Merger Control in Türkiye in 2025: Key Trends and a Comparative Assessment (2020–2025)

Transaction Numbers and Transaction Values

The TCA’s Merger and Acquisition Overview Report for 2025 provides an overview of merger control activity in Türkiye during a year in which both transaction numbers and aggregate deal values increased compared to the immediately preceding period. Based on decisions finalized within the 2025 calendar year, the Report situates these developments within the framework of Article 7 of Law No. 4054 on the Protection of Competition and the secondary legislation governing notification thresholds and review procedures[3].

In total, the TCA reviewed 416 merger and acquisition transactions in 2025. This represents the highest number of cases examined since the Overview Reports began to be published in 2013 and corresponds to an increase of more than one third compared to 2024. Most of these transactions were cleared under the Phase I review procedure, reflecting the operation of the notification system and the fact that a large proportion of notified transactions did not raise competition concerns requiring in-depth assessment. A limited number of transactions were classified as falling outside the scope of merger control due to the absence of a lasting change of control, while privatization transactions continued to be assessed under their specific procedural framework.

From a value perspective, 2025 represents the highest level recorded within the reporting series. Excluding privatizations, transactions involving Turkish-incorporated target companies reached an aggregate value of approximately TRY 466 billion, corresponding to USD 11.8 billion. When privatization transactions are included, the total value of transactions concerning Turkish-incorporated targets amounts to approximately TRY 574 billion, or USD 14.5 billion.

The Report also distinguishes between transactions involving Turkish-incorporated targets and those in which the target companies are established abroad but remain subject to notification due to the turnover thresholds being met. In 2025, 226 transactions fell into this latter category. The aggregate value of these foreign-target transactions exceeded TRY 18.8 trillion, or USD 478.3 billion. Although these transactions do not involve assets located in Türkiye, their inclusion illustrates the extraterritorial application of Turkish merger control rules[4] and places the Authority’s practice within the broader context of global merger control enforcement.

Distribution of Investors by Country of Origin

An examination of the origin of transaction parties indicates that foreign-to-foreign transactions accounted for a substantial share of aggregate transaction value. This outcome is largely attributable to high-value global mergers notified in Türkiye. At the same time, transactions involving both Turkish and foreign undertakings increased in value among Turkey-related transactions, suggesting a continued level of foreign investor interest in Turkish assets.

Foreign investors participated in 55 transactions involving Turkish-incorporated target companies in 2025. The total announced investment value for these transactions amounted to approximately TRY 277 billion, or USD 7 billion. This figure represents close to half of the total transaction value associated with Turkish targets during the year, including privatizations. In comparative terms, this level reflects an increase relative to previous years. When measured in US dollar terms, foreign investment in Turkish targets reached its second-highest level since 2013, indicating an increase in merger and acquisition-based investment beyond purely nominal effects linked to exchange rate movements.

The geographical distribution of foreign investors reflects a diversified investor base. Germany ranked first by number of transactions involving Turkish targets, followed by France and a group of other jurisdictions, including the United States, the United Arab Emirates, China, and several European countries. This distribution indicates that foreign investment interest in Turkish companies is spread across multiple jurisdictions.

Distribution of Transaction Numbers and Values by Economic Activity

Sectoral data provide further insight into the structure of merger and acquisition activity in 2025. In terms of transaction count, the most active sector involving Turkish targets was computer programming, consultancy, and related activities. Energy-related transactions, particularly in electricity generation, transmission, and distribution, also accounted for a significant number of transactions and a substantial share of transaction value. From a value perspective, financial intermediation and related activities accounted for the highest aggregate transaction value among Turkey-related deals, driven by a limited number of transactions.

When transactions are grouped by broader economic activity categories, wholesale and retail trade, including the repair of motor vehicles and motorcycles, generated the highest aggregate transaction value involving Turkish targets. These activities were followed by financial and insurance services and manufacturing. This distribution suggests that merger activity in 2025 was not concentrated in a single sector, but rather spread across a range of economic activities, including both established industries and technology-oriented segments.

Privatizations

Privatization transactions continued to form part of the merger control workload in 2025, although their relative weight was lower than in certain earlier years. During the year, the Authority reviewed 19 privatization transactions, with a combined value of approximately TRY 108 billion, or USD 2.7 billion. Most of this value was associated with transactions in the electricity sector, where large-scale asset transfers accounted for the highest individual transaction values. Although privatizations represented less than one fifth of the total value of transactions involving Turkish-incorporated targets, they remained relevant from both an economic and a competition law perspective.

Administrative Procedures, Final Investigations, and Conditionally Cleared Transactions

From a procedural standpoint, the Report provides information on review timelines and enforcement practice. In 2025, transactions notified to the Authority were, on average, resolved approximately 10 days after the final notification date, calculated from the date on which all additional information and document requests addressed by the Authority are deemed complete.

During 2025, two transactions were referred to an in-depth Phase II investigation. One of these transactions was cleared subject to commitments offered by the notifying parties, while the other remained under review at the time of publication. The limited number of Phase II cases is consistent with the Authority’s established approach of reserving in-depth investigations for transactions that raise competition concerns warranting further scrutiny.

Review timelines may therefore be considered not only as a procedural metric, but also as an indicator of the Authority’s capacity to manage its workload. The gradual reduction in average review periods observed between 2022 and 2024, followed by a further decrease in 2025, suggests that administrative processes and internal coordination mechanisms have adapted to increased notification volumes.

The increasing share of foreign-to-foreign transactions within the merger control workload also warrants contextual consideration. Data from 2024 and 2025 show that transactions not involving a Turkish-incorporated target continue to account for a substantial portion of both transaction numbers and aggregate transaction value. This development may be explained, in part, by the combined effect of the technology undertaking exception[5] and the real erosion of notification thresholds over time. Transactions involving globally active undertakings in technology-driven and digital markets are more likely to fall within the scope of Turkish merger control, even where the direct nexus to Türkiye is limited. As a result, foreign-to-foreign transactions are increasingly captured by the notification regime, reinforcing the extraterritorial dimension of the Turkish merger control system and raising questions regarding the scope and proportionality of notification obligations in global transactions.

Comparative Perspective: Developments Between 2020 and 2025

When assessed over the 2020–2025 period, merger control activity in Türkiye exhibits a clear trajectory rather than isolated year-to-year fluctuations. In terms of overall caseload, the Turkish Competition Authority reviewed 220 merger and acquisition transactions in 2020, followed by a significant increase to 309 transactions in 2021. This was succeeded by a contraction in 2022, when the number of reviewed transactions declined to 245, and reached a further low point in 2023, with 217 transactions. The trend reversed thereafter, with a recovery to 311 transactions in 2024, before reaching 416 transactions in 2025, representing the highest annual caseload recorded since the Overview Reports began to be published in 2013.

Transaction values involving Turkish-incorporated target companies display a broadly comparable pattern. Excluding privatizations, aggregate deal values increased from approximately TRY 29.2 billion in 2020 to TRY 42.6 billion in 2021 and TRY 72.2 billion in 2022. A more pronounced upward trend emerged from 2023 onwards, with transaction values rising to TRY 162.6 billion in 2023 and TRY 191.9 billion in 2024. Against this background, the 2025 figure of approximately TRY 466.1 billion represents a sharp increase compared to previous years. The same trend is observable in US dollar terms, indicating that the expansion in 2025 cannot be attributed solely to nominal exchange-rate effects.

A similar development can be observed in the number of transactions involving Turkish-incorporated targets. Following a decline between 2020 and 2022, the number of Turkey-target transactions increased to 94 in 2023, 131 in 2024, and 162 in 2025, excluding privatizations. Throughout the same period, transactions involving foreign-incorporated targets continued to account for a substantial share of the overall caseload, explaining why total filing volumes remained relatively high even in years when Turkey-target transactions were fewer.

Sectoral patterns over the 2020–2025 period point to continuity rather than structural change. Computer programming, consultancy and related activities, together with electricity generation, transmission and distribution, consistently ranked among the most active sectors in terms of transaction count for Turkish-incorporated targets. What distinguishes 2025 is not a shift in frequently notified sectors, but rather the concentration of transaction value in specific activity areas, most notably financial intermediation, combined with a broader increase in high-value Turkey-target transactions.

Average review periods declined from approximately 18 days in 2020 to 11 days in 2021, stabilized at 15 days in 2022, and continued to decrease to 13 days in 2023, 12 days in 2024, and approximately 10 days in 2025. The reported average review periods do not capture the time elapsed since the initial filing but rather refer to the period calculated from the date on which all additional information and document requests addressed by the Authority are deemed complete.

Phase II investigations remained limited throughout the period, with three cases in 2022, one in 2023, and two cases each in 2024 and 2025. This pattern indicates that the significant increase in transaction numbers and values—particularly in 2025—was not accompanied by a proportional rise in cases requiring in-depth investigation.

Conclusion

The 2025 Merger and Acquisition Overview Report shows that merger control in Türkiye has reached a new level in terms of both notification volume and cross-border relevance. Record-high transaction numbers and values, together with the sustained prominence of foreign-target transactions, confirm that Turkish merger control has become an increasingly important consideration in global deal planning. For globally structured transactions, particularly in technology-driven markets, Turkish merger control analysis must be integrated at an early stage of transaction planning.

[1] Attorney Gülce Korkmaz is the external competition law consultant of Baş | Kaymaz Law Firm. After completing her master’s degree at Bilkent University, she is currently pursuing her doctoral studies in the field of competition law at the Faculty of Law of Lüneburg Leuphana University (Germany) as a PhD researcher with the scholarship of the Joachim Herz Foundation.

[2] Please see here for the full Report (in Turkish).

[3] For an overview of the applicable merger control framework in Türkiye, including notification thresholds, procedural rules, sanctions, and the technology undertakings exception, see the “Merger Control in Türkiye” series here (Parts 1–6).

[4] For an information note we have prepared on the Turkish Competition Board’s decision dated 13 July 2023 and numbered 23-31/586-197, which constitutes an example of the extraterritorial application of Turkish competition law under the effects doctrine, see The Turkish Competition Board’s Clearance of the “RED SEA” Joint Venture: Extraterritorial Competitive Analysis.
[5] For further information on the exception for technology undertakings under Turkish merger control regime, please see: https://www.baskaymaz.av.tr/merger-control-in-turkiye-5-technology-undertakings-exception/

For our recent information notes on Competition Board decisions in which the technology undertaking exception was applied, see:
(i) The information note on Apple/Pixelmator acquisition decision: https://www.baskaymaz.av.tr/the-turkish-competition-boards-apple-pixelmator-decision-a-killer-acquisition/

(ii) the Take-Two/Gearbox acquisition decision: https://www.baskaymaz.av.tr/turkish-competition-board-unconditionally-cleared-take-twos-acquisition-of-gearbox/

(iii) The information note on Google/Galileo acquisition decision: https://www.baskaymaz.av.tr/the-turkish-competition-boards-decision-on-the-google-galileo-acquisition-what-doesnt-kill-you-makes-you-stronger-or-does-it/

As Baş | Kaymaz Law Firm, we provide comprehensive competition law, advice and representation services to both national and multinational companies with our specialized and experienced lawyers.

If you have any questions on this topic or any matter related to Turkish competition law, you may contact us via [email protected].