Important Update in Turkish Merger Control

Significant amendments to the Merger Control Communiqué entered into force today (11.02.2026), increasing the relevant turnover thresholds for all notifiable mergers/acquisitions in Türkiye. The Amended Communiqué affects all notifiable mergers/acquisitions from today, including the filings which are already under the review of the Turkish Competition Authority.

Key changes are:

Turnover thresholds significantly increased: Individual local turnover thresholds have been increased to TRY 1 billion from TRY 250 million (to approx. to USD 25.3 million/EUR 22.4 million from approx. USD 6.3 million/EUR 5.6 million calculated based on FY25 avr. rates); while cumulative local turnover thresholds have been increased to TRY 3 billion from TRY 750 million (approx. to approx. USD 76 million/EUR 67.1 million from USD 19 million/EUR 16.7 million calculated based on FY25 avr. rates). Individual global turnover threshold has been increased to TRY 9 billion from TRY 3 billion (approx. to USD 228 million/EUR 201.3 million from approx. USD 76 million/EUR 67.1 million calculated based on FY25 avr. rates).

Revised Nexus for ‘Technology Undertaking’ Exception: Previously, acquisitions of technology undertakings (as defined in the Communiqué) should have been notified to the Authority when such undertakings (i) were active in the Turkish geographic market or (ii) had R&D activities in the Turkish geographic market or (iii) provided services to customers in Turkey. This position has now significantly changed: The amended provision mainly covers the transactions for Target technology undertakings which has establishment in Türkiye. Also, after the amendments, mergers/acquisitions involving technology undertakings will be notified if the Target’s turnover exceeds TRY 250 million (approx. USD 6.3 million/EUR 5.6 million calculated based on FY25 avr. rates) from Türkiye. Previously there was no local/global turnover applied to the technology undertakings.

Simplified information requirements for venture capital investment trusts and funds, risk capital companies and individual participation investors: The reflected change means that there will be less need for information from these entities regarding their activities at a global scale and their global turnovers.

The Scope of the Simplified Notification Form Has Been Extended: Simplified notification form will be submitted where affected/reportable markets exist for parties under certain market share thresholds. Previously, the full scope Notification Form should have been submitted to the Authority where affected/reportable markets existed, irrespective of the market shares of the parties.       

Filings which are already under review: ongoing merger or acquisition reviews concerning transactions that fall below the newly applicable thresholds or otherwise no longer satisfy the relevant conditions will be terminated by a decision of the Board.

These amendments mark a significant recalibration of Türkiye’s merger control framework and will have immediate implications for deal structuring and filing strategies. Please see our attached note for a detailed overview.