In line with the rapid expansion of electronic commerce, online food ordering services have evolved into a strategically significant market for both consumers and service providers. In response to this development, the Ministry of Trade has introduced a comprehensive new regulatory framework governing food ordering platforms, with the explicit objective of establishing a more transparent, equitable, and competition-driven market structure.

Under this regulation, electronic commerce platforms acting as intermediaries in food ordering services are subject to enhanced transparency and disclosure obligations. In particular, restaurants must be provided with a clear and fully transparent breakdown of all charges, without ambiguity, grouped into distinct categories such as commissions, delivery fees, visibility services, and other related items. These details must be clearly displayed within each restaurant’s dedicated seller panel. This marks a significant shift, enabling restaurants to access, for the first time, granular and verifiable insight into the cost structure applied by platforms, thereby facilitating more informed, predictable, and strategically sound commercial decision-making, including pricing strategies, promotional participation, and platform selection.

Transparency obligations are not confined to merchant-side disclosures but are also extended to the consumer interface. At the order confirmation stage, consumers must be clearly and unequivocally informed that the total amount payable may not solely reflect the product price, but may also include additional service-related components such as commissions, delivery fees, and visibility charges. This requirement is designed to enhance pricing transparency at the point of transaction and to strengthen consumer trust in platform-based services.

A further cornerstone of the regulation relates to the standardization of commission calculation methodologies. The new framework establishes a structured and uniform approach as follows:

• Where no discount is applied, commissions shall be calculated directly on the base product price.
• Where a discount is funded exclusively by the restaurant, commissions shall be calculated on the actual amount paid by the consumer.
• Where both the platform and the restaurant contribute to a discount, commissions shall be calculated on the consumer-paid amount, increased by the portion of the discount subsidized by the platform.

This standardized methodology is intended to eliminate prior uncertainties and inconsistencies in commission determination during promotional and discounted sales periods, thereby ensuring predictability and legal clarity.

In parallel, the regulation significantly reinforces the commercial autonomy of restaurants. Platforms are expressly prohibited from compelling restaurants to participate in additional services, promotional campaigns, discount schemes, or advertising activities. Furthermore, any adverse treatment, restriction, or sanction arising from a restaurant’s refusal to participate in such initiatives is strictly prohibited.

Overall, the regulatory framework introduced by the Ministry of Trade seeks to recalibrate the operational balance within online food ordering ecosystems by strengthening transparency, predictability, and fairness across all stakeholders. Platforms are now required to provide full itemization and disclosure of all service-related charges, while the imposition of additional fees for core intermediary services is effectively restricted. Participation in campaigns, discounts, and advertising activities has been firmly anchored in voluntary consent, thereby reinforcing the commercial independence of restaurants. Commission structures in discounted transactions have been standardized under a unified methodology, and all supplementary services and associated fees are now subject to prior disclosure and explicit merchant approval. On the consumer side, mandatory pre-contractual disclosure obligations ensure that pricing transparency is fully embedded at the point of purchase, extending the principles of clarity and accountability across the entire transactional chain.

@Çağla BARUT