The New Penalty Regulation introduced significant structural changes to competition law, providing for separate administrative fines to be issued for each violation where an undertaking commits multiple violations within the scope of the same investigation. This regulation has brought the possibility of cumulatively exceeding the 10% turnover cap as a result of multiple violations occurring within the same case to the fore. While this change creates new areas of discussion regarding the administrative fines that undertakings may face, it also raises questions about compliance with the principles of legal certainty, predictability and proportionality.

In this issue of the BASEAK CORE Papers series, Of Counsel Reşit Gürpınar and Associate Naz Semercioğlu discuss the details of the newly introduced penalty regulation.

To download BASEAK CORE Papers No. 22 (only in Turkish), please follow this link.