What Does “Established In Türkiye” Mean? The TCA’s Latest Decisions Under The Revised Technology Undertakings Rule

What Does “Established in Türkiye” Mean? The TCA’s Latest Decisions Under the Revised Technology Undertakings Rule

On 11 February 2026, the Turkish Competition Authority (“TCA”) amended Communiqué No. 2010/4 through Communiqué No. 2026/2, restricting the special notification rule for technology undertakings to those "established in Türkiye" and introducing a TRY 250 million Turkish turnover threshold for the target. The definition of a technology undertaking itself remained unchanged.

Under the previous framework, the rule captured technology undertakings with a relatively loose territorial nexus to Türkiye, including those merely supplying services to Turkish users without any corporate presence. The shift to an establishment requirement therefore suggested that a stronger connection would be needed, but neither the amending communiqué nor the TCA's accompanying announcement defines what "established in Türkiye" means.