NEWS & INSIGHTS

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June 2025 – May continued to reflect the Turkish Competition Authority’s (“TCA”) proactive stance, in line with previous months. The TCA issued notable decisions across a broad spectrum of matters, ranging from exemption assessments of credit card cooperation agreements between banks to investigations into the raw milk market. This issue of Quick Read dives into these key developments, providing you with a concise overview of the most important happenings in Türkiye’s competition law landscape during the past month.

TCA Releases 2024 Activity Report

A notable development in May was the release of the TCA’s 2024 activity report, highlighting its sustained focus on active enforcement. According to the report, the TCA handled 139 investigation files over the year. Of these, administrative fines were imposed in 20 cases following full investigations, while 90 cases were concluded through settlement procedures and 23 through commitment mechanisms. These figures underscore the TCA’s strategic use of settlement and commitment tools as key instruments in its enforcement efforts throughout 2024. We have summarised the highlights of the TCA’s activity report here.

Dive into May Case Updates

1. TCA greenlit Uber’s acquisition of TrendyolGO

The TCA has approved the acquisition of an 85% stake and sole control of TrendyolGO, a platform that connects couriers, customers, markets, and restaurants, by US-based transportation and delivery services company Uber.[1] The TCA concluded that the transaction does not impede the effective competition in any product market in Türkiye. With the TCA’s approval, Uber Eats is set to enter the Turkish market, where it will compete with established players such as Yemeksepeti and Getir Yemek.

2. TCA fines RMX concrete firms in Malatya and Aydın provinces

The TCA once again turned its focus to the ready-mixed concrete and cement sectors—industries that have frequently been under the TCA’s radar. The TCA concluded an investigation into several companies operating in the ready-mix concrete, cement, and aggregate production and sales markets in Malatya.[2] The investigation found that several undertakings engaged in price fixing and customer sharing in the ready-mixed concrete as well as the aggregate markets. The TCA continued its scrutiny regarding competition infringement in the labor market and found that the investigated parties also violated competition law by fixing employee wages. Consequently, the TCA imposed separate monetary fines for each infringement, totalling of TRY 70.5 million (approx. EUR 1.6 million).[3]

The TCA similarly imposed fines totalling approx. TRY 76.5 million (approx. EUR 1.7 million) on four ready-mixed concrete producers operating in Aydın over allegations of price fixing and allocation of customers and territories.[4] Previously, the investigation resulted in settlements for 11 producers operating in Aydın, and a total fine of approx. TRY 114 million (approx. EUR 2.6 million) was imposed on these companies.

3. TCA orders revisions to World Credit Card agreement

The TCA has concluded its review of the cooperation agreements signed between banks participating in the World Credit Card Program.[5] The review focused on several restrictive clauses within these agreements, including limitations on member banks providing services to each other’s merchants, restrictions on participating in other co-branded card programs, and constraints on advertising, promotional campaigns, and service terms under the program.

As a result of the review, the TCA ruled that the prohibitions on (i) World banks serving each other's merchants, (ii) joining alternative co-branded programs, and (iii) conducting advertising directly targeting other member banks can benefit from individual exemption. However, the TCA also determined that some clauses imposed restrictions that go beyond what is necessary for cooperation and must be revised. The contractual provisions identified for revision include:

• Narrowing the restriction on offering services to merchants currently working with another World bank, allowing offers to merchants who proactively seek to change providers;
• Removing “waiting periods” before another bank can provide services to merchants whose relationship with a World bank has ended;
• Ensuring member banks are free to set card and annual membership fees, as well as maximum contractual interest rates;
• Setting a minimum nine-month transition period for card migration when a bank exits the program.

4. TCA grants conditional exemption to Bonus Card program agreements

The TCA has granted conditional individual exemption to the Bonus Credit Card Program Sharing Agreements signed between Garanti BBVA and other banks participating in the Bonus program.[6] While the agreements were generally deemed eligible for exemption, certain restrictive clauses, such as the one-month ban on offering services to merchants that have exited the Bonus program, were found excessive. The TCA ruled that these specific provisions cannot benefit from exemption unless amended to reduce their anti-competitive effects.

On the other hand, other restrictions, such as the prohibition on providing services to merchants currently affiliated with the Bonus program during the term of the agreement, were considered eligible for individual exemption. Additionally, the TCA stipulated that for the agreements to receive exemption, clauses requiring payment service providers to prevent merchants from receiving services from competing card or loyalty programs, or to avoid any practices or statements suggesting that the Bonus program is less rewarding or more expensive than competitors, must be removed from the agreements.

5. Doğa College’s labour market practices penalised

The investigation into allegations that private schools operating in Kocaeli colluded to fix school fees, set employee salaries, and not hire each other’s employees was concluded with settlements for 18 undertakings. As a result of the investigation, Doğa College, the only undertaking that did not settle with the TCA, was found to have violated competition law. In the reasoned decision, the TCA ruled that Doğa College’s involvement in determining employee wages and no-poach agreements constituted a violation.[7]

6. TCA skips dawn raid obstruction fine to Unmaş

During an on-site inspection at Unmaş, a baked goods producer known under the Uno brand, concerns arose over the possible deletion of three e-mails.[8] However, the TCA concluded that no e-mails had been deleted; the functions used were identified as archiving and recall actions, which appeared as deletions in the system logs. Despite dissenting opinions within the decision noting that a greater number of e-mails and WhatsApp messages had allegedly been deleted, suggesting that an administrative fine should have been imposed, the TCA ultimately determined that the on-site inspection had not been obstructed.

New Investigations Announced

• TCA expands Apple Investigation to include sensitive data exchange in buy-back market:[9] Early this year, the TCA initiated an investigation to probe allegations that Apple may have engaged in resale price maintenance for its branded products and/or coordinated buy-back prices in the second-hand market. In May, the TCA announced an expansion of this investigation. The broadened scope specifically includes concerns that competitively sensitive data provided to the Fintegre system by companies operating in the buy-back market and by Apple’s resellers may have restricted competition, potentially under Apple’s coordination. This expanded probe will be conducted alongside the initial investigation.
• Raw milk sector under scrutiny:[10] The TCA has launched an investigation of undertakings operating in the markets of raw milk purchase, milk feed sale, and the production and sale of packaged milk and dairy products, as well as the Association of Packaged Milk and Dairy Products Manufacturers, on the grounds that they allegedly violated competition through price fixing, market sharing, and exchange of competitively sensitive information.
• MDF and particleboard sector face competition probe: Çamsan, Kastamonu Entegre and Kronospan, which operate in the MDF and particleboard sector, are under investigation for alleged collusion in raw material procurement processes.
• Investigation into information exchange in the seed sector:[11]  The companies Corteva, KWS, Limagrain, May-Agro, Monsanto, Polen Tohumculuk, and Sygnenta, operating in the field of seeds for field crops, are under investigation for allegedly violating competition through the exchange of competitively sensitive information.

Stay tuned for our next issue of Quick Read, where we will continue to bring you the latest in competition law developments in Türkiye.

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