Compliance Quarterly Türkiye

Global

Navigating global trade uncertainty

The current economic environment, defined by evolving trade regulations and shifting alliances, requires businesses to immediately evaluate and adapt their operational strategies. Recent tariffs and geopolitical tensions are transforming the international trade landscape, exposing companies across all sectors to significant legal and strategic risks.

Read the full publication, "Navigating international trade and tariffs."

FSR guidelines: Clarity missing in action

Despite high anticipation, the European Commission’s draft guidelines on the Foreign Subsidies Regulation (FSR) offer limited practical clarity, largely rephrasing the regulation itself and leaving businesses uncertain about how the EC will exercise its broad enforcement discretion.

Read the full publication, "Draft FSR guidelines – the art of saying much while clarifying little?"

European Commission’s new cartel decision

On June 2, 2025, the European Commission imposed €329 million in fines for coordinated market behavior in online food delivery, marking its first enforcement action addressing labor market harms and cartel conduct linked to a minority shareholding.

Read the full publication, "Key takeaways: The EC’s online food delivery cartel decision."

Global antitrust and competition trends: 2025 hot topics

Shifts in regulation, technology and politics are redefining how antitrust and competition enforcement impacts businesses.

Read the full publication, "Global antitrust and competition trends."

Türkiye

The Communiqué on the Group Exemption for Specialization Agreements has been updated

The Communiqué on the Group Exemption for Specialization Agreements (Communiqué) entered into force upon its publication in the Official Gazette, dated June 26, 2025 and numbered 32938. With this new Communiqué, The Communiqué on the Group Exemption for Specialization Agreements, dated July 26, 2013 and numbered 2013/3, was repealed.

The Communiqué redefines the principles under which specialization agreements between undertakings concerning production or distribution activities may benefit from a group exemption from the prohibition set forth in Article 4 of the Law No. 4054 on the Protection of Competition.

The main changes introduced under the new Communiqué include a reduction in the total market share threshold required to qualify for the group exemption from 25 percent to 20 percent. Besides these changes, where the products subject to specialization are used as essential intermediate goods in the production of products sold by the parties in another market, the 20 percent market share threshold must be satisfied separately in both the relevant market for the specialization products and the downstream market in which these products are used.

Additionally, under the previous regulation, only data from the preceding calendar year was taken into account. Under the new Communiqué, however, if such data does not reflect the parties’ position in the market, the average of the last three calendar years may be used for market share calculations.

Furthermore, under the previous Communiqué, if the parties to an agreement benefiting from the block exemption exceeded a 30 percent market share, the exemption would remain valid for one additional year, whereas if their market share remained between 25 percent and 30 percent, the exemption would continue to apply for two years. It has now been simplified. For agreements where the market share initially does not exceed 20 percent, the exemption will remain valid for two years from the date the threshold is exceeded, even if the market share later surpasses this limit.

A two-year transition period has also been granted for specialization agreements currently benefiting from the 2013/3 Communiqué but not meeting the new requirements, during which the restrictions of Article 4 of the Law No. 4054 will not apply, provided that the agreements are brought into compliance with the provisions of the Communiqué within the two-year period.