For many businesses in Turkey, an online marketplace account is no longer merely an additional sales channel.
A seller may generate 70%, 80% or even almost all of its revenue through platforms such as Trendyol, Amazon, Hepsiburada, N11 or similar marketplaces. Hundreds of products may be listed, thousands of customer reviews accumulated and significant advertising expenditure invested into the account.
Then, suddenly, the seller receives a message:
“Your seller account has been suspended.”
or:
“Your store has been permanently closed due to a policy violation.”
Products disappear from search results, new orders stop, existing funds may be withheld and months or years of marketplace reputation effectively become inaccessible overnight.
This raises an important legal question:
Can an online marketplace simply terminate a seller account whenever it wants?
Under current Turkish law, the answer is generally no.
Following the amendments to Law No. 6563 on the Regulation of Electronic Commerce and the adoption of the Regulation on Electronic Commerce Intermediary Service Providers and Electronic Commerce Service Providers, marketplace operators are subject to specific rules governing the restriction, suspension and termination of seller services.
An unjustified seller suspension can therefore be more than a simple contractual dispute. It may constitute an unfair commercial practice, a breach of contract and, depending on the circumstances, give rise to claims for reinstatement, payment of withheld funds and compensation.
1. Turkish Law Specifically Regulates Marketplace–Seller Relationships
The legal relationship between a marketplace and a seller is now expressly recognised by Turkish electronic-commerce legislation.
A marketplace operator that enables third-party sellers to offer goods or services is generally classified as an Electronic Commerce Intermediary Service Provider — “ETAHS.”
The business selling through that marketplace is generally classified as an Electronic Commerce Service Provider — “ETHS.”
The Ministry of Trade explains that the regulatory framework introduced after the 2022 amendments was specifically designed, among other objectives, to protect sellers against unfair practices by electronic marketplaces and to establish minimum requirements for marketplace intermediation agreements.
This is a significant development.
The legal position is no longer simply:
“You clicked ‘I agree’ to the seller agreement, therefore the marketplace can do whatever the contract says.”
Marketplace discretion is now restricted by mandatory electronic-commerce rules.
2. The Seller Agreement Must State When an Account Can Be Suspended
The starting point is the marketplace’s seller or intermediation agreement.
Article 15 of the applicable Regulation requires the agreement to specify, among other matters:
- the intermediary services provided to the seller;
- the circumstances in which those services may be restricted, suspended or terminated; and
- the procedures applicable to those measures.
This means that account suspension cannot properly operate as a completely undefined power.
A clause such as:
“The platform may terminate any seller account at any time for any reason at its sole discretion”
should not automatically be regarded as giving the platform unlimited freedom.
The suspension mechanism must be connected to identifiable criteria and must also comply with the mandatory statutory framework.
3. The Key Rule: Suspension Must Be Based on Objective Criteria
Article 17 of the Regulation contains one of the strongest protections available to marketplace sellers.
It provides that an electronic commerce intermediary service provider may not restrict, suspend or terminate its intermediary services except on the basis of the objective criteria contained in the intermediation agreement.
This is crucial.
The platform should therefore be capable of answering a simple question:
Which objective rule did the seller violate?
A notification merely stating:
- “policy violation”;
- “risk detected”;
- “associated seller account”;
- “unusual activity”;
- “seller quality issue”; or
- “violation of marketplace rules”
may not necessarily be sufficient if the platform cannot identify the concrete contractual criterion and factual conduct relied upon.
The legal analysis should therefore compare:
the alleged misconduct + the seller agreement + the evidence + the sanction imposed.
4. The Marketplace Must Normally Give the Seller an Opportunity to Explain
An even more important safeguard concerns the seller’s right to respond.
Where the marketplace believes that circumstances requiring restriction, suspension or termination exist, Article 17 generally requires it to:
clearly and understandably state its reasons, request an explanation from the seller and give the seller at least three business days to respond.
If the seller provides no response or if the explanation is considered insufficient, the marketplace may then impose the restriction.
The platform must notify its decision within the regulatory timeframe. Where an explanation has been submitted, the decision must generally be communicated within seven business days after receipt of that explanation.
Therefore, immediate permanent closure without any opportunity to respond may raise a serious compliance issue unless one of the statutory exceptions applies.
5. There Are Important Exceptions: Some Accounts Can Be Suspended Immediately
The three-business-day defence mechanism does not apply in every situation.
Under Article 17(7), intermediary services may be restricted, suspended or terminated immediately where the circumstances arise from legislation or involve matters such as:
- public order;
- situations in which delay creates serious risk;
- fraud;
- data breaches; or
- other cybersecurity risks.
Even in these circumstances, however, the reason for the restriction must be communicated to the seller without delay.
This distinction is essential.
Suppose an account appears to have been compromised by hackers and the seller’s bank account information is suddenly changed.
An immediate temporary suspension may be entirely justified.
The same analysis may apply where there is credible evidence of organised fraud.
But the existence of an “emergency exception” does not mean that a marketplace can permanently classify every ordinary contractual dispute as a fraud risk in order to avoid the procedural protections given to sellers.
The underlying facts remain important.
6. Unjustified Suspension May Constitute an “Unfair Commercial Practice”
Law No. 6563 goes even further.
Its Additional Article 1 establishes a general prohibition against unfair commercial practices in electronic commerce.
A marketplace practice is regarded as unfair where it significantly disrupts the commercial activities of the seller, reduces the seller’s ability to make reasonable commercial decisions or forces the seller into a commercial relationship it would not normally have accepted.
Certain practices are automatically regarded as unfair.
One particularly relevant example is where the marketplace:
restricts, suspends or terminates services without objective criteria being included in the intermediation agreement.
The legislation also specifically prohibits penalising a seller through ranking, restriction, suspension or termination because the seller applied to an administrative authority or judicial body.
This creates a potentially powerful protection.
For example, a marketplace should not retaliate against a seller because the seller:
- filed a lawsuit;
- commenced enforcement proceedings;
- complained to the Ministry of Trade; or
- challenged marketplace deductions before a competent authority.
Such retaliatory action may itself constitute an unfair commercial practice.
7. “The Seller Accepted the Contract” Is Not Always a Sufficient Defence
Marketplaces frequently defend suspension cases by relying on their seller agreements.
They may argue:
“The seller voluntarily accepted our rules.”
Contractual freedom is relevant, but it is not absolute.
Law No. 6563 expressly prohibits certain forms of marketplace conduct and the Regulation establishes mandatory procedural rules concerning suspensions.
The legislation also considers certain unilateral changes to seller agreements unfair, particularly retroactive or seller-adverse unilateral amendments.
Therefore, a marketplace cannot necessarily create unlimited powers for itself simply by inserting them into standard terms.
Contractual provisions must be interpreted together with mandatory legislation, the Turkish Code of Obligations and the principle of good faith.
8. Counterfeit Product Allegations Require Special Attention
One of the most common reasons for marketplace suspension is an allegation involving:
counterfeit or non-original products.
This area has a specific regulatory framework.
Where an intellectual or industrial property rights holder submits a compliant complaint, the marketplace may be required to remove the relevant product.
The Regulation requires a properly documented intellectual-property complaint and provides a corresponding objection mechanism for the seller.
A seller challenging the complaint may submit evidence such as:
- purchase invoices;
- distributor agreements;
- authorised-reseller certificates;
- supply-chain records; and
- documents tracing the product back to the intellectual-property rights holder or an authorised supplier.
Where it is clear from the seller’s evidence that the objection is justified, the marketplace must generally republish the product within 24 hours following receipt of the objection.
This creates an important practical strategy.
A seller accused of selling counterfeit products should not merely write:
“My products are original.”
It should establish the entire supply chain.
The stronger the documentary chain from manufacturer or authorised distributor to the seller, the stronger the challenge to the suspension.
9. Removing One Product and Closing the Entire Store Are Different Measures
Proportionality can also become relevant.
Suppose a seller has 3,000 product listings and one intellectual-property complaint is made concerning one listing.
The marketplace may have legal grounds to remove the disputed product.
That does not automatically answer the separate question of whether permanently closing the seller’s entire account is justified.
The contractual criteria, repeated violations, seriousness of the allegation and applicable marketplace policies must be examined.
A complete suspension that destroys a seller’s commercial activity may be considerably more difficult to justify where a narrower measure would adequately address the underlying problem.
10. “Associated Seller Account” Suspensions Can Be Challenged
Another frequently encountered problem involves platforms identifying supposedly related seller accounts.
The platform may conclude that two stores are linked because they have:
- the same IP address;
- the same physical address;
- related shareholders;
- common employees;
- the same computer;
- common bank details; or
- another technical connection.
The seller may then receive penalties or even account closure because another supposedly associated account previously violated marketplace rules.
Such cases require careful factual analysis.
For example, two independent companies may:
- operate from the same business centre;
- use the same accountant;
- have previously shared an employee;
- access the platform through the same office Wi-Fi; or
- belong to relatives without forming a single commercial operation.
Technical association does not necessarily establish that one company should be legally responsible for another seller’s misconduct.
The seller should therefore demand identification of the criterion used to establish the connection and submit corporate, accounting and technical evidence demonstrating the actual relationship.
11. Withholding Seller Money Is a Separate Legal Issue
Marketplace disputes often involve two separate measures:
closing the store, and
blocking payments already earned from completed sales.
These issues should not automatically be treated as the same thing.
The Regulation generally requires seller payments to be made within the prescribed framework and classifies certain delayed payments as unfair commercial practices. It does, however, recognise exceptions where payment is postponed or suspended for purposes such as preventing unlawful activities or complying with statutory obligations.
The existence of an account suspension therefore does not automatically mean that the marketplace has unlimited authority to retain all seller funds indefinitely.
A noteworthy 12 May 2026 decision of the Istanbul 16th Commercial Court of First Instance concerned a marketplace that had withheld nearly TRY 1 million of seller receivables. The court found that the platform had failed to establish the concrete risk allegedly justifying the payment hold and considered the approximately three-to-four-month retention period inconsistent with a reasonable suspension period under the contractual circumstances.
Although a first-instance judgment is not binding precedent in the manner of a Court of Cassation judgment, the case demonstrates an important practical principle:
a contractual right to hold payments does not necessarily mean that funds may be retained indefinitely without a concrete justification.
12. Can the Seller Demand Reopening of the Store?
Potentially, yes.
Where suspension was imposed contrary to the seller agreement or the mandatory electronic-commerce rules, the seller may seek judicial protection concerning the continuation of the contractual relationship.
However, obtaining immediate reinstatement before the main case is resolved is not automatic.
Under Article 389 of the Code of Civil Procedure, an interim injunction may be available where changes in the existing situation could make enforcement of the right significantly more difficult or impossible, or where delay could cause serious damage.
The seller must also establish its claim on an approximate proof standard for interim relief.
A recent case demonstrates the challenge.
In Istanbul Regional Court of Appeal, 18th Civil Chamber, E. 2026/730, K. 2026/574, dated 22 April 2026, a seller sought interim reopening of a marketplace account after the platform alleged the sale of non-original products. The seller argued that it had not been given the three-business-day explanation period required by Article 17 and claimed that closing the store endangered its entire business. The Regional Court nevertheless upheld the refusal of interim relief, concluding that the disputed issues required examination in the substantive proceedings.
The decision is significant for two reasons.
First, courts are now expressly examining marketplace suspensions through Article 17 of the Regulation.
Second, demonstrating economic dependence on the platform alone may not always be sufficient to secure immediate reinstatement.
The evidence supporting the unlawfulness of the suspension must be particularly strong.
13. What Evidence Should the Seller Preserve?
Evidence preservation should begin immediately after suspension.
The seller should download or record:
- the seller agreement applicable on the suspension date;
- historical versions of the agreement where possible;
- the exact suspension notification;
- violation-point records;
- marketplace support tickets;
- internal communication-system messages;
- e-mails;
- invoices;
- product sourcing documents;
- trademark licences;
- authorised-dealer certificates;
- sales statistics;
- seller ratings;
- customer reviews;
- marketplace advertising expenditure;
- monthly turnover;
- payout statements;
- withheld payment records; and
- evidence showing the commercial effect of the suspension.
Screenshots should ideally identify the date and relevant account.
If access to the platform may disappear completely, key evidence should be preserved before that happens.
14. Send a Formal Legal Notice
Where the internal appeal mechanism fails, the seller should consider sending a formal notice, commonly through KEP or a notary, depending on the circumstances.
The notice should not merely state:
“Please reopen our account.”
It should identify:
- the seller account;
- the date of suspension;
- the stated reason;
- the contractual provision allegedly relied upon;
- why the criterion has not been satisfied;
- any breach of Article 17;
- the evidence submitted by the seller;
- withheld receivables;
- the financial losses being generated; and
- the remedy demanded.
Where appropriate, the marketplace should be requested to:
reactivate the seller account, release accrued payments, preserve electronic records and provide the concrete factual and contractual basis of the restriction.
The notice can later become important evidence concerning default and damages.
15. A Complaint to the Ministry of Trade May Also Be Considered
The Ministry of Trade supervises the electronic-commerce regulatory framework and administrative sanctions apply to violations of Law No. 6563.
The Ministry specifically identifies the protection of marketplace sellers against unfair commercial practices as one of the objectives of the legislation.
Administrative penalties may apply to violations of the unfair commercial practice provisions. For 2026, administrative fine amounts under Article 12 of Law No. 6563 have been updated through the annual communiqué.
An administrative complaint and a private-law claim serve different purposes.
A Ministry investigation may result in administrative enforcement against the platform.
It does not necessarily compensate the seller for millions of lira in lost profits.
For compensation, the seller may still need to pursue private-law remedies.
16. Can the Seller Claim Compensation?
Yes, if the necessary legal conditions are established.
Article 112 of the Turkish Code of Obligations establishes the general principle that where a contractual obligation is not performed or is improperly performed, the debtor must compensate the resulting damage unless it proves that no fault can be attributed to it.
Where an unlawful suspension constitutes breach of the marketplace agreement, potential damages may include provable losses arising from that breach.
Possible claims may involve:
- withheld marketplace receivables;
- lost sales;
- wasted advertising expenditure;
- additional warehouse expenses;
- additional financing costs;
- losses relating to perishable or seasonal inventory;
- costs of moving sales to another platform; and
- other foreseeable commercial losses.
However, the seller must prove causation and amount.
17. Lost Profits Are Possible — But They Must Be Proven Properly
A seller may argue:
“My store normally made TRY 5 million in sales every month. The platform closed me for three months, so I lost TRY 15 million.”
That calculation is usually too simplistic.
Turnover is not the same as profit.
A proper damages analysis may need to deduct:
- cost of goods;
- marketplace commissions;
- shipping;
- advertising;
- returns;
- personnel expenses;
- taxes where relevant; and
- costs the seller did not incur because the sales never occurred.
Historical sales are nevertheless extremely important.
An established store with two years of consistent monthly sales has a stronger evidentiary basis for lost-profit calculations than a seller whose account was opened only one week before suspension.
Accounting and financial expert evidence can therefore become decisive.
18. The Seller Must Also Mitigate Its Loss
A claimant cannot ordinarily allow damages to increase indefinitely when reasonable alternatives exist.
The marketplace may argue that the seller could have:
- sold through its own website;
- moved stock to another marketplace;
- used wholesale channels; or
- otherwise reduced the loss.
Therefore, evidence that the seller attempted to mitigate the consequences can strengthen a compensation claim.
At the same time, the commercial reality should be recognised.
A business that has accumulated 50,000 customer reviews and built a large following on one marketplace cannot necessarily reproduce that commercial position on another platform overnight.
That loss of marketplace-specific visibility may itself form part of the factual damage analysis.
19. Which Court Hears the Dispute?
Where both parties are commercial enterprises and the dispute arises from a marketplace seller agreement, the dispute will generally have a commercial character.
Depending on the precise parties and claim, proceedings will commonly be brought before the competent Commercial Court of First Instance.
Claims seeking payment or compensation in commercial disputes are also generally subject to mandatory pre-action mediation under Article 5/A of the Turkish Commercial Code.
The current provision expressly covers commercial claims involving monetary receivables, damages, actions for annulment of objection, negative declaratory actions and restitution actions; the mediation process is generally to be concluded within six weeks, subject to a limited extension.
Where the primary claim is purely non-monetary—for example, reinstatement of the seller account—the procedural analysis should be carried out separately, particularly if combined with monetary claims.
20. A Practical Legal Strategy After an Unfair Suspension
When a profitable marketplace account is suddenly closed, the seller should avoid relying exclusively on repeated customer-support tickets.
A more structured approach is usually preferable.
Step 1 — Identify the Exact Reason
Obtain the suspension notification and identify the contractual provision relied upon.
Step 2 — Check the Objective Criterion
Determine whether the alleged violation is actually listed in the seller agreement as a ground for restriction, suspension or termination.
Step 3 — Check Article 17 Procedure
Was the seller asked for an explanation?
Was at least three business days provided?
Was the platform entitled to rely on the emergency exception?
Step 4 — Submit Documentary Evidence
Where authenticity, intellectual property, related accounts or customer complaints are involved, build a documentary response rather than merely denying the allegation.
Step 5 — Preserve Commercial Evidence
Record turnover, profits, advertising expenditure, ratings, inventory and withheld payments.
Step 6 — Send a Formal Notice
Demand reinstatement and/or payment and place the platform formally on notice of continuing losses.
Step 7 — Consider Administrative Complaint
Where the conduct potentially constitutes an unfair commercial practice, consider an application to the Ministry of Trade.
Step 8 — Consider Interim Judicial Protection
Where the business faces imminent and serious harm, analyse whether the conditions for an interim injunction can be established.
Step 9 — Commence Mediation Where Required
Particularly before pursuing monetary compensation or receivables.
Step 10 — File the Commercial Claim
Potential remedies can then be structured around reinstatement, declaratory relief, payment of withheld funds and compensation, depending on the circumstances.
Conclusion: A Marketplace Is Powerful, but It Does Not Have Unlimited Contractual Authority
Marketplaces undoubtedly need mechanisms to protect consumers, prevent fraud, remove counterfeit goods and safeguard their digital systems.
A seller does not have an unconditional right to remain on a platform despite genuine misconduct.
But the opposite proposition is equally important:
a marketplace does not have an unlimited right to destroy a seller’s online business through an unexplained algorithmic decision.
Turkish electronic-commerce legislation now expressly requires objective suspension criteria and, except in specified urgent circumstances, a transparent process giving the seller an opportunity to explain itself.
Law No. 6563 also expressly prohibits certain forms of arbitrary suspension as unfair commercial practices.
Therefore, when a Trendyol, Amazon, Hepsiburada, N11 or similar seller account is closed, the seller should not ask only:
“How do I convince customer support to reopen my store?”
The legally relevant questions are:
What objective contractual rule did I allegedly violate?
Was I given the legally required opportunity to respond?
Was immediate suspension genuinely justified by fraud, cybersecurity or another urgent statutory reason?
Is the platform withholding money in addition to closing the store?
What financial damage can I prove?
Those questions transform what initially looks like a “seller support problem” into what it may actually be:
a commercial dispute involving statutory marketplace obligations, unfair commercial practices, contractual liability and potentially substantial compensation.
For businesses generating significant revenue through online marketplaces, the seller account itself may be one of the company’s most valuable commercial assets.
When that asset is unjustifiably disabled, Turkish law provides remedies that go considerably beyond clicking “appeal suspension” one more time.
This article provides general legal information concerning Turkish law as of August 2026 and does not constitute legal advice. Each seller-account suspension should be assessed according to the applicable seller agreement, the stated violation, marketplace communications, evidence supporting the suspension, the seller’s corporate status and the financial consequences of the restriction.
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