Key Decisions of the Turkish Competition Board in 2025–2026

October 27, 2026 · Mosturoğlu & Çopuroğlu

Since late 2025, the Turkish Competition Board (the “Board”) has rendered notable decisions, both in terms of the size of fines and the types of infringement it focuses on. Agreements in labour markets, indirect information exchanges through suppliers or dealers, and the preservation of digital evidence during dawn raids have been the key themes of this period. In this article, we summarise the main decisions that undertakings should take into account in their compliance programmes.

1. Labour Markets: No-Poach Agreements and Wage Information Exchange

Pharmaceutical sector decision

In its decision no. 25-34/810-474 of 11.09.2025 (reasoned decision published in April 2026), the Board found, in an investigation into 30 pharmaceutical companies, that 17 companies had infringed Article 4 of Law No. 4054 and imposed fines totalling approximately TRY 244.8 million. In the decision:

• Agreements between competitors not to hire each other’s employees were likened to customer or market allocation cartels and treated as restrictions by object; proof of effects on the market was therefore not required.
• Forward-looking information on salary increases shared by email between HR executives was also treated as a restriction by object.
• Non-solicitation clauses in commercial agreements or due diligence processes were assessed separately as to whether they were directly related to the main transaction, necessary and proportionate in scope, duration and personnel; some clauses were found acceptable on this basis.
• The acquirer was held liable for the past infringements of the acquired company. This means that labour practices must also be included in legal due diligence in acquisitions.

Exchange of wage information alone

In the Ankara Ready-Mixed Concrete decision (25-19/457-215), the Board held that the exchange of information on employee wages between competitors infringes Article 4 of the Law on its own, even in the absence of any other agreement.

Settlement in the banking sector

The investigation into Türkiye Garanti Bankası A.Ş. concerning labour market practices ended in settlement by decision no. 26-19/601-237; the bank accepted an administrative fine of TRY 1,547,608,979.25.

The Board’s determination in this area continues. In August 2026, an investigation was opened into 37 undertakings in the automotive supply industry and two industry organisations on allegations of no-poach agreements and wage information exchange (26-29/831-M). These investigations are based on the Guidelines on Competition Infringements in Labour Markets adopted by the Board on 21.11.2024.

2. Indirect Information Exchange: Hub-and-Spoke Cartels

In its decision no. 26-11/343-130 of 02.04.2026, the Board assessed an indirect information exchange in the small household appliances sector between Teknosa, Vatan Bilgisayar and Media Markt through the supplier Fakir Elektrikli Ev Aletleri. Although there was no direct contact between the competitors, the transmission of competitively sensitive information through a common supplier was found to constitute a hub-and-spoke cartel, and Media Markt was fined TRY 330,322,816.48.

A similar approach was taken in the tyre sector investigation concluded in June 2026. In the investigation, which covered allegations of price coordination, exchange of competitively sensitive information, resale price maintenance, territorial and customer restrictions on dealers and labour market conduct, fines totalling TRY 3,633,935,171 were imposed, of which TRY 497,091,986 related to seven undertakings that used the settlement procedure. The Board also introduced measures to prevent indirect information exchange through dealers, requiring dealer price announcements to be made through individual, password-protected portals and in coded form rather than through bulk or verbal notices.

3. Bid Rigging

The investigation in the MDF and particleboard sector, concerning collusion with competitors in wood product sales tenders held by the General Directorate of Forestry, was completed in October 2026. Six undertakings used the settlement procedure and agreed to pay fines totalling approximately TRY 860 million. Yıldız Entegre Ağaç Sanayi ve Ticaret A.Ş., which did not settle, was fined TRY 469,894,576.63 by decision of 15.10.2026, bringing the total fines in the investigation to approximately TRY 1.33 billion.

4. Dawn Raids and Digital Evidence

Reasoned decisions published in the first half of 2026 show that the Board’s practice regarding digital evidence during on-site inspections has become stricter:

• Deleting WhatsApp messages during an inspection was treated as obstruction, even in an inspection at a distributor (Duru Pazarlama, 25-43/1059-606).
• Deleted messages can be detected through forensic review and sanctioned (Coca-Cola, 25-43/1058-605).
• A manager’s mobile device located outside the workplace may also be requested (Erkal, 25-34/800-470).
• Passively failing to hand over a requested device may also constitute obstruction (Provision, 25-41/998-575).
• Leaving a WhatsApp group including competitors during an inspection may be examined (SELTAŞ, 25-34/799-469).
• Obstruction was also found against an undertaking that continued to serve the Turkish market after closing its Turkish office, with daily fines to apply until it invites the Authority to inspect (Spotify, 25-26/634-392).

5. Digital Markets: Commitments and Interim Measures

The Board is increasingly using commitments and interim measures in digital markets and exclusionary conduct cases. During this period, commitments were accepted allowing Meta’s Threads to be used independently of Instagram and limiting data combination, and an interim measure was ordered regarding the restriction of WhatsApp users to Meta AI. Concerns about self-preferencing and data use by Sahibinden.com were resolved through commitments (25-49/1208-683). Commitments limiting content and talent exclusivity by streaming platforms were also accepted.

On 07.04.2026, the Board also launched a sector inquiry into the AI value chain, access to data and computing power, and relationships between big tech companies and AI developers.

Conclusion

The decisions of this period clearly reveal the Board’s priorities: agreements in labour markets are now treated as seriously as cartels, information exchanges through suppliers or dealers are considered infringements even without direct contact between competitors, and failure to preserve digital evidence during dawn raids has serious consequences. The widespread use of the settlement procedure is also notable.

We recommend that undertakings review their HR departments’ communications with competitors, recruitment practices, information flows with suppliers and dealers and internal dawn raid procedures (in particular policies on mobile devices and messaging apps), and update their competition law compliance training to cover these topics.