May 2026 – Following the February 2026 updates, the Turkish Competition Authority (“Authority”) has introduced pivotal changes to four merger control guidelines (“Guidelines”). While the amendments provide welcome clarity on transaction aggregation and joint venture coordination, the new methodology for technology undertaking turnovers represents a sharp departure from established practice.
1. The Major Shift: Sector-Specific Turnover for Technology Undertakings
The most impactful change introduces a granular approach to calculating turnover for technology undertakings. The Authority has moved from a general turnover approach to a surgical one for technology undertakings. Under Article 7(2), the TRY 250 million threshold is now assessed based only on turnover derived from specific fields: digital platforms, software/gaming, fintech, biotech, pharmacology, agrochemicals, and health tech shall be taken as the basis.