One morning, inspectors from the Provincial Directorate of Commerce visit your workplace; they examine the label prices, purchase invoices, and recent price changes of several products on the shelves, and draw up a report. In the letter received a few weeks later, it is reported that the Unfair Price Assessment Board has imposed administrative monetary fines amounting to hundreds of thousands of liras on your business, separately for each product. Or, conversely: As a consumer, you think a price you see in a market is unfair and wonder where to apply.

In this article, we extensively address exorbitant price increases and stockpiling prohibitions; the current penalty amounts applied in 2026, the separate application of penalties “for each violation”, penalties that double upon repetition, the authority to close workplaces introduced in 2024, the criteria for individualizing the penalty, the right of defense, the Constitutional Court’s decisions dated 2023 and 2026, and the appeal process against the penalty, detailing them with legislation, official communiques, and judicial decisions.

1. Legal Basis and History of the Regulation

Prohibitions on exorbitant price increases and hoarding, and administrative fines to be applied in case of violation thereof, are regulated by the Law No. 6585 on the Regulation of Retail Trade, the Law No. 5326 on Misdemeanors, and the Regulation on the Unfair Price Evaluation Board, published in the Official Gazette dated 28.05.2020 and numbered 31138. The regulation has been amended several times in a short period:

The amounts related to the 2022 amendment are available in public sources and publications reporting on the Board’s practice; the full law number and effective date should be checked from the Official Gazette.

2. Prohibitions: Law No. 6585, Additional Article 1

The “(…)” sign in the paragraph indicates the place of the phrase “to make regulations” which was annulled by the Constitutional Court’s decision dated 01.06.2023 (see section 9). As reported in the sources, the Board consists of thirteen members, chaired by the Director General of Internal Trade; the authority to impose penalties rests with the Board according to Article 18/4 of Law No. 6585.

The prohibition covers not only retail sellers but also producers and suppliers. Since the Law covers the prices of services as well as goods, it is understood from the Ministry of Trade’s statements that penalties have been imposed in various sectors, such as food, fire safety equipment, and private school fees, under the Board’s implementation.

3. Concepts of Exorbitant Pricing and Hoarding

The Law does not define the concepts of “exorbitant price increase” and “hoarding.” The definition is found in Article 3 of the Regulation on the Unfair Price Evaluation Board. This definition was presented in an abridged form in the source report; its full version, as found in publicly available sources, is as follows:

From this definition, four elements that can be used in defense emerge:

• Period element: The increase must have occurred during extraordinary circumstances, disasters, economic fluctuations, or other emergencies.
• Product element: The good or service must be essential to meet the public’s basic needs such as nutrition, healthy living, and protection.
• Absence of just cause: The increase must not be based on a just cause such as an increase in input and other production costs.
• Excessiveness: The increase must be excessive and unfair.

Regarding hoarding, the Law defines the act in Additional Article 1/2: creating scarcity in the market, disrupting market balance and free competition, or preventing consumers from accessing goods. In practice, holding goods in storage without offering them for sale, restricting sales, or artificially reducing market supply are considered within this scope.

4. Penalty Amounts: Legal Range and 2026 Amounts

The text of the provision was also quoted verbatim in the Constitutional Court’s decision dated 26.02.2026, numbered E.2024/146, K.2026/50. The source report indicates that the same text also appeared in the Court of Jurisdictional Disputes’ decision dated 24.11.2025, numbered E.2025/500, K.2025/699.

Amounts applied in 2026

In accordance with the “Communiqué on Administrative Fines to be Applied in 2026 According to Article 18 of Law No. 6585 on the Regulation of Retail Trade”, the amounts increased by a revaluation rate of 25.49%, published in the Official Gazette dated 27.11.2025 and numbered 33090, and to be applied between 01.01.2026 – 31.12.2026 are as follows:

In the 2026 Communiqué, the annual total upper limits of penalties, determined according to enterprise size and stipulated in the seventh paragraph of Article 18 of Law No. 6585, have also been updated (for example, 36,123,551 TL for small-scale enterprises, 361,235,514 TL for medium-scale enterprises). Whether these total upper limits apply to the penalties in sub-paragraph (k) should also be checked from the current text of the Law.

5. Annual Update: Revaluation Mechanism

In accordance with this provision, the fixed lower and upper limits in Law No. 6585 are increased at the revaluation rate announced at the beginning of each calendar year. The rate for 2026 is 25.49%. The Ministry of Trade announces the updated amounts with a communiqué every year.

6. Penalty for Each Violation, Recurrence, and Workplace Closure

Separate penalty for each violation

Law no. 6585, Article 18/1-k, stipulates a penalty “for each violation”. Therefore, separate penalties can be imposed for violations detected in different product types or at different times. In an audit where ten products are identified, even if the penalty is imposed at the lowest limit, the total amount can be in the millions. For this reason, in the objection, it should be examined whether each item constitutes a separate “violation” and whether the same act has been divided into multiple penalties.

Recidivism: double within the same year

The same rule is reiterated in the sixth paragraph of Article 15 of the Regulation. Example of recidivism calculation:

Recidivism is limited to repetitions within the same calendar year; the count restarts in the new year. For recidivism, the existence, date, and notification of the previous penalty must be clearly shown in the file.

Workplace closure: three times for hoarding

This sanction, not included in the source report, comes into play only for hoarding (Additional Article 1/2) and on the condition that a penalty has been imposed at least three times within a calendar year. The authority to close is granted to the Ministry, not the Board, and the duration is up to six days. The legal remedy to be sought against the closure decision should be evaluated separately according to the nature of the decision; some sources state that an annulment lawsuit should be filed in the administrative court against these decisions.

7. Individualization of the Penalty

Since the Law prescribes a wide range of lower and upper limits, where the penalty will be placed within this range is the most debated issue in practice.

Law on Misdemeanors, Article 17/2, stipulates that when determining the amount of an administrative fine, the unfairness content of the misdemeanor committed, the fault of the perpetrator, and their economic situation shall be considered together. This general principle is regulated in more detail in the Regulation for the Board:

8. Audit, Defense and Board Decision

Audits are conducted by the Ministry of Trade, provincial directorates, and authorized administrations at the request of the Ministry; identified irregularities are discussed and decided upon by the Board. Sources indicate that Board decisions are made by an absolute majority at meetings attended by at least seven members.

Right to defense: 2021 amendment

In the original version of Article 11 of the Regulation, it was clearly stipulated that the enterprise would be given a period for defense of not less than ten days from the date of inspection, and that the Board could not issue an administrative monetary fine decision without receiving a defense. With the amendment published in the Official Gazette dated 05.02.2021 and numbered 31386, the article was modified as follows:

• From the date of inspection, a period for defense of not less than seven days may be given, and this period may be extended once for up to seven days.
• All documents supporting the defense must be attached to the defense submission.
• Failure to submit a defense within the given periods does not prevent the Board from issuing an administrative monetary fine decision.

The change from the phrase “is given” to “may be given” has been criticized in doctrine: Since the right to defense is linked to Article 36 of the Constitution and the right to a fair trial, making a decision in administrative sanctions of a punitive nature without taking a defense can be put forward as a reason for unlawfulness in an objection. For businesses, the safest way is to present a timely and detailed defense with their documents when a defense period is granted.

9. Constitutional Court Decisions

10. Appeal Path, Period, and Advance Payment

Competent court: criminal judgeship of peace

Since Law No. 6585 does not regulate a special appeal path against administrative monetary penalties imposed by the Board, the general provisions of the Law on Misdemeanors apply. Accordingly, an appeal against an administrative monetary penalty must be filed with the criminal judgeship of peace within fifteen days from the notification or promulgation of the decision (Law on Misdemeanors art. 27/1). If the fifteen-day period is missed, the penalty becomes final.

Early payment discount

In accordance with Article 17/6 of the Misdemeanor Law, provided that the right to appeal is reserved, if the administrative fine is paid within the period stipulated by law from the date of notification, three-quarters will be collected; meaning a 25% discount will be applied. This payment does not eliminate the right to apply to the magistrate’s criminal court. If the application is accepted, a refund of the paid amount can be requested.

Against the decision of the magistrate’s criminal court

An appeal can be made against the decision of the Penal Judgeship of Peace in accordance with Article 29 of the Misdemeanors Law. The decision and the appeal period must be followed according to current procedural provisions.

11. Defense Guide for Businesses

• Keep cost documents ready: Purchase invoices, supply contracts, documents showing increases in energy, logistics, rent and personnel expenses, and calculations demonstrating the impact of exchange rates are the basis of the “just cause” defense.
• Keep price-cost history: A table of previous period sales price, cost, and profit margin per product shows that the increase is proportionate to the cost increase.
• Question the elements of the definition: Is the product within the scope of basic necessity, was the increase made during an extraordinary or emergency period, is the margin truly excessive?
• Evaluate each violation separately: Check whether the same act has been split into multiple penalties, and whether each item constitutes a separate violation.
• Check the recidivism record: Examine whether the previous penalty was issued in the same calendar year, whether it became final, and whether it was notified.
• Do not miss the defense period: If a defense is requested, provide a detailed defense with supporting documents within the given period.
• Document stock movements: Against claims of hoarding, warehouse entries and exits, sales data, and supply delays must be documented.
• Monitor the period: When the penalty is notified, consider the fifteen-day objection period together with the early payment discount period.

12. Complaint Channels for Consumers

Consumers who suspect exorbitant pricing or hoarding can report to the Ministry of Trade through the following channels:

• Unfair Price Increase (HFA) complaint system: Complaints can be made via the Ministry’s HFA Notification application or e-Government, providing product, business, price, and address information.
• Alo 175 Consumer Advisory Line: Reports can be made by phone.
• Evidence: A photograph of the label or shelf price, a receipt or invoice, and date and time information facilitate the investigation of the complaint.

The complaint initiates an administrative investigation; however, for the refund of the excess amount paid by the consumer, consumer arbitration committees or consumer courts should be considered separately.

13. Why is it Important to Correctly Manage the Process in These Cases?

Exorbitant price and hoarding penalties can reach amounts exceeding a business’s annual profit due to being applied separately “for each violation”, doubling upon recurrence, and the possibility of business closure. Cost documents not submitted during the defense phase, missing the fifteen-day objection period, or applying to the wrong judicial authority leads to the finalization of the penalty.

• During the inspection and defense phase: systematic submission of cost and price data, questioning the elements of the definition,
• During the objection phase: individualization of the penalty, calculation for each violation and recurrence, timely submission of objections to the criminal judgeship of peace regarding the right of defense and the principle of legality,
• Strategic evaluation: the right choice between early payment discount and objection, monitoring the pending case at the Constitutional Court.

Regions we serve

2M Hukuk Law Office is located in Tuzla. In objection to administrative fines and during the audit processes of commercial enterprises, we follow cases in the criminal judgeships of peace at the Istanbul Anatolian Courthouse and in the courthouses of Gebze and Kocaeli. We work on cases for manufacturers, suppliers, and retail businesses on the Anatolian Side in Tuzla, Pendik, Kartal, Maltepe, Ataşehir, Kadıköy, Ümraniye, and Sancaktepe; on the European Side in Beylikdüzü, Esenyurt, and Başakşehir; and in Kocaeli, in Gebze, Darıca, Çayırova, Dilovası, and İzmit.

14. Frequently Asked Questions

What is the penalty for exorbitant pricing in 2026?

According to Article 18 of Law No. 6585, and pursuant to the Communiqué on administrative fines to be applied in 2026, an administrative fine of between 180,617 TL and 1,806,177 TL is imposed for each violation in cases of exorbitant price increases (Additional Article 1/1). The base amounts specified in the law text are between 100,000 TL and 1,000,000 TL; these amounts are increased annually by the revaluation rate.

What is the penalty for hoarding in 2026?

Administrative monetary penalties ranging from 1,806,177 TL to 21,674,130 TL will be applied in 2026 for each violation of activities that create scarcity in the market, disrupt market balance and free competition, or prevent consumers from accessing goods (Additional Article 1/2). The base amount in the legal text is between 1,000,000 TL and 12,000,000 TL.

Is the penalty applied separately for each product?

The law stipulates the penalty “for each violation.” Therefore, separate penalties may be applied for violations detected in different products or at different periods, and the total amount can quickly increase.

What happens if I receive a penalty again within the same year?

In case of a repeated violation within a calendar year, an administrative monetary penalty twice the amount of the previous penalty is applied for each repetition (Law No. 6585, Art. 18/5). For example, if the first penalty is 200,000 TL, the second violation within the same year will result in a 400,000 TL penalty, and the third in 800,000 TL.

Can my workplace be shut down?

Yes, in terms of stock-piling. According to the sentence added to the fifth paragraph of Article 18 of Law No. 6585 by Law No. 7511, the Ministry of Trade is authorized to shut down the workplaces of manufacturers, suppliers, and retail businesses for up to six days if they are subjected to administrative monetary penalties at least three times within a calendar year for acting in violation of Additional Article 1/2.

Where can one object to an exorbitant price penalty?

Since no special application procedure is regulated in Law No. 6585, the Misdemeanors Law applies. An application against the administrative fine decision must be made to the magistrate court within fifteen days from the notification of the decision (Misdemeanors Law Art. 27/1). Lawsuits filed in administrative courts are rejected on grounds of jurisdiction.

If I pay the penalty in advance, do I lose my right to object?

No. Pursuant to Article 17/6 of the Misdemeanors Law, provided that the right to apply for legal remedy is reserved, three-quarters of the administrative fine is collected if it is paid within the period stipulated by law. Discounted payment does not eliminate the right to apply to the magistrate court.

How do I prove that the price increase is justified?

Purchase invoices showing an increase in input costs, supply contracts, changes in energy, logistics, rent, and personnel expenses, the impact of exchange rates, and previous period price-cost tables should be presented. The definition in the regulation considers an increase that is not based on a justifiable reason, such as an increase in input and other production costs, as exorbitant.

Can a penalty be issued without providing a defense?

According to Article 11 of the Unfair Price Assessment Board Regulation, amended in 2021, a defense period of not less than seven days can be given from the date of the inspection, and this period can be extended once for up to seven days; failure to submit a defense within the given period does not prevent a penalty decision. Due to the connection of the right to defense with Article 36 of the Constitution, decisions made without taking a defense can be challenged in an appeal.

Where can I complain about exorbitant prices?

Consumers can submit a notification through the Ministry of Trade’s Unfair Price Increase (HFA) complaint system, via e-Devlet, or by calling the Alo 175 line. The notification should include product, business, price, and address information, and, if possible, a photo of the label or receipt.

Did the Constitutional Court annul these penalties?

The Constitutional Court, with its decision dated 01.06.2023, annulled the Board’s authority to “make regulations” regarding exorbitant prices and hoarding; the penal provisions were not annulled by this decision. However, the request for annulment concerning the penalty amounts amended by Law No. 7511 and the authority to close businesses continues to be examined, having been registered under a separate file with the Constitutional Court’s decision dated 26.02.2026.

15. Decisions and Conclusion Mentioned in the Article

As a result, exorbitant price increases and hoarding have been prohibited by Article 1 of Annex 1 to Law No. 6585 and made subject to severe administrative fines under Article 18/1-k. In 2026, for each violation, an exorbitant price fine of 180,617 TL – 1,806,177 TL, and for hoarding, 1,806,177 TL – 21,674,130 TL will be applied; in case of recurrence within the same calendar year, the penalty doubles, and the workplace of a business fined for hoarding at least three times a year may be closed for up to six days. The Board must individualize the fine amount with justification, considering the content of the injustice, repetition and number, benefit, harm, fault, and economic situation. The Board’s regulatory authority was annulled by the Constitutional Court in 2023, and the increased penalty amounts and workplace closure authority in 2024 are still under examination by the Constitutional Court. An appeal must be made to the magistrate criminal court within fifteen days from the notification of the penalty; it should be noted that the one-fourth discount applied to payments made on time does not waive the right to object.

This article is for general informational purposes only and does not constitute legal advice for specific cases. Since penalty amounts change annually, the Communiqué of the relevant year should be taken as a basis. The mentioned decisions are based on the texts in their published sources; especially those bearing the note “quoted from a secondary source,” should be confirmed from UYAP or official decision databases before being used in a petition or application.