The third quarter of 2026 was marked by significant regulatory and enforcement activity from the Turkish Competition Authority ("TCA"), with pharmaceutical sector policy taking centre stage following the Pharmaceutical Sector Inquiry Preliminary Report and a subsequent stakeholder workshop. The TCA also launched a landmark labour market investigation into 37 undertakings and two associations in the automotive supply sector over alleged no-poach agreements. On the procedural front, obstruction fines were imposed on Allianz Sigorta and Temu for interference with on-site inspections. The merger control practice delivered notable conditional clearances, including the Paramount Skydance/Warner Bros. Discovery and A101/CarrefourSA transactions.
This bulletin surveys the principal developments of Q3 2026, examining regulatory reforms, notable enforcement decisions, and emerging priorities.
Regulatory & Policy Developments
TCA Pharmaceutical Sector Inquiry: Preliminary Report and Stakeholder Workshop
Following a sector inquiry launched in December 2021, the TCA published its Pharmaceutical Sector Inquiry Preliminary Report on 10 August 2026. The report summarises the TCA's enforcement activities over the past ten years and assesses the competitive structure across the full supply chain under three headings: (i) Production, (ii) market entry, and (iii) distribution.
At the production stage, the report identifies practices such as misuse of divisional patents, product hopping, and strategic regulatory interventions as potential atypical infringement tools. On patent settlements, the TCA screened approximately 350 patent cases since 2015, found no pay-for-delay agreements in Türkiye to date, but designates this a priority monitoring area.
At the market entry stage, the report examines how patent processes, licensing, and reimbursement mechanisms affect competition, warning that regulatory compliance alone does not guarantee competition law compliance.
At the distribution stage, the report identifies structural concentration concerns in wholesale markets, recommends replacing the sole authorised distributor model with a shared exclusivity framework of up to five distributors per province, and raises competition law risks arising from information exchange in the Public Institution Discount framework.
The report proposes certain recommendations that do not require dismantling the existing administrative, legal, economic, or institutional framework. The public consultation period offers an important opportunity for industry stakeholders to engage with the TCA on the final recommendations1.
Following publication of the Preliminary Report, the TCA held a stakeholder workshop on 21 September 2026, bringing together public institutions, industry representatives, academics, and other stakeholders to evaluate the preliminary findings. At the distribution stage, the report makes clear that individual exemptions for exclusivity arrangements will not be available on the basis of hypothetical efficiency arguments; namely, consumer benefits must be demonstrated concretely and tied to the exclusivity in question. The report further emphasises that compliance with sectoral regulation does not equate to compliance with competition law where the conduct forms part of a broader strategy to foreclose competitors.
In the public sector panel, government representatives emphasised the strategic importance of domestic pharmaceutical manufacturing, confirmed that the legal responsibility for the Public Institution Discount (a mandatory discount mechanism applicable to pharmaceutical sales to public healthcare institutions) lies with suppliers whilst cautioning about practical enforcement challenges, and noted that secondary patents lacking novelty can in practice be registered and that litigation may be used as a delaying tool against generic entry.
In the private sector panel, industry stakeholders stressed that the balance between incentivising innovation and ensuring access to medicines must account for the right to health, and called for a predictable regulatory framework on pricing and reimbursement rather than an approach focused solely on cost reduction.
Footnote
1. The Preliminary Report has also prompted considerable interest across the legal and industry community, with various organisations hosting events to discuss its findings and implications. See, e.g., BASEAK, "Coffee Break Webinar: Pharmaceutical Sector Inquiry Preliminary Report" (September 2026), available at https://www.baseak.com/en/facts-about-baseak/news/2026/september/coffee-break-webinar-pharmaceutical-sector-inquiry-preliminary-report.
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