E-Commerce Scale Thresholds

With its 2022 amendment, Law No. 6563 classified marketplaces and sellers as medium, large and very large according to net transaction volume and number of transactions. Obligations and restrictions increase with scale. This tiered structure aims to keep a balance between platforms with high market power and smaller players.

Scale-Based Obligations

• Licence: Marketplaces and sellers exceeding certain thresholds must obtain an e-commerce licence and pay a licence fee.
• Data portability and access: For sellers above a certain scale, data portability and restrictions on access between their own e-commerce environments.
• Advertising and discount budgets: Advertising spending and discount budgets such as promotions, rewards, points and coupons of large and very large marketplaces are capped relative to net transaction volume.
• Transport and postal services: Very large marketplaces may not carry out goods transport and postal services other than for sales on their own sites.
• Listings and sales: Very large marketplaces publishing listings for goods or services may not allow sales contracts in the same environment.
• Payment services: Very large marketplaces may offer certain payment services only through licensed institutions.

These obligations apply in addition to the general restrictions on marketplaces.

Annual Update of Thresholds

The monetary thresholds set in the Law in 2022 are updated every year, under the Law’s additional articles, at the rate of annual change in e-commerce volume and announced by the Ministry of Trade. For example, the 2026 update increased the thresholds by approximately 48 percent. Figures in 2022 sources are therefore no longer current.

Exemption

Sellers and marketplaces earning more than half of their total sales revenue from non-e-commerce sales are exempt from a significant part of the scale-based obligations other than ETBİS registration. This ratio must be reassessed every year.

In Practice

At the start of each year, companies should compare the previous year’s net transaction volume with the current thresholds announced by the Ministry, determine their scale category and, if a licence is required, not miss the March application window.