A Practical Legal Guide to Recovering Seller Funds Withheld by Online Marketplaces Under Turkish Law

An online seller may successfully deliver hundreds of orders through a marketplace, issue all required invoices and wait for the expected settlement date—only to discover that the marketplace has suddenly placed the seller’s balance on hold.

The seller dashboard may display messages such as:

“Your payments have been temporarily suspended due to a risk review.”

“Your balance has been blocked due to suspicious activity.”

“Payments will remain in reserve until the investigation is completed.”

or simply:

“Your settlement is currently unavailable.”

The withheld amount may represent hundreds of thousands or even millions of Turkish lira.

This is particularly important for businesses operating through platforms comparable to:

• Trendyol,
• Amazon,
• Hepsiburada,
• N11,
• ÇiçekSepeti,
• or other online marketplaces.

The central legal question is therefore:

Can an online marketplace simply block the seller’s money because its standard terms allow it to do so?

Under Turkish law, the answer is:

Not without limits.

The regulatory framework created by Law No. 6563 on the Regulation of Electronic Commerce and the Regulation on Electronic Commerce Intermediary Service Providers and Electronic Commerce Service Providers introduced specific protections against unfair commercial practices directed at marketplace sellers.

The Ministry of Trade expressly states that one of the principal purposes of the current e-commerce framework is to prevent unfair practices against sellers operating on online marketplaces.

Most importantly, the Regulation establishes a specific rule concerning when marketplace sales proceeds must be transferred to sellers.

This rule can provide a powerful legal basis for businesses whose money is being unjustifiably withheld.

1. The Seller–Marketplace Relationship Is Usually a Commercial Relationship

The first procedural point is fundamental.

A business selling goods through an online marketplace is generally not acting as a consumer when dealing with the marketplace.

The marketplace provides a commercial intermediary service to the seller, and the seller uses that service in connection with its commercial or professional activity.

Accordingly, a dispute such as:

“The marketplace owes my company TRY 3 million from completed sales but refuses to release the money”

will generally not be resolved through a Consumer Arbitration Committee or Consumer Court merely because consumers purchased the underlying products.

The dispute is usually between:

• the Electronic Commerce Intermediary Service Provider (ETAHS), meaning the marketplace; and
• the Electronic Commerce Service Provider (ETHS), meaning the seller.

The current Regulation expressly uses this structure to regulate commercial relations between marketplaces and sellers.

For a corporate seller, the dispute will therefore generally have the characteristics of a commercial dispute.

2. What Does Turkish Law Say About Marketplace Payments to Sellers?

One of the strongest protections appears in Article 11 of the relevant Regulation.

The Regulation expressly prohibits unfair commercial practices in electronic commerce.

A marketplace practice is deemed unfair where it significantly disrupts the commercial activity of the seller, impairs the seller’s ability to make reasonable commercial decisions or forces the seller into a commercial relationship it would not normally accept.

More importantly, some practices are classified as unfair in all circumstances.

One of them concerns delayed settlement payments.

The Regulation provides that the payment due to the seller from a sale must generally be made no later than five business days from the date on which both:

• the sales proceeds have come under the marketplace’s control; and
• the order has reached the buyer.

Failure to make the full payment within that framework is expressly classified as an unfair commercial practice.

This rule is extremely important in seller-payment disputes.

3. The Five-Business-Day Rule Can Be a Powerful Weapon for Sellers

Suppose a seller sells electronic products through a marketplace.

The customer:

• pays TRY 40,000;
• receives the product;
• does not request a return;
• raises no dispute;
• and the marketplace receives the purchase price.

The marketplace nevertheless keeps the seller’s money for:

• twenty days,
• forty-five days,
• ninety days,
• or an indefinite “risk review period.”

The starting point under the Regulation is that the seller should receive the amount due within the statutory framework.

A platform cannot automatically justify a long-term reserve merely because its standard agreement contains a broadly drafted clause such as:

“The Marketplace may withhold any seller balance for any period it considers appropriate.”

The agreement must be examined together with mandatory e-commerce legislation.

4. However, the Five-Day Rule Has an Important Exception

This is the most important qualification in the entire analysis.

Not every payment suspension is unlawful.

Article 11(5) of the Regulation provides that the five-business-day payment rule does not apply where the marketplace postpones or suspends payments for purposes such as:

• preventing unlawful activities; or
• fulfilling obligations arising from legislation.

Therefore, the correct legal argument is not:

“The marketplace can never block seller funds.”

That would be incorrect.

A marketplace may have legitimate reasons to suspend settlement.

For example:

• suspected fraud,
• stolen credit cards,
• money laundering concerns,
• fraudulent orders,
• sanctions issues,
• counterfeit goods,
• regulatory instructions,
• court orders,
• administrative authority decisions.

But this exception should not be treated as an unlimited authorization to freeze every payment indefinitely.

5. “Risk Review” Is Not a Magic Legal Formula

One of the most common marketplace responses is:

“Your balance has been blocked due to a risk assessment.”

That statement alone should not end the legal analysis.

The seller should ask:

What risk?

Which transactions?

Which contractual provision?

Which legal obligation?

Which amount is exposed to the alleged risk?

Why must the entire balance be frozen?

For example, assume:

• twenty transactions totalling TRY 50,000 are disputed;
• the seller’s total available balance is TRY 4 million.

A marketplace decision to block the entire TRY 4 million balance for months may require significantly stronger justification than reserving an amount reasonably connected to the disputed transactions.

The general principles of contractual performance, good faith and proportionality may become important in evaluating whether the platform’s conduct exceeds the legitimate purpose of its risk control.

6. The Marketplace Agreement Is the First Document That Must Be Examined

Every serious claim should begin with the intermediation agreement.

Article 15 of the Regulation requires the relationship between the marketplace and seller to be governed by a written or electronic intermediation agreement.

The agreement must contain, among other matters:

• information concerning the intermediary services;
• situations in which services may be restricted, suspended or terminated;
• fees charged to the seller;
• payment periods;
• internal communication procedures.

Therefore, when seller funds are frozen, counsel should immediately obtain:

• the agreement effective when the relevant sales occurred;
• later versions;
• amendments;
• payment policies;
• reserve policies;
• prohibited-product rules;
• risk policies;
• seller-panel notices.

The exact contractual version matters.

7. Retroactive Contract Changes Are Specifically Restricted

Another major protection for sellers is that marketplaces cannot freely rewrite the contract after the commercial transaction has occurred.

The Regulation expressly classifies as unfair a practice whereby contractual provisions are changed:

• retroactively;
• unilaterally to the seller’s disadvantage;

or the contract includes provisions allowing such retroactive adverse changes.

This can be crucial.

For example:

The seller completes sales in January under a contract allowing a seven-day reserve.

The marketplace changes the terms in February and claims that the new ninety-day reserve also applies to January transactions.

That conduct may raise significant regulatory and contractual objections.

8. The Marketplace Cannot Invent Charges That Were Not Properly Agreed

Article 11 also provides that charging the seller for a service may constitute an unfair commercial practice where:

• no service was actually provided; or
• the nature of the service and the applicable amount or rate were not specified in the intermediation agreement.

This becomes relevant where marketplaces deduct amounts described as:

• risk fee,
• operational penalty,
• customer-experience deduction,
• service adjustment,
• dispute-management fee,
• logistics adjustment.

The seller should ask:

Where exactly in the contract was this charge agreed, and how was the amount calculated?

9. Lawful Set-Off Must Be Distinguished From an Unlawful Payment Block

Sometimes the marketplace does not technically “freeze” money.

Instead, it states:

“We have set off our receivable against your seller balance.”

Article 11 contains an important rule in this respect.

Where the marketplace deducts:

• matured receivables arising from its intermediary services; or
• amounts paid on behalf of the seller pursuant to a judicial or administrative decision,

the statutory framework may treat the seller as having been paid to that extent.

Therefore, counsel must distinguish between:

A Genuine Set-Off

For example:

• commission already due,
• agreed logistics fee,
• matured contractual debt.

and:

A Vague Reserve

For example:

“We might suffer losses at some point, therefore we are keeping TRY 5 million.”

These are legally different situations.

10. Potential Future Claims Are Not the Same as Matured Claims

This distinction is especially important.

Suppose the marketplace says:

“Some customers may request refunds during the next six months.”

A possible future refund risk is not automatically the same as a presently matured receivable.

The marketplace must identify the contractual and statutory basis for maintaining the reserve.

Where the seller’s already-earned receivables are being withheld to secure hypothetical future losses, the enforceability of the clause and proportionality of the reserve deserve close scrutiny.

11. Chargebacks Can Legitimately Affect the Analysis

Credit-card chargebacks create a more complicated situation.

A buyer may challenge a transaction through its issuing bank on grounds such as:

• unauthorized transaction;
• non-delivery;
• fraudulent use of the card.

If the marketplace has a contractual obligation toward the payment provider or acquiring bank and has a realistic exposure to chargebacks, some reserve mechanism may be commercially justified.

However, the seller should still request:

• transaction identification;
• chargeback amount;
• chargeback reason;
• date;
• documentary basis;
• expected resolution period.

The existence of one chargeback should not automatically justify an unexplained indefinite freeze of unrelated sales proceeds.

12. The Payment-Service Provider Must Also Be Identified

Modern marketplaces frequently do not hold customer money directly.

Payments may pass through:

• banks,
• payment institutions,
• electronic-money institutions,
• marketplace-affiliated payment companies.

This creates an important factual question:

Who actually controls the money?

The Regulation provides that where payment is made to a payment-service provider within the same economic group as the marketplace, that payment may be treated as payment to the marketplace for purposes of the statutory rule.

Accordingly, a marketplace should not automatically avoid the settlement obligation by saying:

“The money is technically with our payment company.”

The economic and contractual structure must be examined.

13. Account Suspension and Payment Suspension Are Not Exactly the Same

Another common situation is:

1. seller account is suspended;
2. new sales are stopped;
3. existing money is also frozen.

These measures must be analysed separately.

The fact that the marketplace may have the right to suspend future marketplace activity does not necessarily mean it has an unlimited right to retain already-earned receivables.

The contractual and statutory basis for each measure should be examined independently.

14. Marketplaces Cannot Suspend Seller Services Arbitrarily

Article 17 of the Regulation contains important procedural safeguards concerning restriction, suspension and termination of marketplace services.

As a general rule, the marketplace may restrict, suspend or terminate intermediary services only by reference to objective criteria included in the intermediation agreement.

Where circumstances justifying restriction, suspension or termination allegedly exist, the marketplace must generally:

• clearly explain the reasons;
• request an explanation from the seller;
• provide at least three business days for the seller to respond.

If the response is considered insufficient, the platform can take action but must generally communicate its decision within the regulatory timeframe, including the seven-business-day decision period described in the Regulation.

These rules provide useful evidence in a related payment dispute.

15. There Are Emergency Exceptions

Article 17 also recognizes circumstances in which immediate action can be justified.

The marketplace may act immediately in circumstances arising from legislation or involving:

• public order,
• urgency,
• fraud,
• data breaches,
• cybersecurity risks.

But even then, the reasons for the restriction, suspension or termination must be notified to the seller without delay.

Therefore, even in a genuine fraud case, transparency remains important.

16. An Indefinite “Investigation” Can Become Legally Problematic

A typical dispute may look like this:

Day 1: Seller account blocked.

Day 10: Seller asks why.

Day 20: Marketplace says “investigation continues.”

Day 60: Same answer.

Day 120: TRY 8 million still blocked.

At some point, the issue becomes:

Is the marketplace genuinely conducting a legally required investigation, or is the platform simply financing itself with the seller’s money?

The longer the freeze continues, the more important it becomes for the marketplace to demonstrate:

• the legal basis;
• the transactions affected;
• why the amount withheld is necessary;
• why the investigation has not concluded.

17. The Marketplace’s Internal Communication System Should Be Used Immediately

The Regulation requires marketplaces to operate an internal communication system through which sellers can make applications.

Unless another specific period applies, applications made through that system must generally be resolved within fifteen days and the result must be communicated through the system.

The seller should therefore use the marketplace’s internal communication channel immediately.

But the application should be legally structured.

Do not merely write:

“Please release my money.”

Instead request specific information.

18. What Should the Seller Request From the Marketplace?

The seller should demand a written explanation identifying:

• total amount blocked;
• date on which each amount became payable;
• relevant order numbers;
• reason for each withheld payment;
• exact contractual provision relied upon;
• exact statutory or regulatory obligation relied upon;
• amount attributed to refunds;
• amount attributed to chargebacks;
• amount attributed to commissions or set-off;
• amount attributed to fraud investigations;
• expected release date.

This forces the marketplace to move from a vague statement such as:

“Risk identified”

to a legally testable position.

19. Preserve the Seller Dashboard Before It Changes

One of the biggest evidential mistakes is failing to document the online seller panel.

The seller should preserve:

• balance screens;
• blocked-balance screens;
• payment schedules;
• settlement dates;
• order details;
• commission calculations;
• refund reports;
• risk warnings;
• account-suspension notices;
• support tickets.

Screenshots are useful.

For high-value disputes, stronger electronic-evidence preservation methods may also be considered.

The marketplace’s digital records can later become central evidence in commercial proceedings.

20. Download the Intermediation Agreement Immediately

Marketplaces frequently update seller agreements.

A seller may later discover that the agreement visible in the dashboard is not the exact version that applied when the money was withheld.

The current Regulation requires the marketplace to preserve the intermediation agreement in its internal communication system in a manner accessible to the seller.

Nevertheless, the seller should independently preserve:

• PDF copies;
• screenshots;
• amendment notices;
• version dates.

Do this before the relationship is terminated.

21. Send a Formal Notice

If internal support does not resolve the issue, the next practical step is usually a formal legal demand.

Depending on the parties and circumstances, this may be sent through:

• registered electronic mail (KEP);
• notary notice;
• another provable written method.

The notice should not merely demand “unblocking.”

It should establish:

1. amount owed;
2. transactions generating the receivable;
3. contractual payment date;
4. statutory payment framework;
5. previous applications;
6. absence or inadequacy of justification;
7. default.

The marketplace should be given a clear deadline to pay.

22. Why a Formal Notice Matters

A properly drafted notice can serve several purposes.

It may:

• place the marketplace in default;
• establish the chronology;
• support interest claims;
• undermine later allegations that the seller failed to cooperate;
• support a Ministry complaint;
• strengthen a subsequent court claim.

A vague customer-support ticket usually does not perform all these functions.

23. Can the Seller Claim Interest?

Potentially, yes.

Where a commercial receivable has become due and the marketplace fails to pay, the seller may seek applicable contractual or statutory default interest depending on the legal structure of the relationship.

In a significant commercial dispute, the claim should therefore not necessarily be limited to:

principal amount.

It may include:

• principal receivable;
• default interest;
• contractual damages where available;
• additional provable losses.

24. Can the Seller Claim Damages Beyond the Blocked Money?

Possibly, but the evidentiary burden becomes greater.

Suppose a marketplace unlawfully blocks TRY 10 million for six months.

Because of the freeze, the seller:

• cannot purchase inventory;
• loses an important distribution contract;
• defaults on bank obligations;
• pays expensive emergency financing.

The seller may attempt to claim additional damages.

However, it will need to establish:

• contractual or statutory breach;
• loss;
• causation;
• amount of damage.

The seller should therefore preserve evidence of financing costs and lost commercial opportunities from the beginning.

25. Can the Seller Start Enforcement Proceedings?

Where the receivable is determined and due, ordinary enforcement proceedings for a monetary claim may be considered.

This can create commercial pressure because the marketplace must decide whether to:

• pay;
• or formally object.

If the marketplace does not object within the applicable enforcement period, the proceedings may become final.

If it objects, the seller may need to proceed with the appropriate litigation route.

Whether enforcement proceedings are strategically preferable to commencing with mediation and litigation depends on the evidence and contract.

26. Mandatory Mediation Usually Applies Before a Commercial Receivables Action

For commercial disputes involving payment of a monetary receivable, Turkish law generally requires mediation before filing the relevant lawsuit.

The Ministry of Justice confirms that under Article 5/A of the Turkish Commercial Code, mediation is a precondition for commercial lawsuits concerning monetary receivables and compensation. The scope also includes actions such as annulment of objection in applicable commercial disputes.

Therefore, a seller seeking:

TRY 5 million blocked by the marketplace

will ordinarily need to consider mandatory commercial mediation before bringing the payment action.

27. Enforcement Proceedings and Mediation Should Not Be Confused

Mandatory mediation concerns filing certain lawsuits.

It does not mean that every enforcement proceeding must first pass through mediation.

A seller may therefore, depending on strategy, consider:

enforcement first → objection by marketplace → mediation → action for annulment of objection.

Alternatively:

formal demand → mediation → commercial receivables lawsuit.

The best route depends on factors such as:

• clarity of the debt;
• amount;
• marketplace defence;
• urgency;
• need for interim protection.

28. Which Court Usually Has Jurisdiction?

Where the seller and marketplace are merchants and the dispute concerns their commercial enterprises, the dispute will generally be commercial in nature.

Accordingly, the Commercial Court of First Instance (Asliye Ticaret Mahkemesi) will commonly be the relevant judicial forum, subject to the exact circumstances and any valid jurisdiction arrangements.

The intermediation agreement should be reviewed for:

• jurisdiction clauses;
• arbitration clauses;
• applicable-law provisions.

Large marketplaces frequently include detailed dispute-resolution clauses.

Their validity and applicability should be analysed before filing.

29. Can the Seller Obtain a Provisional Attachment?

For large blocked balances, provisional attachment (ihtiyati haciz) can be a particularly important consideration.

Article 257 of the Enforcement and Bankruptcy Law provides that a creditor holding an unsecured and matured monetary claim may request provisional attachment over the debtor’s assets, receivables and rights.

This remedy may be relevant where:

• the seller’s receivable is already due;
• the amount can be established;
• it is not secured by a pledge.

The objective is to secure the eventual collection of the debt.

30. Provisional Attachment Is Often More Appropriate Than an Interim Injunction for a Pure Monetary Claim

This procedural distinction matters.

Where the ultimate claim is simply:

“Marketplace owes me TRY 4 million,”

the appropriate protective measure will often be examined under the rules governing provisional attachment rather than attempting to obtain a general interim injunction over the same monetary claim.

The Ministry of Justice’s materials similarly emphasize that provisional attachment is the mechanism intended for unsecured monetary claims meeting the conditions under Article 257.

The appropriate measure must nevertheless be assessed individually.

31. What Must Be Shown for a Strong Provisional Attachment Application?

The seller should ideally present documents establishing the receivable with sufficient strength.

Useful evidence may include:

• marketplace settlement statements;
• invoices;
• delivered-order reports;
• seller account balance;
• payment calendar;
• written acknowledgment by the platform;
• previous partial payments;
• intermediation agreement.

The application becomes considerably stronger where the marketplace does not dispute that the sales occurred but relies only on an indefinite payment block.

32. Can the Marketplace’s Bank Accounts Be Provisionally Attached?

Where the court grants provisional attachment, enforcement can potentially be pursued against attachable assets and receivables of the debtor in accordance with enforcement law.

For a marketplace company, relevant assets may include receivables or bank accounts.

However, the procedural strategy should be designed carefully, particularly for large regulated businesses and complex payment structures.

33. A Ministry of Trade Complaint Is a Separate Remedy

Court proceedings seek to recover money for the seller.

Administrative enforcement serves a different function.

The Regulation expressly gives the Ministry of Trade authority to conduct inspections concerning compliance with the e-commerce framework.

The Ministry may request:

• documents;
• books;
• electronic records;
• explanations.

The parties are required to provide requested information and facilitate the inspection.

A seller alleging an unlawful marketplace payment practice may therefore also consider an administrative complaint to the Ministry.

34. Why a Ministry Complaint Can Be Powerful

The seller may have access only to its own dashboard.

The Ministry, by contrast, has statutory supervisory powers.

It may investigate whether a marketplace systematically:

• delays seller payments;
• applies unlawful reserves;
• uses undisclosed deductions;
• applies retroactive contractual amendments;
• restricts sellers without objective criteria.

The Ministry itself explains that the 2022–2023 e-commerce reforms were designed specifically to eliminate unfair commercial practices against marketplace sellers.

Administrative enforcement can therefore place additional pressure on the marketplace.

35. But the Ministry Does Not Replace a Debt Collection Action

This distinction is important.

A Ministry complaint may result in:

• investigation;
• regulatory findings;
• administrative sanctions.

It does not necessarily function as an ordinary civil judgment ordering immediate payment of every disputed seller receivable.

Therefore, where a business urgently needs its money back, it should not rely exclusively on the administrative route.

A parallel strategy may be more effective:

administrative complaint + commercial debt recovery.

36. The Seller Should Not Apply to the Consumer Arbitration Committee for Its Own Marketplace Balance

This is a frequent procedural mistake.

The seller may think:

“This occurred on an e-commerce platform, so I should apply to the Consumer Arbitration Committee.”

But the seller’s own dispute with the marketplace arises from its commercial selling activity.

The Ministry of Trade confirms in its general consumer guidance that transactions entered into for commercial or professional purposes do not receive consumer status merely because one party purchased a service.

For a marketplace merchant seeking settlement of commercial sales proceeds, the proper commercial remedies should therefore be examined instead.

37. What If Only Part of the Balance Is Disputed?

This can significantly strengthen the seller’s argument.

Suppose:

Total seller balance: TRY 6,000,000

Transactions under refund investigation: TRY 100,000

Potential chargebacks: TRY 75,000

The marketplace freezes:

TRY 6,000,000.

The seller should demand an explanation for why undisputed funds totalling approximately TRY 5.8 million are also being withheld.

A practical legal strategy may be to demand immediate release of at least the undisputed portion.

This prevents the marketplace from turning a narrow transaction dispute into a complete liquidity freeze.

38. What If the Marketplace Says the Seller Sold Counterfeit Goods?

Counterfeit-goods allegations require separate analysis.

The marketplace has regulatory obligations concerning unlawful content and intellectual-property complaints.

Under the Regulation, specific procedures exist for intellectual-property complaints and seller objections, including documentary evidence concerning product authenticity.

The seller should immediately preserve:

• purchase invoices;
• distribution agreements;
• trademark owner authorizations;
• import documentation;
• supplier invoices;
• serial-number records.

A strong authenticity file may help both restore listings and challenge continued withholding of payments.

39. What If the Seller Account Was Used for Fraud?

Where there is genuine evidence that the seller account has been used for fraud, the marketplace’s position is stronger.

The Regulation expressly permits immediate restriction or suspension in cases involving fraud and allows payment suspension where necessary to prevent unlawful activities.

In such a case, a court will not simply ask:

“Were five business days exceeded?”

It will also examine:

• why payments were suspended;
• whether the platform was complying with legal obligations;
• whether the seller itself was involved;
• whether the amount and duration were justified.

40. A Fraud Exception Does Not Automatically Justify Permanent Confiscation

Suspending a payment is different from permanently keeping the money.

Even where an initial fraud investigation was legitimate, the marketplace must eventually determine:

• which funds are legitimate;
• which funds are connected to unlawful transactions;
• which amounts must be refunded;
• which amounts remain payable to the seller.

A temporary protective measure should not automatically turn into permanent appropriation of unrelated seller receivables.

41. What If the Marketplace Says “We Can Keep the Money for 180 Days”?

Some contracts contain long reserve provisions.

The clause must be analysed together with the mandatory e-commerce framework.

The key questions are:

• What is the purpose of the reserve?
• Does the Regulation permit it?
• Is the clause sufficiently clear?
• Was it in force when the transaction occurred?
• Is the amount proportionate to the identified risk?
• Is the platform relying on the statutory unlawful-activity exception?
• Has the seller been informed of the specific reason?

The mere presence of “180 days” in general terms does not necessarily answer all of these questions.

42. Standard Contract Terms Are Not Above Mandatory Law

Marketplaces often have substantially greater bargaining power than individual sellers.

The seller may have accepted hundreds of pages of terms by clicking:

“I agree.”

That does not mean every clause is immune from judicial review.

Mandatory statutory rules, general contractual principles and rules governing standard terms may still affect enforceability.

Particularly problematic provisions may include clauses giving the platform unlimited authority to:

• confiscate money;
• impose undisclosed deductions;
• retrospectively change payment rules;
• block payments without any objective basis.

43. Evidence of Other Sellers’ Problems Can Be Relevant but Is Not Enough Alone

A seller may discover hundreds of internet complaints stating:

“The same marketplace blocked my money.”

This may indicate a systematic problem.

However, another seller’s online complaint usually cannot replace evidence in the claimant’s own case.

The seller’s strongest case will be built around:

• its own transactions;
• its own contract;
• its own payment records;
• its own communications.

Evidence of a wider pattern can be supplementary.

44. A Practical Example: TRY 3 Million Blocked After Delivered Orders

Consider the following case.

A Turkish electronics seller operates through a major marketplace.

During one month:

• 1,200 orders are completed;
• all products are delivered;
• total amount payable to the seller is TRY 3 million.

The marketplace then announces:

“Your balance has been frozen due to risk indicators.”

No transaction is identified.

No customer complaint is disclosed.

The money remains blocked for eighty days.

A legal strategy could involve:

Step 1

Download all payment and order data.

Step 2

Obtain the applicable intermediation agreement.

Step 3

Demand identification of the objective criterion and legal basis for the block.

Step 4

Invoke the statutory payment framework and unfair commercial practice rules.

Step 5

Send KEP/notary notice.

Step 6

Consider Ministry of Trade complaint.

Step 7

Commence commercial mediation for payment of the receivable.

Step 8

If no settlement occurs, file the appropriate commercial claim.

Step 9

Where conditions exist, consider provisional attachment.

This is substantially stronger than repeatedly contacting customer support.

45. Another Example: TRY 500,000 Blocked but TRY 400,000 Represents Returns

Consider a different seller.

The marketplace owes TRY 500,000.

However:

• TRY 300,000 relates to confirmed refunds;
• TRY 100,000 relates to valid chargebacks;
• only TRY 100,000 remains undisputed.

In that case, demanding immediate payment of the entire TRY 500,000 may be weak.

The case should instead identify the net amount legally due.

This is why reconciliation is essential before litigation.

46. Prepare a Transaction-by-Transaction Reconciliation

For high-value disputes, counsel should create a spreadsheet containing:

• order number;
• sale date;
• delivery date;
• gross price;
• commission;
• logistics fee;
• refund;
• chargeback;
• contractual deduction;
• amount payable;
• statutory due date;
• payment received;
• unpaid balance.

This transforms the dispute from:

“The marketplace owes us money.”

into:

“These 1,842 completed transactions created a net matured receivable of TRY 7,420,318.64.”

That is a much stronger litigation position.

47. The Marketplace Should Be Forced to Separate Different Categories

A marketplace balance can contain several legally different categories.

Counsel should separate:

Category A — Undisputed completed sales

Strongest payment claim.

Category B — Customer returns

Requires reconciliation.

Category C — Chargebacks

Requires payment-system analysis.

Category D — Contractual commissions

Usually deductible if matured and valid.

Category E — Penalties

Require contractual and legal review.

Category F — Fraud-related reserve

Requires examination under the statutory exception.

Category G — Judicial or administrative deductions

May have a separate legal basis.

This prevents the marketplace from using one vague “blocked balance” label for everything.

48. What Is the Seller’s Strongest Case?

The strongest claim will generally involve facts such as:

• goods delivered;
• no refund;
• no chargeback;
• no fraudulent transaction;
• payment received by marketplace;
• statutory/contractual payment date passed;
• no specific legal reason provided for suspension;
• no matured counterclaim;
• long delay.

In that situation, the seller may have strong arguments based on:

• contract;
• Law No. 6563;
• the e-commerce Regulation;
• commercial default principles.

49. What Is the Marketplace’s Strongest Defence?

The marketplace’s strongest defence is usually not:

“Our contract says we can do anything.”

A stronger defence would be:

“Specific transactions generated a documented fraud or regulatory risk; payment was suspended to prevent unlawful activity under Article 11(5); the relevant amounts and legal basis were notified to the seller; the reserve was limited to the risk and reviewed within a reasonable period.”

The more specific and documented the marketplace’s explanation, the more difficult the seller’s claim becomes.

50. What Should the Lawyer Ask on the First Day?

A seller approaching counsel should ideally provide:

1. marketplace legal entity;
2. current seller agreement;
3. previous agreement if amended;
4. blocked amount;
5. seller dashboard;
6. payment schedule;
7. delivery confirmations;
8. invoices;
9. return and chargeback data;
10. reason stated for the block;
11. support correspondence;
12. date the money first became due.

Without these documents, it is difficult to determine whether the dispute involves:

• genuine payment default;
• valid set-off;
• chargeback reserve;
• regulatory freeze;
• fraud investigation.

51. A Practical Legal Roadmap

For most significant marketplace-payment disputes, the seller can consider the following sequence:

Stage 1 — Freeze the Evidence

Download all contractual and transaction records.

Stage 2 — Reconcile the Balance

Calculate the exact matured receivable.

Stage 3 — Internal Objection

Use the marketplace’s internal communication system.

Stage 4 — Demand the Legal Basis

Require transaction-specific justification.

Stage 5 — Formal Notice

Send a legally reasoned KEP or notary demand.

Stage 6 — Administrative Complaint

Where there is evidence of an unfair marketplace practice, consider notifying the Ministry of Trade.

Stage 7 — Commercial Enforcement Strategy

Evaluate ordinary enforcement proceedings.

Stage 8 — Mandatory Mediation

Complete mediation where required before the relevant commercial lawsuit.

Stage 9 — Commercial Court Proceedings

Seek payment, interest and, where proven, additional damages.

Stage 10 — Protective Measures

Where legally available, consider provisional attachment.

52. Final Assessment: A Marketplace Does Not Own the Seller’s Sales Proceeds

The fact that customer payments pass through a marketplace does not mean the marketplace has unlimited discretion to retain those funds.

Turkey’s current electronic-commerce framework was specifically designed to regulate the imbalance between marketplaces and sellers.

The Regulation expressly classifies failure to transfer the seller’s payment within the statutory framework as an unfair commercial practice and establishes the general five-business-day rule.

At the same time, the law recognizes legitimate exceptions.

A marketplace may temporarily suspend payments where necessary to:

• prevent unlawful activities; or
• comply with legal obligations.

Therefore, the strongest legal analysis does not ask merely:

“Has the money been blocked?”

It asks:

Why was it blocked, which transactions justify the block, what contractual and statutory provision permits it, how much money must reasonably be reserved, and for how long?

Where the marketplace cannot answer those questions and simply retains already-earned seller proceeds indefinitely, the seller should consider moving beyond customer-support correspondence.

The practical route is usually:

document the debt → challenge the block internally → send a formal demand → invoke the unfair-commercial-practice framework → consider Ministry supervision → pursue commercial mediation and debt recovery → seek provisional protection where necessary.

For businesses dependent on marketplace cash flow, the issue should be treated urgently.

Because when a platform blocks a seller’s money, the dispute is not merely about an account setting.

It may be a multimillion-lira commercial receivables claim.