Facts
Under decisions of 18 July 2018 and 7 February 2019, the Turkish Competition Board investigated Alphabet Inc. and four Google companies, treated as one economic entity. Google launched Google Shopping in Türkiye in September 2016; the Shopping Unit, showing product ads with images at the top of the results page for product searches, also fed traffic to it. Comparison shopping sites such as Akakçe and Cimri drew much of their traffic from Google's organic results and ad service while competing with Google in that market. It was alleged that the Shopping Unit was not recognisable as advertising, that rival comparison sites were kept out of it, and that Google's algorithms pushed rivals down in organic results.
Question
The Board examined whether Google, dominant in general search, abused that position under Article 6 of Law No. 4054 on the Protection of Competition by showing the Shopping Unit above rival sites, in a large space, with product images and without making clear that it was advertising; by giving rival comparison sites no direct access to it even for payment; and by placing it at the top even for searches naming a rival site. It also tested the allegation that Google had deliberately pushed rivals down in organic rankings, using the comparison sites' index counts, organic traffic and average rankings, and Akakçe's and Cimri's positions for the queries that brought them the most traffic.
Decision
By decision 20-10/119-69 of 13 February 2020 the Board unanimously found Google dominant in general search and online comparison shopping and held that it had breached Article 6 by disadvantaging rival comparison shopping services. The Google entities were fined TRY 98,354,027.39, jointly and severally. Within three months of service Google had to ensure rivals were not disadvantaged against its own service on the results page, make the Shopping Unit header non-clickable, remove ambiguity about the space being advertising and stop prioritising it for searches naming rival brands, and report annually for five years. The data did not bear out deliberate demotion in organic rankings. Annulled in 2026 over the fine calculation, the decision was re-adopted with the same findings, remedies and amount.
Why it matters
The decision subjects the design of a search results page, and the space a company reserves for its own service, to competition-law scrutiny. The Board based the infringement on the Shopping Unit's position and display advantage, while the claim that ranking algorithms had been used to push rivals down could not be confirmed by the ranking data. Faced with the remedies, Google withdrew Shopping ads from its search pages in Türkiye. The infringement finding was upheld at first instance and on appeal; as the Board reads the 2026 annulment, it concerned only which fining regulation should set the rate. The 2026 re-decision can itself be challenged in court.
Related stages
Google's action against the decision was dismissed by the Ankara 12th Administrative Court on 29 March 2021 (E. 2020/1522, K. 2021/626), and its appeal by the 8th Administrative Chamber of the Ankara Regional Administrative Court on 4 November 2021 (E. 2021/869, K. 2021/1557). On 30 December 2025 the 13th Chamber of the Council of State (Danıştay) reversed that appeal ruling (E. 2022/257, K. 2025/4223). On 16 April 2026 the Regional Court set aside the first-instance judgment and annulled the Board's decision (E. 2026/550, K. 2026/768). As the Board reads it, the sole ground was that the fine rate had to be reset by comparing the repealed 2009 fining regulation with the new regulation published on 27 December 2024 and applying the more favourable one, without worsening Google's position; no illegality on the merits was found. By decision 26-19/566-212 of 21 May 2026 the Board unanimously re-adopted the dominance and infringement findings and the obligations. Because the new regulation, applied to 2024 turnover, would have produced TRY 1,522,044,308.11, it held the repealed regulation more favourable and re-imposed TRY 98,354,027.39. That decision, published on 5 September 2026, can be challenged before the Ankara administrative courts within 60 days of service; whether Google has done so could not be established. On 29 July 2020 Google announced that it would remove Shopping ads from its search pages in Türkiye from 10 August 2020. By decision 20-39/543-243 of 27 August 2020 the Board found Google's compliance proposals of 28 July 2020, which centred on letting rival comparison sites appear in the Shopping Unit through ads, not fully sufficient to meet its obligations, and held that the infringement had ended because Google had shut the Shopping Unit as of 10 August 2020. On 4 March 2022 the Ankara 18th Administrative Court unanimously dismissed Google's action against the part of that decision finding the equal-treatment obligation unmet (E. 2021/373, K. 2022/473); the later course of that case could not be verified. The decisions on Google's local search and ad tech services are covered in separate entries.