeure. The mediation process pauses the periods of statute of limitation and time-bar.

Other than this, there is no dedicated procedural regime for competition damages claims under Turkish law. Accordingly, claimants are subject to the general tort-based civil litigation procedure and must comply with the procedural rules of Turkish civil procedure law, in particular the Code of Civil Procedure No. 6100 (“Civil Procedure Code”).

As a general rule, the Competition Act does not limit the types of damages for competition damages claims. Claimants can claim “all types of their damages”, with regards to the general provisions of Turkish tort law.

Article 58 of the Competition Act provides guidance towards claims, as follows:

• Claimants that suffer from prevention, distortion or restriction of competition may claim difference between the prices they paid and the prices they would have paid in the absence of such infringement;
• Competitors that are affected by competition restrictions may claim their entire damages;
• Claimants may claim treble damages or three-fold amount of the respondent’s potential or actual profit, in cases where the damages are incurred due to an agreement, a decision or gross negligence.

Aside from the substantive damages, claimants can also request ancillary awards such as litigation costs, attorneys’ fees, and interest.

The measure of damages follows the general Turkish tort principle of full compensation: the claimant is to be placed in the position it would have occupied had the infringement not taken place. In practice the loss is quantified as the difference between the claimant’s actual financial position and the hypothetical “but-for” position absent the infringement. Article 58(1) of the Competition Act translates this into two heads of recovery: (i) parties harmed by the prevention, distortion or restriction of competition may claim the difference between the price they paid and the price they would have paid absent the infringement (the classic overcharge, most relevant to cartels); and (ii) competing undertakings affected by the restriction may claim the entirety of their loss, including the profits they were prevented from earning, their past balance sheets being taken into account.

Article 58(2) additionally empowers the court, at the claimant’s request, to award up to three times the material loss (or up to three times the profit the infringers gained or were likely to gain) where the harm results from an agreement, a decision, or gross negligence. This treble award is discretionary rather than automatic: the court must first establish an actual, quantified loss on a but-for basis and then expressly exercise its discretion to multiply it, so that a claim for the multiplied amount fails where the single-fold loss itself is not proven (İzmir Regional Court of Appeal, 11th Civil Chamber, 2023/1845 E., 2025/263 K.). Quantification is fact-intensive and, in the banking-cartel follow-on actions, the courts have proceeded on the basis of court-appointed expert (bilirkişi) reports to assess whether and to what extent the claimant paid an overcharge (see, e.g., Court of Cassation, 3rd Civil Chamber, 2024/54 E., 2024/3696 K.). The economic methodologies used for that assessment are discussed at Question 18.

Joint and several liability is expressly recognised. Under the second sentence of Article 57 of the Competition Act, where the loss has arisen from the conduct of more than one person, those persons are jointly and severally liable for it. The claimant may therefore pursue any one, several, or all of the infringing undertakings for the whole of the loss, and where affiliated undertakings are involved the action may be directed at the parent or the subsidiary according to the role each played in the prohibited conduct. Internal apportionment between co-infringers is a separate question, governed by the recourse rules of the Code of Obligations (see Question 20).

Turkish law contains no exception shielding leniency applicants from private damages liability. Neither the Competition Act nor the secondary legislation on leniency grants an immunity recipient any civil-law privilege; the benefit of leniency is confined to the reduction or removal of administrative fines and does not attenuate the applicant’s exposure to, or its joint and several liability in, a damages claim (see also Question 17).

There are no competition law specific limitation periods for competition damages claims. Therefore, general tort law principles apply.

Pursuant to Article 72 of the Turkish Code of Obligations No. 6098 (“Code of Obligations”);

• a 2-year ordinary limitation period from the date the claimant becomes aware of both the harm and the liable party; and
• a 10-year maximum limitation period from the perpetration date of the competition infringement,

should be applied. Yet, limitation operates as a defence rather than a matter the court raises of its own motion: under Article 161 of the Code of Obligations, the court may take limitation into account only if the defendant expressly pleads it.

However, Article 72 of the Code of Obligations also provides that statute of limitation provided under penal laws should be implemented in cases where damages arise from an action that constitutes a crime and the statute of limitation provided under the respective penal provision is longer.

Based on the Misdemeanors Act No. 5326 and the established precedents of the Court of Cassation, competition infringements are bound by the statute of limitation period of 8 years with respect to the Competition Authority’s enforcement. Although there is not an established practice of courts regarding this issue, it could be argued that the ordinary limitation period, which begins by the date the claimant becomes aware of both the harm and the liable party, should be implemented as 8 years.

Articles from 154 to 161 of the Code of Obligations regulate interruption of the statute of limitations. Accordingly, the following cases warrant interruption of the limitation period:

• Acknowledgement of the damages by the liable party; or
• Claiming the damages before a court or initiating an enforcement or bankruptcy action with regards to the damages claimed.

It is worth underlining that filing a complaint with the Competition Authority (“Authority”) against the liable undertaking, nor any action by the Authority do not suspend or interrupt the limitation period. Such a complaint is only relevant for determining the date on which the harm and the liable party became known. Similarly, the initiation of an investigation by the Board against the liable undertaking does not, in itself, constitute a ground for suspension or interruption. Indeed, there is no provision under Turkish law that recognises such investigative actions by the Board as having any effect on the running of the limitation period.

When the limitation period becomes interrupted, the limitation period restarts from day zero after the interruption ends.

Pursuant to Article 2 of the Civil Procedure Code, unless otherwise provided by the law, the Civil Courts of first instance are competent to hear competition damages claims.

As above-mentioned, in the event both the claimant and the respondent parties of a litigation are considered as ‘merchants’ under the Commercial Code, any lawsuits, including competition damages claims, must be resolved by Commercial Courts of first instance.

Furthermore, where the relationship between the claimant and the defendant qualifies as a “consumer transaction” under the Consumer Protection Act No. 6502 and the claimant is an end user, Consumer Courts of first instance must adjudicate the disputes regarding competition damages.

Pursuant to the general rule of jurisdiction provided in Article 5 of the Civil Procedure Code, the court of the respondent’s business address has the jurisdiction.

Additionally, since competition damages claims are classified as tort claims under Turkish law, the following courts may also have jurisdiction:

• the court where the competition infringement was perpetrated;
• the court where the damage occurred or is likely to occur; or
• the court of the claimant’s domicile or business address.

According to Article 38 of the International Private and Procedural Law Act No. 5718 claims arising from restriction of competition shall be governed by the laws of the country whose market is directly affected by the restriction. For that reason, competition damages claims regarding competition infringements that affect Turkish market should be resolved in accordance with Turkish law.

The general standard of proof applicable within tort cases under Turkish law requires the claimant to prove:

• the existence of the alleged tort;
• the occurrence and amount of the damage;
• fault on the part of the respondent; and
• a causal link between the competition law infringement and the damage suffered.

The Competition Board’s decision plays two distinct evidentiary roles. As explained at Question 10, once final it is conclusive as to the existence of the infringement itself. As to the remaining elements of the claim, the occurrence, amount and causal link of the claimant’s own loss, the Board’s findings on the nature, scope and market impact of the infringement serve as highly persuasive evidence, materially lowering the burden the claimant would otherwise face in proving causation and quantum.

Furthermore, Article 59(1) of the Competition Act allows reversal of the burden of proof from the claimant to the respondent, in cases where damage has been caused by cartels or concerted practices. Accordingly, if the claimant presents evidence regarding existence of an anti-competitive agreement or indications of distortion in the market, such as factual division of market, stability in market prices observed over a relatively long period, or price increases applied by undertakings operating in the market at close margins, the respondent should undertake the burden of proving absence of a collusion among undertakings.

For domestic decisions, the settled position of the Court of Cassation is that a finding of infringement by the Competition Board is a precondition of a damages claim, by way of the concept of ‘prejudicial issue’ provided under the Civil Procedure Code. This is not a formal condition of the action (“dava şartı”) that would bar the claim if filed before the Board has ruled but a substantive prerequisite to success on the merits, given effect by staying the proceedings rather than dismissing the claim. Pursuant to Article 165 of the Civil Procedure Code “if the rendering of a judgment in a case depends, in whole or in part, on the outcome of another case, on a determination by an administrative authority, or on the existence of a legal relationship pertaining to the subject matter of the case, the court may stay the proceedings until that case is resolved or until the administrative authority issues its decision.”: That said, courts consider that the unlawfulness on which the claim rests can be established only by the Board, and once the Board’s decision has become final it operates as conclusive proof of the infringement before the civil court. Where the Board’s decision is not yet final, typically because it is under review before the administrative courts and the respective appeal courts, the civil court does not rule on the infringement but stays the action, treating the finality of the Board’s decision as a prejudicial issue  under Article 165 of the Civil Procedure Code. This approach is firmly established in the recent follow-on litigation: see, among many, Court of Cassation, 3rd Civil Chamber, 18 November 2024, 2024/54 E., 2024/3696 K. and 13 February 2024, 2023/2603 E., 2024/590 K.; and İstanbul Regional Court of Appeal, 45th Civil Chamber, 18 December 2024, 2024/833 E., 2024/1690 K., which collects the earlier authorities (Court of Cassation, 11th Civil Chamber, 2013/7687 E., 2014/13657 K. and 2015/5134 E., 2016/2543 K.; 19th Civil Chamber, 2008/5139 E., 2008/12276 K.). The corollary is equally settled: if the administrative courts ultimately annul the Board’s infringement decision, the civil claim fails for want of an unlawful act, irrespective of the fine originally imposed.

Turkish courts are not bound by the decisions of foreign competition authorities such as the European Commission or the U.S. antitrust agencies. Such decisions may nonetheless carry persuasive weight, particularly in multi-jurisdictional matters such as international cartels, and their influence in a given case will depend on the content of the decision and its connection to the Turkish market. There is as yet no Court of Cassation authority squarely addressing the evidentiary status of foreign infringement decisions in Turkish damages actions.

A private damages action may be filed while the Competition Board’s public enforcement is still under way, and the mediation prerequisite (Question 2) or limitation concerns may in practice prompt claimants to file before the Board’s decision is final. As a rule, however, the action typically is not expected to be carried through to judgment in parallel with the public process. Because the civil court cannot itself determine the existence of the infringement, it will ordinarily stay the damages action as a prejudicial issue until the Board has decided and, where the decision is challenged, until it has survived judicial review before the respective appeal court (see Question 10). Filing a complaint with the Authority, or the opening of an investigation, does not of itself suspend or interrupt the limitation period (see Question 5).

Turkish law provides no mechanism enabling the Authority or the Board — which are not parties to the civil proceedings — to stay a private action. The decision whether to suspend the civil case is the civil court’s alone, exercised under Article 165 of the Civil Procedure Code; in practice the courts exercise that discretion in favour of awaiting the Board’s final decision, but the impetus comes from the court (typically on the defendant’s request), not from the enforcer.

Turkish civil procedure does not offer an opt-out class action or a US-style damages class mechanism, and this remains the principal structural gap in Turkish private enforcement. As a matter of principle a claimant may sue only on its own behalf and for its own loss, which is difficult to reconcile with the group-wide, aggregate assessment of damages that a class action entails.

Three narrower devices are nonetheless available. First, Article 113 of the Civil Procedure Code permits a “community action” by associations and other legal entities to protect the interests of their members — but this is confined to the determination of unlawfulness and to declaratory or injunctive relief, and cannot be used to recover aggregated monetary damages for the members.

Second, where several claims arise from the same infringement, the court may consolidate connected actions through case management (Article 166 of the Civil Procedure Code). Third, claims may be assigned (Article 183 of the Code of Obligations), so that a claims-vehicle or bundled-assignment model is theoretically conceivable, although it is untested in the competition field. None of these substitutes for a genuine collective damages procedure.

Neither the Competition Act nor Turkish case-law expressly regulates or has yet tested the pass-on defence, and no Turkish court has yet applied it in practice; there is no reported judgment in which it has been examined. Were a Turkish court to entertain it, ordinary evidentiary principles would apply: as the party raising the pass-on argument, the defendant would be expected to substantiate that the overcharge was passed on, in line with the general rule that a party asserting a fact bears the burden of proving it, and may seek supporting information or evidence from the claimant or a third party. The defence, and the correlative indirect-purchaser rule, have to date been discussed in Turkey mainly as features of EU law rather than domestic practice. Separately, even without formal recognition of a stand-alone pass-on defence, Article 52 of the Code of Obligations gives the court a general discretion to reduce or eliminate damages where the claimant’s own conduct contributed to the occurrence or aggravation of the loss; a defendant could seek to invoke this provision to argue that the claimant’s resale or pricing conduct diminished the loss actually suffered.

Expert evidence is admissible and, in practice, central to competition damages litigation, where the existence and quantum of loss turn on economic questions the court cannot resolve unaided. Under Article 266 et seq. of the Civil Procedure Code, expert examination is a discretionary form of evidence: the court appoints the expert (bilirkişi), whether of its own motion or on a party’s request, and the expert owes duties of independence and impartiality to the court rather than to any party. In the follow-on banking-cartel actions the courts have consistently commissioned expert reports to assess whether, and to what extent, the claimant paid a cartel overcharge.

In addition, a party may submit its own expert opinion (uzman görüşü) under Article 293 of the Civil Procedure Code. Such privately commissioned opinions are admissible, but the weight to be given to them, as against the court-appointed expert’s report, remains within the court’s discretion.

There being no special procedural regime, the general rules of civil procedure govern. The proceedings have written and oral stages. First, the parties set out their claims and defences in written pleadings; after the exchange of written pleadings and a preliminary examination, the court moves to the investigation stage, with hearings held in particular to examine evidence, such as expert reports, expert opinions, and commercial books of companies etc. Within the scope of the investigation phase, the court typically orders preparation of an expert report for calculation of damages, summons and hears the witnesses, and carries out other evidence-examining work, such as on-site inspection. Following the investigation phase, the court decides to end the investigation and move the case to the oral pleading phase. In the oral pleading phase, the court asks for the last arguments of the parties and renders its decision.

At first instance, the case is heard, depending on the parties’ status, by a commercial court, a consumer court or a general civil court, which is the decision-maker on both fact and law. Turkish procedure does not recognise adversarial cross-examination: witnesses are questioned by the court, and while counsel may put questions, this occurs under the judge’s control rather than through direct party-to-witness examination.

The first hearing in a competition damages action is typically held some 3 to 6 months after filing, subject to the court’s workload, the complexity of the file and the number of parties, the state of service of process and any deficiencies in the pleadings. After the preliminary hearing the case moves to the investigation stage, in which evidence is gathered and expert reports obtained; a first-instance judgment commonly follows within about 1.5 to 2 years, though the timetable may be extended due to awaiting of the finalization of the Competition Board’s decision and its judicial review before ruling.

Turkey has a three-tier judicial system. An appeal against the first-instance judgment lies to the competent Regional Court of Appeal where the monetary thresholds are met; unlike cassation, this appeal involves a full re-examination on the facts and, if necessary, a fresh judgment on the merits. A further appeal on points of law lies to the Court of Cassation against the Regional Court of Appeal’s decision, again subject to the applicable thresholds. Each of these appellate stages may take up to two years to conclude.

A leniency applicant obtains no benefit in the damages context. Turkish private law affords no protection to undertakings that have used the leniency mechanism: a leniency application confers no substantive or procedural advantage, exemption or cap in a subsequent damages action, and does not affect the applicant’s joint and several liability. The benefit of leniency is limited to immunity from, or reduction of, administrative fines (see also Question 4).

The court assesses loss on the difference (but-for) basis described at Question 4, comparing the claimant’s actual position with the position that would have obtained absent the infringement. No single economic methodology is prescribed; in practice the analysis is entrusted to court-appointed experts, who may draw on comparator-based techniques (comparison across time — before, during and after the infringement — or across markets or firms) and on regression analysis to isolate the overcharge from other price drivers.

“Umbrella effects”, the harm suffered by customers of non-infringing competitors that raised their own prices under the price umbrella created by the cartel, are not addressed by the Competition Act, and Turkish courts have not yet ruled on them. In EU law the Court of Justice has accepted, in Kone (C-557/12), that umbrella damages are in principle recoverable where the requisite causal link is shown. Given the EU-oriented character of Turkish competition law and the fact that the Competition Act does not confine standing to claimants who dealt directly with the cartel members, an umbrella claim might be theoretically entertained, if the claimant could prove both the loss and a causal link between the cartel and the competitors’ price increases.

Because these claims sound in tort, interest runs as default interest (temerrüt faizi); and, since the debtor is in default from the moment the tort is committed, it accrues from the date the loss arose rather than from any later demand. The applicable rate depends on the parties’ status: where both parties are merchants, commercial default interest applies; where at least one party is not a merchant, the statutory rate under the Law No. 3095 on Statutory Interest and Default Interest applies.

Where several undertakings have acted together in breach of the Competition Act they are jointly and severally liable to the injured party under the second sentence of Article 57, and the claimant may recover the whole of its loss from any one of them. As between the co-infringers, however, liability is shared internally in proportion to each party’s degree of fault and the gravity of its conduct.

An undertaking that has paid more than the share corresponding to its own fault has a right of recourse against the other liable undertakings under Article 62 of the Code of Obligations, so that the compensation burden is ultimately reallocated according to each party’s contribution to the harm. This preserves the injured party’s ability to obtain full compensation from a single defendant while ensuring a fair final allocation among the infringers.

A claim for recourse is time-barred after two years have elapsed from the date on which the full amount of compensation was paid and the jointly liable party was identified, and in any event after ten years have elapsed from the date on which the full amount of compensation was paid.

A case may be disposed of at the preliminary stage. The claim may be dismissed on procedural grounds, for a number of reasons including lack of jurisdiction or competence, or where a fundamental condition of the action such as legal interest, capacity to be a party or capacity to sue is absent, or where the defendant successfully raises a plea of res judicata, without any examination of the merits.

Additionally, the claimant may waive their claims and thereby terminate the proceedings at any time before the judgment becomes final.

Turkish law provides no collective settlement mechanism designed for competition damages. Settlement is a matter of general contract law and binds only the contracting parties, there is no procedure by which a settlement can be made binding on a defined class, whether domestic or foreign.

Document production is governed by Article 219 et seq. of the Civil Procedure Code. A party, in principle, must produce the documents in its possession that are relevant to the dispute, and may ask the court to order the opposing party or third parties, including the Competition Authority, to produce a document believed to be in its hands; the court then assesses relevance, possession and whether production is legally permissible before ordering it.

Due to defined circumstances, such as protection of trade secrets, professional confidentiality, personal data and private life, and documents requiring a third party’s consent, the court can order that the documents submitted to the case file be treated as confidential. Such confidential documents cannot be accessed without the court’s express approval.

Currently Turkish law does not have a comprehensive framework for protection of trade secrets and the Civil Procedure Code does not regulate these mechanisms in detail, so each case is assessed on its own facts and decided in accordance with the principle of proportionality. Further, Turkish law contains no dedicated carve-out protecting leniency statements or settlement submissions from disclosure.

During the proceedings the court may adopt various measures to protect trade secrets and personal data, including:

• submission of the relevant document or information to the file under a confidentiality order; and
• restricting access to the file, by requiring the court’s express permission.

On the other hand, pursuant to the principle of publicity provided in Article 28 of the Civil Procedure Code, hearings and verdicts shall always be public. The only exception to that rule is that there is a “definitive necessity for secrecy due to general morality or public security”. Accordingly, protection of confidential information, personal data or trade secrets typically does not amount to a reason for ensuring privacy of the hearings and court’s verdict.

Litigation costs are, in principle, borne by the unsuccessful party. Under Articles 323 and 326 of the Civil Procedure Code, the losing party is liable for the costs of the proceedings, which include court fees, service, expert, witness and site-inspection costs, and the statutory attorney’s fee awarded to the successful party. Court fees are set by the tariff under the Law on Fees; expert, inspection and witness fees follow annually published tariffs, and the statutory attorney’s fee is fixed by the Minimum Attorneyship Fee Tariff published each judicial year by the Union of Turkish Bar Associations.

Where each party succeeds in part, the costs are apportioned between them in proportion to their respective success and failure, so that recovery may be correspondingly limited.

No rule expressly prohibits a third party from bearing another party’s litigation costs, so third-party funding is in principle permissible. However, because only the parties to the action can be held liable for its costs, a third-party funder, cannot be ordered to pay the opposing side’s costs.

As for lawyers’ fees, the Attorneyship Law No. 1136 allows fee arrangements to be linked to the outcome of the case, but the agreed fee may not fall below the Minimum Attorneyship Fee Tariff.

Several circumstances may be considered as obstacles to litigating competition damages claims.

First, the absence of any collective-redress mechanism makes individually small, widely dispersed claims economically and commercially irrational to pursue. Claims put forward by smaller market players, undertakings operating within the supply chain or consumers might even trigger covert exclusionary conduct by the defendant.

Second, because competition harm turns on complex economic behaviour, quantification almost always depends on expert analysis, which lengthens the proceedings and adds to their cost. Furthermore, claimants’ access to evidence usually falls short of proving the causal link between the alleged unlawful conduct and the damage incurred.

Third, the estimated duration of the cases may discourage the injured parties from initiating lawsuits, given the “prejudicial-issue” practice (see Question 10), since cases are routinely stayed until the Competition Board’s decision and its potential judicial review are final, which may even exceed a decade.

Historically these factors have kept private enforcement marginal; the wave of follow-on actions arising from the banking-cartel decision suggests the picture is beginning to change.

The 2020 amendments to the Competition Act (Law No. 7246) introduced, among other changes, the commitment and settlement procedures into Turkish competition law. Since then, a growing number of the investigations conducted by the Competition Authority have come to be concluded within shorter timeframes — in particular through the settlement procedure, in which the investigated undertaking admits the infringement. Because settlement decisions contain a finding and an admission of the infringement, as well as a waiver from appeal lawsuits against the settlement decision, they offer a firmer basis for follow-on damages actions; coupled with the faster finalisation of the Competition Board’s decisions, an increase in competition damages claims can accordingly be expected in the near future.

As regards potential future developments more broadly, although Turkish case-law on competition damages is not yet extensive, the anticipated growth in such actions is likely to generate a greater number of landmark rulings from the Court of Cassation and the regional courts of appeal. This should, in turn, bring greater clarity and predictability to the factors that shape the decision whether to pursue a damages claim — such as the methodology for calculating loss and the applicable evidentiary thresholds.

By contrast, the commitment procedure may pull in the opposite direction, because an investigation resolved through commitments is closed without a definitive finding of infringement or the imposition of an administrative penalty. For that reason, it could be argued that the conduct concerned, even where it might well have amounted to a competition infringement, is effectively placed beyond the reach of damages claims, which under the settled case-law require a final infringement decision of the Board (see Question 10). The wider use of the commitment mechanism may therefore, in practice, remove a category of potentially actionable conduct from the scope of private enforcement. Indeed, it could therefore be desirable for the legislator to address this gap, for example, by preserving a route to compensation for those harmed by conduct that is closed through commitments, so that the efficiency gains of the commitment mechanism are not achieved at the expense of injured parties’ right to recover their loss.

A further, near-certain development is procedural rather than substantive: the Constitutional Court has annulled Article 1 of Law No. 3095, the source of the default statutory interest rate, as applied to non-contractual obligations, with effect from 1 September 2026 (E.2024/24, K.2025/164, 22 July 2025). Unless the legislature enacts a replacement mechanism before that date, claimants in competition damages actions against non-merchant defendants will face a legislative gap in calculating default interest, which is likely to generate its own body of litigation and possibly a shift toward claiming excess inflation-linked loss under Article 122 of the Code of Obligations instead of, or alongside, statutory interest.