The Turkish Competition Authority’s Fintech Report’s Effects on the Payments Ecosystem

Part X: The Google Investigation

On 22.08.2025, the Turkish Competition Authority (the “Authority”) announced [1] that it had decided to launch an investigation (the “Investigation”) into the economic undertaking comprised of Alphabet Inc., Google Ireland Limited, Google LLC, Google International LLC, and Google Reklamcılık ve Pazarlama Ltd. Şti. (collectively, “Google”).

The rapid growth of the digital economy has created complex market structures that require the reinterpretation of traditional competition law principles. The most prominent elements of this new structure are platforms like mobile operating systems (Android, iOS) and their associated app stores (Google Play, App Store). These platforms act as critical gateways or gatekeepers between users and app developers. Their establishment of monopoly-like dominance within their own ecosystems creates potential risks of vertical integration and self-preferencing, which are significant concerns from a competition law perspective.

In this context, the Authority’s announcement stated that the Investigation focuses on the allegation that Google violated Article 6 of the Law on the Protection of Competition No. 4054 (the “Law”). The alleged violation stems from Google’s requirement that app developers who wish to distribute their applications on the Play Store must use Google Play Billing, the payment infrastructure developed for in-app purchases. Furthermore, the Authority alleges that Google prevented developers from informing their users about alternative payment channels.

This situation shows a direct parallel with the investigation launched against Apple on almost identical grounds. These simultaneous and similar investigations indicate that the Authority is adopting a systematic approach to supervising the market power of digital platforms.

In this article, we will analyze the recent investigation into Google Play. We will argue that this is not an isolated case but rather the most recent reflection of the Authority’s consistent and strategic regulatory approach toward digital markets. This approach demonstrates parallels with:

- Previous investigations against Apple on similar grounds, such as not allowing alternative payment systems in the App Store and enforcing anti-steering provisions on developers [2].

- The Authority’s previous work, such as its Fintech Sector Inquiry Report [3] (the “Fintech Report”), published on 09.12.2021. The report was prepared to examine the current state of the fintech ecosystem in payment services and its effects on competition.

Furthermore, the resemblance of these cases to precedent-setting decisions and regulations under the Digital Markets Act (the “DMA”) in the European Union (the “EU”) suggests the formation of a global consensus among regulators.

The Competition Authority’s Broad Perspective on the Payments Ecosystem

The decisions made by the Turkish Competition Authority regarding digital platforms can be considered part of a long-term strategic approach that scrutinizes the payments ecosystem. The Authority has not limited its scrutiny of fintech issues to mobile app stores. For instance, in an investigation against global payment giants Visa and Mastercard, the Authority focused on allegations that these companies prevented payment institutions based in Turkey from offering services to merchants located abroad and excluded alternative payment solutions.

Simultaneously, the Authority has also taken steps to facilitate the entry of local actors into the market. In a 2017 decision, the barriers to payment institutions’ access to the “Bonus” platform were removed. This allowed payment institutions to play a more active role in providing POS services alongside banks, thereby improving competitive conditions in the market. This led to more affordable services, particularly for SMEs and consumers.

Moreover, the 2016 exemption decision for the Interbank Card Center to create a national card payment system with the “Türkiye’nin Ödeme Yöntemi” (“TROY”) brand is one of the most concrete examples of the Authority’s vision to support local payment solutions and create an environment that can compete with global systems.

When viewed collectively, all of the Authority’s work, investigations, and decisions show that the Google and Apple investigations are not isolated incidents. Instead, they are a continuation of a consistent strategy to promote competition within the digital payments ecosystem.

The Competition Authority’s Google Play Investigation: Rationale and Legal Analysis

The investigation launched against Google focuses specifically on its conduct in the payment services market, which is closely related to the dynamics of the digital market. The primary reason for the investigation is Google’s alleged requirement for app developers to use only the Google Play Billing system for in-app purchases. This requirement is alleged to have a market-foreclosing effect on other payment service providers. Furthermore, it was found that developers were prevented from informing their users about alternative and potentially more affordable payment channels outside the application.

These actions, known in competition literature as anti-steering provisions, are considered practices that restrict consumer choice. They are being evaluated under Article 6 of the Law, which governs the abuse of a dominant position. Article 6 prohibits an undertaking with a dominant position in the relevant market from using this power in a way that excludes competitors or harms consumers.

The preliminary investigation by the Authority found that there were serious and sufficient concerns that Google’s conduct violated this article. Consequently, the Competition Board officially decided to open a full investigation.

The investigation into Google is not an isolated case. The Competition Authority has previously launched investigations and imposed administrative fines on Google for abusing its dominant position in different market areas.

Statements from Authority Vice President Ferhat Topkaya also support this trend. Topkaya has noted that fines imposed on large technology companies are not, by themselves, a sufficient deterrent. Companies tend to pay the fines and continue the violation [4].

These statements indicate that the Authority is moving away from the traditional approach of simply imposing fines. Instead, it is adopting new methods, such as “behavioral and structural remedies,” to break this cycle. In this context, the Google Play investigation is not merely the prosecution of a specific violation but can also be seen as part of the Authority’s search for a lasting solution to chronic problems in digital markets. This approach demonstrates an effort to adapt to the complex structure of digital platforms.

Similar Case: The Apple Investigation

The Competition Authority’s investigation into Google Play is almost identical in its rationale to the earlier investigation launched against Apple. The Competition Board initiated an investigation against Apple for not allowing alternative payment systems in the App Store and for applying provisions that prohibit mobile app developers from directing users to different payment channels. The allegations in both cases focus on the platforms’ imposition of their own payment systems and their prevention of developers from using alternatives with lower commission rates.

For our analysis of the Authority’s Apple investigation, you can read our article titled, “The European Commission’s Apple Pay Decision and the Turkish Competition Authority’s Apple Investigation’s Impact on MobilePOS/TaptoPay/SoftPOS” at this link: https://medium.com/yüksel-attorneys-at-law/avrupa-komisyonunun-apple-pay-kararı-ve-rekabet-kurumunun-apple-soruşturmasının-4df2263cef5d

The Payment Systems and Steering Investigation against Apple, launched under the Mobile Ecosystems Sector Inquiry [5] with the exact same rationale as the Google investigation, was proactively initiated as a result of the Authority’s systematic examination of the structure of mobile ecosystems.

The fact that the investigation into Apple’s payment systems was triggered by findings from the Inquiry confirms that the Authority has adopted a new proactive, sector-based approach to digital markets. This is evidence that regulation is not limited to a complaint mechanism. The Authority is also proactively conducting in-depth analyses to identify potential violations.

The Ideological Underpinning of the Investigations: The Fintech Report

The Fintech Report, published on 09.12.2021, can be considered the strategic foundation for the Competition Authority’s actions regarding digital platforms in recent years. The report provided a comprehensive examination of the current state of the fintech ecosystem in Turkey, its competitive conditions, and the barriers it faces.

In the Fintech Report, the Authority addressed investigations opened by the European Commission and concluded that opening up Apple’s payment ecosystems to third-party service providers would be a healthier structure. The report also focused on how data and network effects shape competition in the financial services market. It noted that the vertical relationship created by fintech companies’ dependence on banking infrastructure to operate could lead to potential competition problems.

The Fintech Report forms the strategic basis for the Google and Apple payment systems investigations. The investigations launched by the Competition Authority after the report’s publication in December 2021 can be considered concrete applications of the “vertical integration” and “exclusionary acts” issues theoretically presented in the Fintech Report.

This is a strong argument that the Authority’s approach to digital markets is based on in-depth sector analysis and strategic foresight, not on random complaints. It shows that the Authority follows a road map and implements concrete interventions in problem areas it has identified.

The International Legal Landscape: European Union Practices

The investigations and developments in Turkey show a strong parallel with international legal trends. The EU has enacted the Digital Markets Act (DMA), which complements traditional competition law and adopts a pre-emptive regulatory approach. It has identified technology companies of a certain size, such as Alphabet (Google), Apple, and Meta, as “gatekeepers” and has imposed strict obligations on them.

The European Commission has launched investigations into Alphabet and Apple under the DMA for non-compliance. The investigation into Google includes allegations of anti-steering rules in Google Play and self-preferencing in Google Search. The Apple investigation focuses on anti-steering rules in the App Store and restrictions in the Safari browser. The allegations in these investigations are largely similar to the grounds for the Competition Authority’s investigations.

The most concrete evidence of this similarity is the €1.84 billion fine imposed by the EU on Apple for violating competition rules in the music streaming market. This fine was imposed because Apple prevented music platforms like Spotify from informing their customers about payment options outside the App Store.

The table below summarizes the key parallels and differences between the main investigations in Turkey and the EU.

Evaluation and Potential Outcomes

We would like to clarify that the launch of the Investigation by the Competition Authority should not be interpreted as a definitive finding that Google has violated the Law or will face a penalty under the Law.

If the Competition Authority determines that Google has violated the Law, it will likely mandate that Google offer alternative payment systems to app developers. This would increase competition in the market, creating a fairer environment for developers and potentially offering consumers access to lower-priced options.

In the event of a violation finding, we believe that the Authority may implement a daily fine that continues as long as the violation persists. The Authority Vice President’s finding that traditional fines are not a sufficient deterrent for tech giants with billions in revenue supports this. These companies might otherwise simply pay the fine and continue their anti-competitive behavior since their profit margins are higher. A daily fine, similar to the one previously imposed in the hotel queries investigation, would be a tool to overcome this risk.

A New Era in the Payments Ecosystem Under the Competition Authority’s Scrutiny

The Competition Authority’s investigations into Google Play and the Apple App Store demonstrate that Turkey is not merely a follower but a proactive and effective actor in protecting competition in the digital economy. These investigations are a concrete result of a proactive approach fueled by prior sector inquiries, such as the Authority’s Fintech Report.

It must be acknowledged that these developments serve as a critical warning for all undertakings operating in the fintech ecosystem.