Google’s Turkish ‘Local Search’ Rollercoaster: A Second Breach of Commitments
August 4, 2025
More than four years on, Google is still dealing with the requirements set out in the Turkish Competition Authority (“TCA”)’s Local Search Decision1. This ongoing process has resulted in a complicated history of deadline extensions, multiple design revisions, and additional fines. While there was a brief phase during which Google appeared to have achieved full compliance, a recent statement from the TCA revealed that the company continues to face challenges in meeting all of its obligations, as it tries to balance regulatory demands with its business interests and offerings to users.
This article provides a unified story on Google’s prolonged journey regarding the Local Search Decision, highlighting key milestones, ongoing adjustments to meet the requirements of the TCA, and the most recent turn of events that prompted the fresh enforcement measure. The recent development shows that TCA continues to monitor digital markets to ensure that undertakings continue to implement their commitments within the boundaries set by the TCA.
The Local Search Decision
In its Local Search Decision, the TCA found that Google held a dominant position in the general search services market in Türkiye and abused this dominance by favoring its own local search (Local Unit) and accommodation price comparison services (or Google Hotel Ads, “GHA”) on its general search results page. According to the TCA, this preferential treatment disadvantaged rival local search sites and impeded their access to the Local Unit, thereby violating Article 6 of Competition Law No. 4054 on the Protection of Competition.
The TCA reached this conclusion by finding that Google had abused its dominant position by systematically favoring its own services, both the 'Local Unit' for local search and 'GHA' for accommodation price comparison. The TCA determined that Google placed these services at the very top of its search results page in a large, visually enhanced format, which gave them an unfair advantage over the standard text links of competitors. Furthermore, the TCA noted that Google had actively blocked competitors from its Local Unit and dismissed the company's defense of using a fair 'quality test,' concluding that such a test was inherently unbalanced. The authority also pointed out that the GHA panel was displayed at the top without undergoing any such test at all. Ultimately, these practices were found to have hindered rivals and distorted competition in the relevant markets, i.e. local search services and accommodation price comparison services market as defined by the TCA.
The TCA imposed an administrative fine on Google at the amount of TRY 296.084.899 (around 33,3 million USD based on the average exchange rate of 2021) and ordered it to:
- Within six months from the notification of the reasoned decision, ensure that rival local search and accommodation price comparison services are not disadvantaged compared to Google's own services on the general search results page.
- Submit periodic reports to the Turkish Competition Authority (TCA) annually for five years from the implementation of the first compliance measure.
Google received the decision on 16.02.2022, setting the initial compliance deadline on 16.08.2022.
The Submission of the Commitments and the Non-Compliance Decision
Following the notification of the detailed Local Search Decision, it is evident from the Non-Compliance Decision2 that Google repeatedly requested extra time to formulate and introduce its compliance solutions. At first, on 08.08.2022, the Board granted a two-month extension. Subsequently, in response to further requests from Google, the Board approved a one-month extension on 06.10.2022 and then issued an additional one-month extension on 10.11.2022.
On 15.12.2022, the Board evaluated the measures proposed by Google:
- For the local search services market, the Board accepted Google’s "Local Selection Showcase" as a temporary solution until the launch of new designs, expected in the first quarter of 2024. In line with this, Google was given a six-month extension—until 19.06.2023—to present new, concrete design proposals through a formal commitment letter. Additionally, the Board required a progress report to be submitted by 19.03.2023.
- Regarding the accommodation price comparison services market, the Board concluded that Google’s initial remedy proposal—to remove the sticky format from the “Overview,” “Prices,” “Reviews,” “Location,” and “Photos” tabs in the Hotel Information Panel on mobile interfaces—was sufficient to satisfy the requirements. According to the proposal, these tabs would be replaced with "refinement chips" that do not redirect users to Google’s hotel pages but instead trigger a new search within the general Google search results page. Additionally, the Board found that Google’s second remedy proposal—to remove hotel advertisements from the Hotel Information Panel on both mobile and desktop platforms—could be monitored further within the additional time requested by Google for modifications to the local search services design. The Board noted that, if deemed necessary, this second remedy proposal could be reconsidered or revised based on ongoing observations and further developments.
By framing the approach as a “temporary solution” the TCA signaled that the solution for local search obligations was approved primarily to grant Google additional time, rather than as confirmation of full compliance with the original requirements. This detail is significant, as Google later argued that the TCA’s acceptance of this measure signified full compliance with the obligations for local search services.
In June 2023, Google presented a draft commitment letter outlining new and specific design proposals for the Local Unit. After engaging in discussions with the TCA, Google formally submitted its final commitments on 19.06.2023, and also requested an extension in case the commitments were not approved.
On 22.06.2023, the Board acknowledged that although these new designs had been presented, they could still be subject to changes following testing and feedback. As a result, a conclusive evaluation could not yet be made. The Board allowed Google until 19.08.2023 to notify the TCA of the timeline for submitting finalized designs, which were expected to be implemented by 29.03.2024.
On 19.08.2023, following Google’s submission, the Board approved a new schedule: Google was to provide its finalized commitments—including comprehensive design details, scheduled for implementation by 29.03.2024—to the TCA by 26.01.2024. During February 2024, Google and the TCA would discuss any questions or feedback. The aim was to present these commitments to the Board by the end of February 2024, with the finalized designs to be put into effect no later than 29.03.2024. Notably, this updated timeline extended the original deadline established by the Local Search Decision by nearly a year and a half.
Final Version of the Commitments and the Board’s Response
On 21.03.2024, the Board reviewed Google’s commitments submitted on 26.01.2024 and authorized their implementation, subject to a three-month monitoring period. At the end of this timeframe, the Board would evaluate the collected data to determine whether the competitive issues identified in the Local Search Decision had been adequately addressed. The Board also stated that if Google’s measures were deemed inadequate, a daily administrative fine of 0.05% of Google’s turnover would be imposed until satisfactory solutions were put in place.
On 19.04.2024, Google notified the TCA that it had discontinued the interim "Local Selection Showcase" measure and, as of 09.04.2024, had begun implementing the commitments detailed in its January 2024 submission. In addition, Google rolled out the new local search designs to all users in Türkiye starting the week of 15.04.2024. It is, however, worth noting that these measures were implemented after the initially agreed deadline of 29.03.2024.
Google also requested written confirmation from the TCA acknowledging its compliance with the obligations set out in the Board's March 2024 decision. However, the Board noted that Google's commitments had not been extended to cover hotel-related searches in local search services.
According to Google’s final commitment letter dated 26.01.2024, with the new design, clicks on maps and local business results would no longer redirect users to other Google services, which Google argued would address its previous competitive advantage in local search. However, the TCA found that for hotel-related searches, users were still redirected to other Google pages when clicking on hotel results or maps. Therefore, according to the TCA, Google did not ensure that clicks on Local Units would not redirect users to a separate Google service, and thus did not eliminate the competitive advantages previously held by its local search services.
On 19.04.2024, the Board emphasized to Google that its duty to provide equal treatment for competing local search services on the general search results page also extended to hotel searches. The Board asked Google to clarify why the commitments were not applied to hotel-related queries.
Google’s Arguments Against Non-Compliance
In its response dated 29.04.2024, Google maintained that there was no obligation to alter the presentation of free hotel search results. The company argued that the Local Search Decision considered local search services and accommodation price comparison services as distinct categories, each to be addressed separately. Google also pointed out that the Board had previously acknowledged Google’s compliance regarding hotel advertisements and asserted that the interim “Local Selection Showcase” was not intended to be extended to free hotel results, with the new commitments serving as its replacement.
Additionally, Google emphasized that throughout the compliance process, there were no questions or requests from the Board about whether the new local search designs should apply to free hotel search results. They stressed that it had been made clear the updated designs targeted local search results specifically, and did not encompass free hotel results. In summary, Google’s position was that hotel searches fell outside the local search services covered by the decision, and therefore, their commitments were not required to address them.
Board’s Counterarguments and Final Verdict
The Board rejected Google’s arguments, clarifying that the Local Search Decision established two separate relevant product markets: local search services and accommodation price comparison services, with hotel searches within specific areas classified as local search services. The Board noted that Google’s Local Unit covers searches for hotels, restaurants, and other local businesses, providing users with details like location, contact information, reviews, and prices. As a result, searches for hotels in a particular location were clearly within the scope of local search services, and the Board’s obligations applied equally to these.
The Board further distinguished between the two services: accommodation price comparison services, such as those offered through GHA, focus on price comparisons for a single hotel, while local search services address initial searches where users evaluate different venues. The commitments accepted in December 2022 applied only to the accommodation price comparison service, not to hotel queries within local search services.
Therefore, the Board concluded that Google’s commitments for local search services should also extend to hotel searches. By not including hotel queries, Google failed to fully comply with its obligations, leading the Board to impose a daily administrative fine of 0.05% of Google’s turnover until the necessary remedies were implemented.
The Compliance Decision3
The core issue in the decision centered on the fact that, although Google had introduced a range of changes, its updated designs did not address hotel-related searches. Key obligations—such as establishing a dedicated free unit for hotel results, modifying click interactions on the search results page, and eliminating redirections to Google services like Google Maps for hotel queries—remained outstanding.
The Compliance decision reevaluates Google’s compliance in light of new developments. In this detailed review, the Board analyzed the correspondence and evidence provided by Google concerning the rollout of its updated local search designs. The decision indicates that, in a more recent filing, Google demonstrated that it had expanded its remedies to include hotel queries.
Before this latest decision, both reports from the Competition Board’s rapporteurs and Google’s own communications dated 16.05.2024 and 22.05.2024 confirmed that Google had started to implement the previously missing measures on both desktop and mobile platforms. Google indicated that it had introduced a dedicated free unit for hotel-related local search results, adjusted the click behavior so that a click on a hotel query now directs users to a specialized search result viewer (rather than another Google service), and removed the feature that previously redirected users to Google Maps when clicking on a map result.
The Board’s assessment, including a review of search queries such as “Hotels in Antalya,” verified that Google had properly implemented the previously absent changes. Comparisons of the new design across desktop and mobile platforms revealed that clicking on hotel-related elements no longer redirected users to Google Maps or any other separate Google service. Instead, these clicks now seamlessly opened an integrated search results viewer. Additionally, the introduction of the new “Local Sites” chip and a dedicated section provided users with a more unified and enhanced display of free hotel search results, making the experience for hotel queries consistent with that of other local search categories.
In its thorough evaluation, the Board emphasized again that the obligations set out in the Local Search Decision clearly encompassed hotel queries, not just standard local searches. The Board reiterated that Google was expected to ensure that its local search results, in all segments including hotels, did not unfairly disadvantage competitors.
Based on the new evidence, the Board found that Google’s updated design included the required dedicated free unit for hotel listings, revised the user interaction flow to eliminate inappropriate redirections, and offered a refined interface that fulfilled the Board’s initial criteria.
As a result, the Compliance Decision determined that the daily administrative fine of 0.05% of Google’s revenue—imposed since 15.04.2024 and intended to remain in effect until Google brought its services into compliance—could end as of 21.05.2024. In total, this amounted to a fine equal to 1.85% of Google’s 2023 Turkish turnover.
Latest fine and Google’s attempts to reintroduce
Just as the saga surrounding Google’s compliance with the Local Search Decision appeared to reach a resolution, the TCA once again intervened. In a new announcement dated 10 July 2025, the TCA revealed that its ongoing monitoring had identified a new breach of commitment by Google.
The TCA determined that Google had, during the ongoing compliance review, introduced new “Business Ads” (paid sponsored advertisement) designs that mirrored the previously problematic local search features investigated in the original case. These new advertisements were found to possess the same essential nature and function as the original local search design, once again placing Google’s own services at a competitive advantage over rival local search and accommodation price comparison services.
The Board’s decision4 established that Google’s new “Business Ads” design constituted a breach of its obligation not to disadvantage competitors on the general search results page within six months of the original reasoned decision. Consequently, the Board imposed a new administrative fine on Google, amounting to 0.05% of Google’s 2024 gross revenue for each day of non-compliance, totaling 355,143,671.89 TRY around 10,8 million USD based on the average exchange rate of 2024). The announcement does not hint how long did the non-compliance continued for.
This latest fine demonstrates the TCA’s ongoing commitment to enforcing competition rules and its willingness to impose substantial penalties on digital gatekeepers that continue to undermine previous remedial measures.
Conclusion: Google’s Long Road to Compliance – Lessons from the Turkish Case
The Google-TCA saga in Türkiye highlights the complexities regulators face when overseeing digital platforms in rapidly evolving markets, as well as the important role played by the companies subject to regulation. Over several years and through multiple Board decisions, it has become clear that compliance is not a one-time requirement; obligations must be continuously maintained, adapted, and effectively implemented with every new iteration or feature. This case demonstrates that competition authorities are adopting increasingly sophisticated approaches to monitoring and are prepared for long-term engagement to ensure that commitments are carefully and consistently upheld.
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