The Competition Board has published an amendment to Communiqué No. 2010/4 on Mergers and Acquisitions Subject to the Approval of the Competition Board, updating the turnover thresholds that trigger mandatory notification under Article 7 of Law No. 4054. The revision aligns the thresholds with the cumulative effects of inflation observed since the last update and recalibrates the perimeter of transactions requiring clearance.
Background
Under Article 7 of Law No. 4054 on the Protection of Competition, mergers and acquisitions that may result in a significant impediment to effective competition are subject to prior notification and clearance. Communiqué No. 2010/4 specifies the turnover-based thresholds and the procedural framework. The thresholds were last revised in 2022, and accumulated price-level adjustments have since rendered the previous figures conservative relative to current transaction values. The Authority initiated a public consultation in early 2026 before adopting the final amendment.
Threshold Revisions
The amended Article 7 of the Communiqué increases the domestic and worldwide turnover thresholds in proportion to the producer price index movements observed in the intervening period. Both the combined Turkish turnover threshold for the transaction parties and the individual Turkish turnover threshold required for at least one party have been revised upward. The technology undertaking carve-out, which disapplies the local turnover threshold for the target undertaking in qualifying digital-economy transactions, is retained without amendment, ensuring that fintech, marketplace, and software targets with Turkish nexus continue to be captured.
Filing fees, procedural deadlines, and the substantive assessment standards under Article 13 of the Communiqué remain unchanged. The amendment also revisits the transactional-value-based filing trigger applicable to certain sectors, clarifying the calculation methodology and the scope of "Turkish nexus" for the purposes of jurisdiction.
Transitional Period and Pending Notifications
The amendment enters into force on the date of publication in the Official Gazette. A transitional provision clarifies that notifications submitted before the entry into force will continue to be assessed under the previous thresholds. Transactions signed but not yet notified at that date may benefit from the revised thresholds, potentially removing the filing obligation altogether for borderline cases.
Practical Implications
Strategic buyers, private equity sponsors, and cross-border acquirers should reassess their transaction pipeline against the new thresholds. Deals previously assumed to be notifiable may now fall below the perimeter, while transactions involving technology targets remain subject to scrutiny regardless of local turnover. Sale-side advisers should update process letters and signing-to-closing timetables accordingly. Our office provides notification feasibility assessments and represents parties before the Competition Authority across the full life cycle of merger control proceedings.