Turkey’s Competition Board imposed TRY 11.46 billion in administrative fines during the first ten months of 2025, a sharp escalation that places competition compliance alongside tax, licensing and foreign-exchange exposure as a material risk for international investors. The enforcement drive reached sectors central to Turkey’s investment proposition, including food, construction, financial services, infrastructure, textiles and digital markets. Subsequent full-year data showed that fines reached approximately TRY 12.1 billion, confirming that the ten-month figure was not an isolated surge but part of a broader shift toward more intensive supervision.
Enforcement Expands Across the Economy
According to official data reported by Anadolu Agency and Hürriyet Daily News, the Turkish Competition Authority received 1,430 applications between January and October 2025 concerning restrictive practices, anticompetitive agreements and alleged abuses of dominance. The Competition Board issued 72 infringement-related decisions during the period. Twelve files were closed at the preliminary stage, while the remaining 60 resulted in sanctions, including cases resolved through settlement.
The sectoral distribution is significant for foreign investors. Food companies received TRY 4.7 billion in fines, while construction accounted for TRY 3.4 billion. Banking, capital markets, finance and insurance followed with approximately TRY 1.1 billion. Infrastructure services attracted TRY 658.9 million in penalties, and textile and apparel companies were fined TRY 402.3 million.
These figures show that the enforcement agenda extends well beyond conventional cartel cases. It reaches industries in which foreign capital frequently enters through acquisitions, distribution agreements, joint ventures, franchise networks, infrastructure contracts or local manufacturing operations.
The final figures in the Competition Authority’s 2025 Annual Report, published in March 2026, reinforce that conclusion. The Authority recorded 530 final decisions during the year, including 104 competition-infringement decisions and 416 merger and acquisition decisions. It conducted 1,509 on-site inspection assignments, approximately 50 percent more than in 2024, according to an analysis of the report by Esin Attorney Partnership.
Total fines for substantive competition violations reached approximately TRY 12.1 billion in 2025. That was about 61 percent above the TRY 7.5 billion recorded in 2024 and more than six times the TRY 1.9 billion imposed in 2023, based on figures in the European Commission’s 2025 Türkiye Report.
The comparison is nominal and must be interpreted in the context of Turkey’s high inflation. It nevertheless reflects a substantial increase in corporate exposure because competition fines are calculated by reference to company revenue rather than as fixed amounts.
A New Fining Framework Raises the Stakes
Turkey’s enforcement acceleration coincided with a major revision of the penalty methodology under Law No. 4054 on the Protection of Competition. A new Fining Regulation entered into force on December 27, 2024, replacing the framework used since 2009. The Competition Authority then adopted detailed implementation guidelines on February 13, 2025.
Under the revised approach, the Board considers the nature of the infringement, its actual or potential competitive harm and its duration when setting the basic fine. Aggravating considerations include repeat conduct, continuing an infringement after notification of an investigation and having a decisive role in the violation. Cooperation and other case-specific factors may support reductions.
The legal ceiling remains 10 percent of the undertaking’s annual gross revenue for each infringement. The guidelines also provide for personal fines against managers or employees found to have exercised a decisive influence over the conduct. Such individual sanctions can reach 5 percent of the fine imposed on the company.
KST Law, in its review of the Authority’s 2025 activity, noted that the Board had revived the use of sanctions against managers after a long period of limited application. For multinational groups, this changes the internal allocation of risk. Competition compliance can no longer be treated solely as a corporate legal issue. Country managers, sales directors, procurement executives and human-resources personnel may face individual scrutiny where they design or maintain restrictive practices.
The framework is especially relevant to foreign-owned subsidiaries because fines are based on gross revenue and the Turkish concept of an “undertaking” examines economic reality rather than corporate form alone. A group cannot assume that separate legal entities, minority positions or contractual operating arrangements will automatically isolate exposure.
Settlement and commitment procedures remain available and were used extensively in 2025. According to KST Law’s analysis, among 89 investigation files, 47 concluded through settlement and 11 through commitments. Those mechanisms can shorten proceedings or resolve identified concerns, but they require an early assessment of evidence, commercial consequences and potential admissions.
Digital Evidence and Labour Markets Become Front-Line Risks
The increase in on-site inspections makes operational readiness as important as the substantive rules. Competition Authority officials can examine company records, electronic communications and business-related data found on corporate devices. Deleting information after an inspection begins may be treated as obstruction even if employees act independently or the material is later recovered.
ACTECON reported that the Authority imposed fines equal to 0.5 percent of annual turnover in cases involving the deletion of WhatsApp messages during inspections. In one 2025 case involving Arzum, investigators found that employees had cleared chats or reinstalled WhatsApp after the inspection started. A separate November 2025 decision imposed a TRY 282.4 million obstruction fine after forensic analysis identified data deleted by a manager.
The judicial position is still developing. In January 2026, Turkey’s Council of State upheld the annulment of an obstruction fine in a case involving a personal mobile device because the Authority had not demonstrated concretely that the deleted messages constituted company data. The judgment does not remove inspection risk, but it highlights the need to distinguish business information from genuinely personal material and to document that distinction carefully.
For international investors, the practical response extends beyond a written competition manual. Turkish subsidiaries need a dawn-raid protocol, designated response personnel, rules for business communications on personal devices and immediate preservation instructions. Headquarters must also understand that a delay caused by waiting for foreign counsel or group approval may not stop inspectors from proceeding.
Labour-market conduct is another expanding area of exposure. The Authority increasingly examines no-poach arrangements, wage coordination and exchanges of employment information. Its 2025 report classified labour markets separately in merger statistics for the first time, while enforcement decisions placed human-resources practices alongside traditional product-market concerns.
This is particularly important in sectors with scarce engineers, software developers, technicians or sales professionals. Informal understandings between employers not to recruit one another’s personnel can create competition risk even when they appear operationally convenient. Due diligence should therefore cover HR communications and industry working groups, not only customer pricing and supplier contracts.
Merger Control Remains Active but Mostly Permissive
The Authority reviewed 305 transactions during the first ten months of 2025, comprising two mergers, 214 acquisitions, 76 joint ventures and 13 privatizations. It granted unconditional clearance to 280 transactions and conditional approval to seven.
The full-year total reached 416 decisions, the highest level in five years, according to the Authority’s annual report. Of those, 381 transactions received unconditional approval, ten were cleared subject to conditions and 25 were considered outside the notification regime. This means that most notified investments continued to clear without remedies, even as enforcement became more intensive.
That distinction matters. The TRY 12.1 billion penalty total should not be interpreted as evidence that Turkey has become closed to transactions. Rather, the system combines relatively high clearance rates with closer scrutiny of deals and post-entry commercial conduct. Information technology and platform services led the 2025 merger caseload with 84 files, followed by automotive and transportation, chemicals and mining, healthcare, and financial services.
In February 2026, the Competition Authority increased the principal notification thresholds to reflect changing macroeconomic conditions. The individual Turkish-turnover threshold rose from TRY 250 million to TRY 1 billion. The combined Turkish threshold increased from TRY 750 million to TRY 3 billion, while the relevant worldwide threshold rose from TRY 3 billion to TRY 9 billion.
The technology-undertaking exception was narrowed to technology companies based in Turkey, with a TRY 250 million threshold applying to transactions involving such businesses. This preserves particular scrutiny of domestic technology targets while reducing the number of smaller conventional transactions requiring notification.
Foreign acquirers must test the thresholds before signing and assess whether the target qualifies as a technology undertaking. The analysis should cover the turnover of all relevant parties, group relationships, joint control and whether a transaction creates a full-function joint venture. Completion before required clearance can itself produce sanctions.
Competition Policy and Turkey’s FDI Proposition
Turkey attracted $13.1 billion in FDI in 2025, an increase of 12.2 percent from the previous year, according to Central Bank data cited by the Presidential Investment Office. Wholesale and retail trade represented 32 percent of inflows, manufacturing 31 percent and information and communication 14 percent. These are also areas in which pricing, distribution, platform conduct and merger control can become prominent.
Effective competition enforcement can support FDI by limiting exclusionary behavior from incumbents and protecting access to customers, suppliers and infrastructure. The OECD’s 2025 Economic Survey of Türkiye argued that stronger product-market competition and lower barriers to domestic and international entry could improve business dynamism and productivity.
The OECD also found that Turkey retains comparatively significant administrative and regulatory barriers for new companies, while state-owned enterprises remain prominent in parts of the economy. This creates a dual challenge. Investors benefit when antitrust rules restrain private market power, but they also need predictable application of those rules and a level playing field in markets affected by licensing, public procurement or state participation.
The European Commission’s 2025 Türkiye Report similarly recorded the rapid rise in competition investigations while noting that Turkish courts upheld 65 percent of the 119 competition judgments concluded in 2024, down from 87 percent in 2023. That decline does not establish a general weakness in enforcement, but it underlines the importance of reasoned decisions, judicial review and procedural safeguards.
For investors, the relevant question is therefore not whether Turkey enforces competition law, but how enforcement interacts with sector regulation, incentives, government contracting and commercial execution.
What This Means for Foreign Investors
The enforcement figures make competition planning an entry requirement rather than a post-investment legal exercise. A foreign investor should begin with market-entry analysis that identifies concentrated markets, dominant suppliers, regulated distribution channels and relationships with trade associations or public bodies.
During incorporation and corporate structuring, responsibility for pricing, sales, procurement, HR and regulatory communications should be clearly allocated. Legal and tax compliance work should include competition controls for distributor agreements, resale restrictions, exclusivity, information exchange, tender participation and recruitment practices.
Acquisitions and joint ventures require early merger-threshold testing, substantive competition analysis and carefully sequenced closing conditions. Investors seeking government incentives must also examine whether exclusivity commitments, localization requirements or cooperation with other beneficiaries create competition concerns. Government-relations support is relevant where Competition Authority review overlaps with sector regulators, ministries, privatizations or public procurement.
Import-export operations require scrutiny of territorial restrictions, parallel trade, customs-facing distribution structures and communications with competing importers. Expo and trade-fair representation also needs safeguards because discussions with competitors at industry events can create evidentiary and substantive risk. Project management should translate the compliance framework into local training, document-retention controls and tested inspection procedures.
Turkey’s higher fines do not negate its investment case. They do, however, increase the cost of entering without a competition map, a defensible transaction structure and operational controls that work from the first day of business.