Vircon Legal advises on competition law matters under the Turkish Competition Authority (Rekabet Kurumu) framework, with particular focus on the issues that arise in technology, fintech, and digital-platform sectors. Our practice covers merger control notifications, anticompetitive-agreement analysis, abuse-of-dominance defense, and the day-to-day commercial-agreement review that growth-stage companies need.
For M&A transactions, we handle pre-closing merger control notifications to the Competition Authority: including the turnover threshold analysis that determines whether a filing is required, drafting of Form 1 and Form 2 notifications, and management of the review period through to clearance. We also advise on whether a transaction qualifies for the simplified procedure or requires full review.
For commercial-agreement reviews, we screen distribution agreements, exclusivity arrangements, non-compete covenants, and platform-merchant terms against the Block Exemption Communiqué frameworks and Article 4 of the Competition Law (Law No. 4054).
Our Competition Law practice includes, but is not limited to, the following:
- Merger control notifications to the Competition Authority
- Turnover-threshold analysis and filing strategy
- Distribution-agreement and vertical-restraint review
- Block Exemption Communiqué compliance
- Abuse-of-dominance defense and investigations
- Cartel-investigation defense and leniency applications
- Digital-platform competition issues
- Non-compete clause review and enforceability analysis
- Internal competition-compliance programs and training
- Competition-related litigation and administrative appeals
How we help
We cover the full spectrum of competition law: from day-to-day compliance to merger-control filings and Competition Authority investigations. We help technology companies grow aggressively while staying on the right side of the rules.
- Merger-control notifications and clearance before the Turkish Competition Authority
- Compliance programmes, distribution and pricing reviews
- Dawn-raid preparation and investigation defence
- Vertical agreements, exclusivity and platform-conduct analysis
- Tailored opinions on competitive risk
Related practice areas
This connects with our M&A, Corporate Law and IT Law practices.
The three questions Turkish competition law asks a growing company
- Does this deal need clearance? Acquisitions that bring a lasting change of control must be notified when the turnover thresholds of Communiqué No. 2010/4 (as amended by Communiqué No. 2026/2) are met; for a target that is a technology undertaking established in Türkiye, its threshold is TRY 250 million instead of TRY 1 billion (Turkey’s New Merger-Control Thresholds).
- Do our agreements restrict competition? Agreements, concerted practices and association decisions that restrict competition are prohibited (Law No. 4054, Art. 4), unless an exemption applies; distribution, exclusivity and pricing clauses are where most companies meet this rule.
- Are we dominant? Conduct that is ordinary for a small player, such as exclusivity, tying or refusing access, can become an abuse once a company holds a dominant position (Art. 6), which matters for platforms early.
Questions clients ask us
Does our acquisition need Competition Board approval?
It does if the 2026 thresholds are met: combined Turkish turnover above TRY 3 billion with at least two parties above TRY 1 billion each, or the target’s Turkish turnover above TRY 1 billion with another party’s worldwide turnover above TRY 9 billion; a Turkish technology target’s threshold is TRY 250 million. Turnover is counted at group level, and a notifiable deal cannot close before clearance (M&A).
Can we set the price our resellers charge?
Fixing a minimum or fixed resale price is treated as a hardcore restriction, including in e-commerce, and falls outside the block exemption. Maximum or recommended prices are permissible only while they stay genuinely non-binding; enforcing them through threats, delisting or incentives turns them into a violation.
What happens in a dawn raid?
Authority case handlers can carry out on-site inspections at the company’s premises, examine books, records and digital data, take copies and ask for oral explanations (Law No. 4054, Art. 15). Obstructing or delaying an inspection is itself fined, so the company needs a short protocol: who receives the team, which counsel is called, and how IT access is handled.
How large can fines be, and are there ways to reduce them?
Fines for anti-competitive agreements and abuse of dominance can reach ten per cent of the company’s annual turnover (Art. 16). Cartel participants who report under the leniency regime can obtain immunity or a reduction, and since Law No. 7246 (2020) the Board can close investigations through commitments or settlement, which can limit both the fine and the time spent.
Is it risky to use pricing software or share data with competitors?
It can be. Sharing competitively sensitive information such as future prices, capacity or strategy can be an infringement without any explicit agreement, and pricing algorithms that react to competitors’ prices raise the same question in a new form. Contract terms with the vendor on data segregation and explainability help (When the Algorithm Fixes the Price).
Reading
- AI Washing: When “AI-Powered” Becomes a Legal Claim in Advertising and Competition
- When Startups Become Buyers: A Legal Guide to Acquiring Companies
Sources. Law No. 4054 on the Protection of Competition. Statute links open the official consolidated Turkish texts on mevzuat.gov.tr.
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