Turkish Competition Authority Launch Investigation into the Turkish Health Insurance and Healthcare Services Market

On April 6, 2026, the Turkish Competition Authority (Rekabet Kurumu) announced the commencement of a formal investigation into various entities operating within the health insurance sector, private healthcare institutions, and technical/operational support providers. This decision follows a preliminary investigation that uncovered alleged serious and sufficient findings of potential violations of Law No. 4054 on the Protection of Competition.

The investigation targets 19 specific undertakings, including major insurance providers and private medical groups. The core allegations centre on anti-competitive agreements to fix prices (premiums), market sharing, the exchange of sensitive commercial data, and the implementation of exclusionary contracts between insurers and healthcare providers.

Market Context and Structural Dynamics

The healthcare sector in Turkey is characterized by a complex network of organizational relationships involving various business models. A critical component of this network is the health insurance market, which the Competition Authority classifies as a two-sided market.

The operational flow of this market involves:

• Transaction Series: When a consumer uses a health insurance product, a series of transactions occur between the insurance company and the consumer, as well as between the insurance company and the contracted healthcare institution.
• Technological Integration: Information technology products and services are essential for managing these high-volume, serialized transactions.
• Interdependency: The market relies on the synergy between insurance companies, private healthcare providers, and technical support firms that facilitate operational processes.

Scope of Alleged Violations

The Competition Board's investigation was prompted by complaints and whistleblowing reports. The preliminary research focused on several alleged specific anti-competitive behaviours that may have compromised market integrity:

1. Horizontal Agreements Among Insurers

There may be allegations that insurance companies may have conspired to:

• Price Fixing: Collectively determining, increasing, or maintaining fixed premium prices.
• Market Allocation: Sharing customers, geographical regions, or specific insurance products to reduce competition.
• Information Sharing: Exchanging sensitive data, including pricing strategies, cost structures, and risk assessment data.

2. Vertical and Exclusionary Practices

The investigation may examine the relationship between insurers and service providers:

Exclusionary Contracts: The potential existence of agreements between insurance companies and health service providers designed to exclude competitors from the market.

Entities Under Investigation

Following the Board meeting on March 16, 2026, a formal investigation (Decision No. 26-10/298-M) was launched against the following 19 undertakings:

Procedural Conclusion

The formal investigation is the result of the Competition Board’s assessment that the evidence gathered during the preliminary phase is substantial enough to warrant a full inquiry into potential breaches of Law No. 4054. The opening of this investigation does not pre-determine a violation but signifies a rigorous legal process to ensure the protection of competition within the Turkish health insurance and healthcare services markets.