Trading Halts, Watchlist Market and Delisting on Borsa Istanbul: Exchange Rules, Squeeze-Outs and Remedies for Foreign Investors

When a Borsa Istanbul share is caught up in a manipulation case, its trading status can change quickly and in several ways. The exchange may halt trading for up to a month on the General Manager’s decision, and longer by board decision (Borsa Istanbul Exchange Activities Regulation Art. 25). It may impose gross settlement or require cash and shares to be deposited before orders are sent (Arts. 36 and 44(2)). It may move the share to the Watchlist Market, where it trades only in single-price sessions (Listing Directive Art. 35), or delist it entirely (Listing Directive Art. 23). SPK keeps its own power to halt trading and delist (Capital Markets Law Art. 69(2)) and can impose trading bans and other measures where manipulation is suspected (Art. 101). Each of these steps has its own legal basis, its own decision-maker and its own route of challenge: claims against the exchange go to the civil courts (Art. 65(11)), and SPK decisions go to the administrative courts. This guide explains the rules, what delisting does and does not change for a holder, how a squeeze-out works as the main route to a voluntary exit, and the remedies open to a foreign institutional investor. It reflects the legislation and exchange rules in force as at 25 October 2026.

Why trading status matters to an institutional holder

For a long-term holder, the price of a share is only part of the picture. Whether the share can be traded at all, in which market segment, under which settlement method and with which order restrictions determines whether a position can be reduced, how it is valued, whether it remains eligible for index and mandate purposes and what evidence exists about the price at any given time. In the 2026 fund and market manipulation cases, these questions arise in practice: shares connected with an investigation may be subject to exchange measures, issuers in financial difficulty may move to the Watchlist Market, and controlling shareholders may use the squeeze-out rules to take a company private.

Turkish law splits these decisions between two bodies. Borsa Istanbul is a joint-stock company subject to private law that carries out the tasks the Capital Markets Law gives it independently and under its own responsibility (Capital Markets Law Art. 65(10)). SPK is the regulator; its decisions are administrative acts. The distinction determines the court that hears a challenge, the time limits and the type of remedy available. The overview of the 2026 cases and the full series of guides is in the legal guide to Turkey’s 2026 fund and market manipulation crisis.

Who decides what: the legal map

The Capital Markets Law sets the framework. Listing, delisting, trading and the halting of trading are governed by regulations the exchange prepares and SPK approves (Art. 67(1)(a)). An exchange may halt trading in an instrument or delist it when the conditions in its own rules are met; it must notify SPK immediately and disclose the decision publicly (Art. 69(1)). SPK’s own power to halt trading and delist is preserved (Art. 69(2)). The detailed rules sit in three instruments: the Borsa Istanbul Exchange Activities Regulation (Official Gazette 19 October 2014, No. 29150, last amended on 10 September 2026), the Listing Directive (revision of 21 September 2026) and the Equity Market Directive (revision of 21 September 2026).

Temporary trading halts

The exchange’s General Manager may temporarily halt trading in an instrument, and in instruments based on it, in three situations (Exchange Activities Regulation Art. 25(1)):

1. 1. Pending information. The exchange learns that there is information important enough to affect investors’ decisions, or that an announcement will be made, and considers it necessary that members and investors be informed during the session.
2. 2. Abnormal market movements. Abnormal market movements prevent a sound market from forming in the instrument, or material factors prevent trading from being carried out properly.
3. 3. Non-cooperation by the issuer. Despite an earlier warning on the same matter, the issuer does not provide information, documents or electronic records the exchange requests, does not provide them on time or in the form requested, or does not allow inspections.

The General Manager may halt trading in an instrument for at most one month; a longer halt requires a decision of the exchange’s board (Art. 25(2)). A temporary halt must be announced on the Public Disclosure Platform (KAP) together with its reasons and notified to SPK (Art. 25(4)). The stated reasons are the starting point for assessing whether a halt was lawful and for following its later course.

A halt does not suspend the issuer’s disclosure duties. The Communiqué on Special Situations expressly applies to issuers whose trading has been temporarily closed (Communiqué II-15.1 Art. 2(1)). Inside information that arises during a halt must still be disclosed under the ordinary rules, which are explained in the guide to continuous disclosure under Communiqué II-15.1.

Circuit breakers and market-wide measures

Separate from discretionary halts, the Equity Market Directive provides for automatic circuit breakers. When a share is trading under the continuous method and its price change, measured against a reference value, reaches or exceeds the ratio set by the General Manager, trading in that share is temporarily halted; a single-price auction may then be used to determine the price, or a set period may be allowed to pass, before continuous trading resumes for the rest of the session (Equity Market Directive Art. 27(1)). The General Manager may also apply an index-based circuit breaker that temporarily halts trading in certain instruments, segments or the whole market when a representative index moves by set ratios (Art. 27(2)).

Two further powers apply at market level. Where extraordinary situations arising from market conditions or infrastructure prevent, or may prevent, orderly and reliable trading, the General Manager may make temporary changes for as long as the situation lasts, including changing session hours, halting or restricting trading and changing daily price limits (Exchange Activities Regulation Art. 37(3)). Where extraordinary developments occur, the exchange’s board may close markets, segments, platforms or systems for up to five trading days and may delegate this power to the General Manager; a closure beyond five trading days requires a board decision submitted to SPK for approval (Art. 39(1)).

These measures are general and price-based. They are relevant mainly as evidence: a circuit breaker triggered on a given day documents abnormal price movement, which may later support an argument about manipulation or about the timing of a disclosure.

Surveillance measures on individual shares

The exchange must operate a surveillance system to ensure that trading is reliable, transparent, efficient, stable, fair, honest and competitive, and to detect transactions carried out in breach of the Capital Markets Law; it may take all kinds of preventive measures (Capital Markets Law Art. 70(2); Exchange Activities Regulation Art. 43). The main share-level tools are the following:

• ▸ Gross settlement. The General Manager may impose a gross settlement obligation for a market, segment, instrument, issuer, exchange member or person giving orders (Regulation Art. 36(1)). Under gross settlement, purchases and sales are settled separately rather than netted against each other.
• ▸ Pre-deposit requirement. For a set period, the General Manager may require that the cash and/or instruments for orders be deposited, in whole or in part, with the exchange, the member, a bank or the settlement and custody institution before the order is sent (Art. 36(1)).
• ▸ Any other preventive measure. To prevent acts and transactions that cannot be explained by a reasonable economic or financial reason and would disrupt the confidence, openness and stability of the markets, and to ensure sound price formation, the General Manager may take any preventive measure, including gross settlement and the deposit requirement, at the level of a market, instrument, issuer, member or person; it may do so on its own initiative or at SPK’s written request (Art. 44(2)).
• ▸ Warnings and sanctions. For breaches, irregularities and fraudulent acts found in inspection and surveillance, the exchange may warn the persons concerned, require the breach to be remedied and apply disciplinary and other sanctions under its rules (Art. 44(1)).
• ▸ Reporting to SPK. Where the exchange finds acts that breach capital markets legislation, in particular insider dealing and market manipulation under Arts. 106 and 107 of the Capital Markets Law and market-disrupting acts under SPK’s Communiqué VI-104.1, or intentional or grossly negligent breaches of exchange rules, it reports the matter to SPK (Art. 44(3)).

In practice, the exchange announces share-level measures on KAP. Announcements have combined gross settlement with a single-price trading method and a ban on orders transmitted over the internet, and have banned short selling and margin trading in particular shares. Such announcements are a public record that the exchange considered trading in the share to need intervention. They do not establish that any particular person committed an offence.

SPK’s own measures

Where there is reasonable suspicion that a person has committed market-disrupting acts, insider dealing or market manipulation (Capital Markets Law Arts. 104, 106 and 107), SPK may take any measure necessary for the effective and sound functioning of the market concerning the persons, their officers and the instruments involved (Art. 101(1)). The measures listed in the Law include:

SPK may also order online content removed or access blocked in the course of these investigations (Art. 101(3)), and it keeps the power to halt trading in an instrument and to delist it (Art. 69(2)). How SPK uses Art. 101 in manipulation cases, and how a trading ban relates to criminal proceedings, is explained in the guide to market manipulation under Article 107.

Transfer to the Watchlist Market

The Watchlist Market (Yakın İzleme Pazarı) is the segment for shares of companies in which developments have occurred that could lead to removal from the Star Market, Main Market or Sub-Market (Listing Directive Art. 4(1)(aa)). The exchange’s board may move a share there in the following cases; before deciding, it may warn the company, give it time to correct the situation or take other measures (Art. 35(1)):

A company whose equity-to-capital ratio falls below one-half, before reaching the one-third threshold, may be warned by the board (Art. 35(2)). After a transfer decision, the share’s trading is closed until the end of the next business day, and it starts trading on the Watchlist Market on the second business day (Art. 35(3)).

Trading conditions there are restrictive. Under the trading rules table in the Equity Market Directive, Watchlist Market shares trade in five single-price sessions a day rather than continuously, short selling and margin trading are not available, and gross settlement applies (Equity Market Directive Art. 39(1)). Liquidity is therefore lower, and building or reducing a position takes longer.

A share returns only on the company’s application. It may move to the Sub-Market once the reasons for the transfer have ceased, any condition attached to the transfer has been met, no other Art. 35(1) ground exists and all listing conditions for the Sub-Market are satisfied; it is not moved directly to the Main Market or Star Market (Listing Directive Art. 36(1)). If the board rejects the application, a new application cannot be made for one year from the decision (Art. 36(4)).

Several grounds overlap with the subjects of other guides in this series. A concordat application is explained in the guide to insolvency, concordat and bankruptcy; large related-party receivables often raise the issues discussed in the guide to concealed profit transfer; and qualified audit opinions bear on the liability questions in the guide to directors’ and auditors’ liability.

Forced delisting

Exchanges must regularly review whether listed instruments still meet the conditions for remaining listed (Capital Markets Law Art. 68(3)). Borsa Istanbul reviews this at least once a year and reports the results to SPK (Exchange Activities Regulation Art. 17(1)). The delisting conditions are set by the exchange’s board, taking into account the issuer’s financial and legal position, compliance with disclosure rules, bankruptcy, loss of the conditions needed to carry on its main business, payment of listing fees and compliance with exchange rules, and are submitted for SPK approval (Art. 16(1)). When a condition is met, the board may delist the instrument; before doing so it may warn the issuer, give it time and take appropriate measures (Art. 16(2)).

For shares on the Star Market, Main Market, Sub-Market and Watchlist Market, the Listing Directive lists the following grounds for permanent delisting by board decision. Before deciding, the board may warn the company, give it time, move the share to the Watchlist Market or take other measures (Listing Directive Art. 23(1)):

A separate rule deals with continued listing. A company loses the conditions for remaining listed if, within one calendar year, the board has warned it three times for failing to meet its disclosure obligations, or if its activities have been halted for the last two years; its instruments are then delisted by board decision (Listing Directive Art. 32(1)–(2)).

The Watchlist and delisting grounds are graduated. Two years of adverse or disclaimed audit opinions can lead to the Watchlist Market; three years can lead to delisting. Related-party receivables above half of total assets in two years’ balance sheets can lead to the Watchlist Market; in three years’ balance sheets, to delisting. A bankruptcy decision is itself a delisting ground, while a concordat application is a Watchlist ground. For a holder, this sequence gives warning: a transfer to the Watchlist Market is often the point at which to examine the company’s disclosures and governance closely.

Shares whose free-float ratio falls below five per cent are treated differently. They may be moved to the Pre-Market Trading Platform (Equity Market Directive Art. 37(5)); the grounds in Art. 23(1) continue to apply to removing them from the platform and banning them from trading, and those that raise their free float to five per cent or more are returned to the relevant market on application (Listing Directive Art. 23(2)).

Relisting

The exchange’s board may relist delisted shares on the company’s application (Listing Directive Art. 28(1)). The conditions depend on the ground for delisting and the time elapsed:

• ▸ Within one year, procedural grounds. Where the shares were delisted for disclosure failures, non-compliance with exchange rules or unpaid fees (Art. 23(1)(a), (b) and (e)), the reasons must have ceased and any other conditions in the board’s decision must be met (Art. 28(1)(a)(1)).
• ▸ Within one year, substantive grounds. Where the shares were delisted for halted activities, deteriorated finances, negative equity, adverse audit opinions or related-party receivables (Art. 23(1)(c), (d), (f), (g) and (ğ)), all the listing conditions must also be met again (Art. 28(1)(a)(2)).
• ▸ After more than one year. The reasons must have ceased, the board’s conditions must be met and all listing conditions must be satisfied (Art. 28(1)(b)).

Where other delisting conditions exist at the date of the application, the board may refuse relisting with reasons or admit the shares to the Watchlist Market (Art. 28(2)). Shares relisted after meeting the full listing conditions start on the Sub-Market and are not admitted to the Main Market or Star Market at first (Art. 28(3)(a)).

What delisting changes, and what it does not

Delisting ends trading on the exchange; it does not extinguish the shares or the rights attached to them. A shareholder of a delisted company remains a shareholder, with the rights to attend and vote at the general meeting, to receive dividends and to bring the actions available under company law. Those rights are explained in the guide to shareholder rights in Turkish listed companies.

The company’s status under capital markets law also needs care. A public company under the Capital Markets Law is a joint-stock company whose shares have been offered, or are deemed offered, to the public (Art. 3(1)(e)). Delisting does not by itself change the fact that the shares were offered to the public. The Listing Directive provides a Pre-Market Trading Platform on which shares of public companies that are not traded on the exchange may be traded without being listed (Art. 4(1)(u)). The position is different after a squeeze-out: a company delisted after the dominant shareholder has used its squeeze-out right is deemed to have left the scope of the Capital Markets Law (Communiqué II-27.3 Art. 5(13)).

Delisting does not end the liability of persons who caused loss before it. Claims for misleading disclosures, manipulation or concealed profit transfer continue to run under their own rules and time limits; a delisting caused by facts that were concealed from the market may itself be part of the loss in such a claim.

Squeeze-out and sell-out

A company does not leave the exchange simply because its controlling shareholder wishes it to. The Listing Directive allows an issuer to apply for delisting within the framework of SPK’s rules, with delisting taking place once the processes required by the relevant legislation are complete (Listing Directive Art. 27(1); Exchange Activities Regulation Art. 16(4)). The principal route SPK’s rules provide is the squeeze-out under Art. 27 of the Capital Markets Law and Communiqué II-27.3 (Official Gazette 31 December 2020, No. 31351).

Where shares acquired through a tender offer or otherwise, including by persons acting together, reach the voting-rights ratio set by SPK, a squeeze-out right arises for the holders and a sell-out right arises for the minority (Capital Markets Law Art. 27(1)–(2)). Communiqué II-27.3 sets the ratio at 98 per cent: a dominant shareholder is a person holding, alone or with persons acting in concert, at least 98 per cent of the company’s voting rights (Art. 3(1)(c)). The rights arise when that threshold is reached, or when the dominant shareholder acquires additional shares while above it (Art. 4(1)). The rules for calculating the threshold are specific:

• ▸ Direct and indirect holdings count. The dominant shareholder’s direct and indirect shares are taken into account; voting privileges are disregarded (Art. 4(2)).
• ▸ Some acquisitions do not trigger the rights. Shares received in bonus issues, or in rights issues where pre-emption rights were not restricted, and changes resulting from inheritance, share buy-backs or the freezing of voting rights do not give rise to the rights (Art. 4(3)).
• ▸ Persons deemed to act together. Companies under the management control of a shareholder, and persons controlling a corporate shareholder together with companies they control, are deemed to act together (Art. 4(4)).
• ▸ Two-year restriction. The rights cannot be used for two years from the first trading of the company’s shares on the exchange (Art. 9(1)).
• ▸ Public sector holdings. The Communiqué does not apply to shares held by public institutions unless they request otherwise (Art. 8(1)).

The procedure runs on fixed deadlines, with a month counted as thirty days (Art. 5(1)):

A sell-out request must cover all of the requesting shareholder’s shares, privileged or not (Art. 5(5)). The sell-out right continues to be honoured until the end of the two-month period even if the dominant shareholder loses that status in the meantime, and during the period the dominant shareholder may not buy additional shares other than through sell-out requests (Art. 5(2)). The amounts relating to shares recorded in the MKK system under the company itself rather than in an intermediary account, and to shares that have not been dematerialised, are kept for three years in an interest-bearing blocked account at Takasbank; the balance is then returned to the company on request, and the company pays persons who later prove that they are shareholders (Art. 5(10)).

The squeeze-out price and manipulation periods

The squeeze-out and sell-out price is paid in Turkish lira, in full and in cash (Communiqué II-27.3 Art. 6(1)). For companies whose shares trade on the exchange, the price is the higher of two figures (Art. 6(2)(a)):

1. 1. Market and valuation average. The average of (i) the arithmetic mean of the daily adjusted weighted average prices on the exchange over the month before the date the rights were disclosed for Star Market companies, or over the six months before that date for companies on other markets and platforms, and (ii) the value set for each share group in the valuation report.
2. 2. Mandatory tender offer price. Where acquiring the dominant position also changes management control, the mandatory tender offer price calculated under the tender offer rules.

For a company whose shares are not traded on the exchange, the valuation report value is used, again subject to the mandatory tender offer price where control changes at the same time (Art. 6(2)(b)).

The rule most relevant to the 2026 cases is in Art. 6(3). If, within the reference periods, SPK has decided to take action under Art. 101 or Art. 107 of the Capital Markets Law because of acts listed in Art. 107, or has recognised extraordinary developments affecting the economy or the sector, the periods on which those decisions were based are left out of the calculation. The reference period is then completed by adding the same length of time to its beginning. The purpose is to prevent prices affected by manipulation, or by extraordinary events, from setting the squeeze-out price.

Communiqué II-27.3 does not contain its own court procedure for reviewing the price. A shareholder who considers the price wrongly calculated must therefore use the general routes: raising the matter with SPK before it approves the issue document, and, where SPK’s approval or another SPK decision is itself unlawful, an action in the administrative courts within the general time limit. Claims against the persons responsible for misleading information in the valuation report or disclosures are civil claims, discussed below.

Challenging an exchange decision

Lawsuits against an exchange are heard by the ordinary (civil) courts (Capital Markets Law Art. 65(11)). This follows from the exchange’s status: it is subject to private law and performs its statutory tasks independently and under its own responsibility (Art. 65(10)). A halt, a gross settlement measure, a Watchlist transfer or a forced delisting decided by Borsa Istanbul is therefore challenged in the civil courts, not by an administrative annulment action. Unless a special rule applies, the general venue is the court of the defendant’s domicile at the date of filing (Code of Civil Procedure Art. 6(1)).

Two types of claim are possible:

• ▸ A claim that the decision is unlawful. The central question is whether the decision had a ground in the Regulation or the Listing Directive, was taken by the competent body within its time limits and followed the required procedure, such as the announcement of a halt with its reasons on KAP (Regulation Art. 25(4)) or a board decision for a halt longer than a month (Art. 25(2)).
• ▸ A damages claim. A person who causes loss to another by a culpable and unlawful act must compensate it (Code of Obligations Art. 49(1)). A damages claim against the exchange therefore requires showing an unlawful act, fault, loss and causation. A measure taken lawfully on a ground provided in the rules is not an unlawful act, however much it affects the holder.

Where waiting for a judgment would cause serious harm, an interim injunction may be sought. Under the Code of Civil Procedure, an interim injunction may be granted where there is concern that a change in the existing situation will make it considerably more difficult or impossible to obtain the right, or that delay will cause a disadvantage or serious damage (Code of Civil Procedure Art. 389(1)). The conditions and practice are explained in the guide to freezing assets and interim injunctions in Turkey.

Challenging an SPK decision

Decisions SPK takes itself, such as halting trading or delisting under Art. 69(2), trading bans and other measures under Art. 101(1), or approving the issue document in a squeeze-out, are administrative acts. They are challenged in the administrative courts. Unless a special law provides otherwise, the time limit for filing is sixty days, running from written notification of the act (Administrative Procedure Law Art. 7(1)–(2)). Where SPK acts on a request to the exchange, as under Art. 44(2) of the Exchange Activities Regulation, it is important to identify which body’s act caused the loss, because that determines whether the civil or the administrative courts have jurisdiction. Actions against SPK, including full-remedy actions for supervisory failures, are explained in the guide to suing SPK in the administrative courts.

The exchange’s dispute procedure for trades

A different procedure applies to disputes over exchange transactions themselves. The procedures for resolving disputes between investment firms, and between investment firms and their customers, that arise from order transmission and matching and from the timely performance of obligations in executed trades are set by the exchange’s board (Capital Markets Law Art. 70(1)). Under the Exchange Activities Regulation:

1. 1. Who decides. Disputes between exchange members, and disputes of the same kind between members and their customers on the customer’s application, are resolved by the exchange’s board, assisted by a Dispute Committee (Art. 47(1)).
2. 2. How to apply. The application is made by written petition and payment of the dispute service fee (Art. 48(1)).
3. 3. Time limit. Applications not made within two years of the date of the first exchange transaction in dispute are not examined (Art. 48(3)).
4. 4. Objection to SPK. Where the amount in the board’s decision exceeds the amount determined under Art. 84(5) of the Capital Markets Law, the parties may object to SPK through the exchange within fifteen days of notification; SPK’s decisions on the dispute are final (Regulation Art. 49; Capital Markets Law Art. 70(1)).
5. 5. Courts remain available. The parties’ right to apply to the courts is reserved (Art. 47(3)). If the complaint is withdrawn, the parties settle or a party goes to court or arbitration, the file is closed and a new application on the same dispute cannot be made (Art. 50(1) and (3)).

The Art. 84(5) amount is the maximum compensation payable by the Investor Compensation Center to each investor; the Law sets it at TRY 100,000 and increases it annually by the revaluation rate (Capital Markets Law Art. 84(5)), so the current figure should be checked for each year. Disputes with brokers and custodians that go beyond exchange transactions, such as mandate breaches or custody failures, are discussed in the guide to claims against brokers, custodians and portfolio managers.

Damages: who may be liable

The exchange is rarely the right defendant. When a share is halted, moved to the Watchlist Market or delisted because of facts that were hidden from investors, the loss usually traces back to the persons responsible for those facts. Turkish law provides several routes:

For claims based on public disclosure documents, causation is presumed where the instruments were bought or sold on the exchange after the misleading document was disclosed and sold or bought after the true information emerged (Capital Markets Law Art. 32(4)). A KAP announcement of a halt, a Watchlist transfer or a delisting is often the moment the true position becomes public, so its date matters for the calculation of loss and for the six-month limitation period. How loss is measured is explained in the guide to calculating damages in Turkish securities claims.

Points for institutional investors

• ▸ Monitoring. Exchange measures, market transfers, halts and delisting decisions are announced on KAP. Monitoring KAP for each holding, not only for issuer disclosures but also for exchange announcements, gives the earliest notice.
• ▸ Record keeping. Keep a dated record of every measure affecting a holding: the KAP text, the ground relied on, the start and end dates, and the trading data on those days. These records support later claims and help in valuation decisions.
• ▸ Watchlist triggers as signals. Several Watchlist grounds, such as qualified audit opinions, large related-party receivables and overdue debts, are also indicators of the problems that give rise to investor claims. A transfer is a reason to review the issuer’s disclosures and governance, and to consider evidence preservation.
• ▸ Squeeze-out deadlines. The two-month sell-out period is a forfeiture period. Custodians and sub-custodians must be instructed in time, and the request must cover all shares held.
• ▸ Price checks. In a squeeze-out, compare the price with the mandatory tender offer price where control has changed, and check whether periods affected by SPK action for manipulation have been excluded (Communiqué II-27.3 Art. 6(3)).
• ▸ Choosing the defendant. Separate the act of the exchange, which is challenged in the civil courts, from the act of SPK, which is challenged in the administrative courts, and from the conduct of the issuer, its managers and others, which is the usual basis for damages.
• ▸ Time limits. Limitation periods for the underlying claims continue to run during halts and after delisting. The guide to limitation periods for investor claims sets them out together.

Action plan

1. 1. Identify the act. Determine which body took the decision (exchange General Manager, exchange board or SPK), on which provision and on what date, using the KAP announcement.
2. 2. Check the conditions. Compare the stated ground with the Exchange Activities Regulation, the Listing Directive or the Capital Markets Law, and check the time limits, such as the one-month limit for a halt by the General Manager.
3. 3. Preserve evidence. Save KAP announcements, exchange bulletins, trading data and the issuer’s disclosures; where documents held by others are needed, consider evidence preservation before a lawsuit.
4. 4. Decide on a challenge. For an exchange decision, assess a civil action and interim relief; for an SPK decision, file in the administrative courts within sixty days of notification.
5. 5. Use the squeeze-out rights. If a dominant shareholder discloses 98 per cent, diarise the valuation summary date and the two-month sell-out period, instruct custodians and check the price calculation.
6. 6. Pursue the responsible persons. Where the measure revealed hidden problems, assess claims against the issuer, directors, auditors, manipulators and related parties, within their limitation periods.
7. 7. Follow the criminal file. Where the measure is connected with a manipulation investigation, consider a complaint and participation in the criminal proceedings to obtain access to evidence.

Time limits

Frequently asked questions

Who can halt trading in a Borsa Istanbul share?

The exchange’s General Manager may halt trading temporarily on the grounds in Art. 25(1) of the Exchange Activities Regulation, for up to one month; longer halts require a board decision. SPK also has its own power to halt trading (Capital Markets Law Art. 69(2)).

Must the exchange explain why trading was halted?

Yes. A temporary halt is announced on KAP together with its reasons and notified to SPK (Exchange Activities Regulation Art. 25(4)).

Does an issuer still have to disclose inside information while its shares are halted?

Yes. Communiqué II-15.1 expressly applies to issuers whose trading has been temporarily closed (Art. 2(1)).

What is the Watchlist Market on Borsa Istanbul?

It is the segment for shares of companies in which developments have occurred that could lead to removal from the main segments, such as qualified audit opinions, a concordat application or large related-party receivables (Listing Directive Arts. 4(1)(aa) and 35(1)). Shares there trade in single-price sessions with gross settlement and without short selling or margin trading (Equity Market Directive Art. 39(1)).

Can a share leave the Watchlist Market?

Yes, on the company’s application once the reasons for the transfer have ceased and all Sub-Market listing conditions are met; it moves to the Sub-Market first (Listing Directive Art. 36(1)).

On what grounds can a company be delisted?

The grounds include established disclosure failures, non-compliance with exchange rules, activities halted for over a year, bankruptcy, severe financial deterioration, unpaid fees, negative equity, three years of adverse or disclaimed audit opinions and related-party receivables above half of total assets for three years (Listing Directive Art. 23(1)).

Do I lose my shares if a company is delisted?

No. Forced delisting ends exchange trading but the shares and shareholder rights remain. After a squeeze-out, however, the minority’s shares are cancelled against payment of the squeeze-out price (Communiqué II-27.3 Art. 5).

Can a controlling shareholder simply take a listed company private?

Voluntary delisting takes place within SPK’s rules (Listing Directive Art. 27(1)). The principal route is the squeeze-out under Capital Markets Law Art. 27 and Communiqué II-27.3, which requires at least 98 per cent of the voting rights.

How long do I have to use the sell-out right?

Two months from the disclosure of the valuation report summary; the period is a forfeiture period (Communiqué II-27.3 Art. 5(1)).

How is the squeeze-out price set?

For listed companies, it is the higher of the average of the market price average and the valuation report value, and, where control changes at the same time, the mandatory tender offer price (Communiqué II-27.3 Art. 6(2)(a)).

Are manipulated prices used to set the squeeze-out price?

Periods on which SPK based action under Art. 101 or Art. 107 for manipulation, or a decision recognising extraordinary developments, are excluded, and the reference period is extended backwards by the same length (Communiqué II-27.3 Art. 6(3)).

Which court hears a challenge to a Borsa Istanbul decision?

The civil courts. Lawsuits against exchanges are heard by the ordinary courts (Capital Markets Law Art. 65(11)).

Which court hears a challenge to an SPK decision?

The administrative courts; the general time limit is sixty days from written notification (Administrative Procedure Law Art. 7).

Can I claim damages from the exchange for a trading halt?

Only if the halt was unlawful and the other conditions of tort liability are met (Code of Obligations Art. 49(1)). A halt taken lawfully on a ground in the rules does not give rise to damages; claims usually lie against the persons responsible for the facts that caused the halt.

How are disputes with a broker over exchange trades resolved?

The exchange’s board, assisted by a Dispute Committee, resolves them on application; above the Art. 84(5) amount an objection lies to SPK within fifteen days, and the right to go to court is reserved (Exchange Activities Regulation Arts. 47–50).

Can a delisted company be relisted?

Yes, on application, if the reasons for delisting have ceased and the conditions in Listing Directive Art. 28 are met; shares relisted under the full listing conditions start on the Sub-Market (Art. 28(3)(a)).

Related guides

• Turkey’s 2026 Fund and Market Manipulation Crisis: Legal Guide for Foreign Institutional Investors — the entry point to this series
• Mandatory Tender Offers in Turkey
• Market Manipulation under Turkish Law: Article 107
• Continuous Disclosure in Turkey: Communiqué II-15.1
• Shareholder Rights in Turkish Listed Companies
• Suing SPK in the Administrative Courts
• Insolvency in Turkey: Concordat, Bankruptcy and Client Assets
• Concealed Profit Transfer in Turkey
• Directors’ and Auditors’ Liability in Turkish Listed Companies
• Claims Against Brokers, Custodians and Portfolio Managers in Turkey
• Freezing Assets in Turkey for Investor Claims
• Social Media Manipulation and Unlicensed Investment Advice in Turkey