Recent Amendments in Turkish Merger Regulation & Filing Thresholds

Turkish Competition Authority (“TCA”) has amended the Communiqué no 2010/4 Concerning the Mergers and Acquisitions Calling for the Authorization of the Competition Board and the Notification Form effective as of publishment and the amendments are published on Official Gazette on 11.02.2026.

First of all, please find below the amended turnover thresholds:

Please also find below a brief note on the amendments in general:

• Amendment to the definition of “Transaction Party” The definition of ‘transaction party,’ which appears to give rise to uncertainty in practice in certain cases, is further elaborated, particularly with respect to the party being acquired. The amendment clarifies that transaction parties are the economic entities comprising the merging undertakings in merger transactions and the acquiring undertakings in acquisition transactions; for the undertaking subject to the transaction, itself and the economic units it controls. This reflects the established approach of the TCA rather than a new concept.
• Increase in thresholds: Turnover thresholds specified for transactions subject to notification are updated in light of the changes in the various macroeconomic indicators. The single threshold, which is currently 250 million TL, is amended to 1 billion TL, while the Türkiye turnover threshold, currently at 750 million TL, is updated to 3 billion TL, and the global turnover threshold, currently at 3 billion TL, is updated to 9 billion TL.
• New era in the “Technology Undertaking Exemption”: The application of the technology undertaking exemption is limited to those tech companies “based in Türkiye,” and it is regulated that a single turnover threshold of 250 million TL will be sought in transactions involving undertakings of this nature.
• Coordination analysis for joint ventures: A new provision added to the Communiqué delineates the framework of the assessment to be conducted into the coordination risk between the main undertakings of the joint venture.
• Simplification in the Notification Form: The update also includes significant simplifications in the Notification Form. Some of the information currently requested from the parties is completely removed from the Notification Form. In case the total share of the parties in the affected markets is low (where the combined market share of the parties to the transaction is less than fifteen percent for horizontal relationships, or where the share of one of the parties to the transaction is less than twenty percent for vertical relationships), some of the questions which include detailed information on the market structure, demand/supply/import/export conditions as well as biggest customers/suppliers, associations of undertakings etc. will no longer be responded.
• Moreover, some convenience is introduced in filling the Notification Form for transactions executed by undertakings such as venture capital investment trusts, venture capital investment funds or venture capital firms. Except for the transaction party subject to transfer, for transaction parties that are venture capital investment partnerships, venture capital investment funds, venture capital companies, or individual participating investors, only the activity areas in Türkiye needs to be provided. For transaction parties of this nature, if it is declared that the global turnover threshold has been exceeded, it is sufficient to provide only the turnover figures for Türkiye.
• Ongoing transactions: An additional article introduced clarifies that the ongoing processes involving those transactions that do not meet the new turnover thresholds or other conditions required for notification will be terminated with a Board decision.