OECD Türkiye Report 2026: What Is Missing in Combating Foreign Bribery?

In June 2026, the OECD Working Group on Bribery published its “Phase 4 Follow-Up Report on Türkiye”, assessing the country’s progress in implementing the recommendations issued following its 2024 Phase 4 evaluation under the OECD Anti-Bribery Convention. The report evaluates Türkiye’s implementation of 71 recommendations aimed at strengthening its legal and institutional framework for preventing, detecting, investigating, and prosecuting foreign bribery.

The overall conclusion is striking. According to the OECD, Türkiye has fully implemented only 10 of the 71 recommendations, partially implemented 12, while 49 recommendations remain unimplemented.

While the report covers a broad range of issues, several findings stand out as the OECD’s highest priorities.

1. Whistleblower Protection Remains Absent

One of the OECD’s strongest criticisms concerns the continued absence of comprehensive whistleblower protection legislation covering both the public and private sectors.

The Working Group notes that it has been urging Türkiye to introduce such legislation since 2007, yet no draft law has been prepared and no realistic timeline has been established. According to the OECD, this significantly weakens the country’s ability to detect corruption and foreign bribery.

2. Corporate Liability Remains Inadequate

Another major concern relates to corporate liability.

The OECD concludes that Türkiye has not yet established an effective legal framework under which companies can be held liable independently of the conviction of natural persons. Similarly, no adequate framework exists for imposing corporate liability for accounting offences associated with foreign bribery. Although legislative amendments have been proposed, none have been enacted.

3. Limited Enforcement of Foreign Bribery Cases

Perhaps the report’s most significant finding concerns enforcement.

The OECD expresses serious concern that Türkiye has failed to demonstrate sufficient efforts to investigate and prosecute foreign bribery allegations. According to the report:

• Most known foreign bribery allegations have never been investigated.
• No new investigations or prosecutions have been initiated following the Phase 4 evaluation, despite additional allegations emerging.
• Türkiye still has no foreign bribery convictions.
• No specialised prosecutorial unit has yet been designated to handle foreign bribery cases.

For the OECD, this represents one of the most significant weaknesses in Türkiye’s anti-bribery enforcement framework.

4. Weak Mechanisms for Reporting Foreign Bribery Allegations

The report also highlights deficiencies in the mechanisms for transmitting foreign bribery allegations to prosecutors.

According to the OECD, Türkiye still lacks an effective system to ensure that allegations received by various public authorities are promptly communicated to prosecutors for investigation. This weakness continues to hinder timely and coordinated enforcement efforts.

5. Prevention Framework Requires Significant Improvement

Beyond enforcement, the OECD identifies substantial shortcomings in preventive measures.

Among the key concerns are:

• the absence of a comprehensive national anti-foreign bribery strategy;
• insufficient promotion of corporate compliance programmes;
• lack of guidance for external auditors on detecting foreign bribery;
• and the absence of mechanisms encouraging companies to voluntarily self-report foreign bribery.

Positive Developments

The report does not present an entirely negative picture. The OECD acknowledges several positive developments, particularly the training delivered over the past two years to public officials, tax inspectors, judges, and prosecutors on foreign bribery, the Ministry of Foreign Affairs’ updated guidance on combating foreign bribery, and the inclusion by MASAK of foreign bribery-related money laundering risks in Türkiye’s National Risk Assessment. However, the OECD concludes that these initiatives are not sufficient to address the country’s underlying legislative and structural deficiencies.

Conclusion

The OECD’s 2026 Follow-Up Report on Türkiye delivers a clear message that, in combating the bribery of foreign public officials, effective implementation is now more important than legislative reform alone.

The report concludes that Türkiye has made limited progress in several critical areas, particularly with respect to whistleblower protection, corporate liability, the effective investigation of foreign bribery allegations, and mechanisms for sharing information among competent authorities.

At the same time, while the OECD acknowledges positive developments in areas such as training and awareness-raising, it makes clear that its primary expectation is no longer the preparation of policy papers or draft legislation, but rather the adoption of effective legal reforms, the conduct of robust investigations, and the imposition of meaningful sanctions. In this respect, the report serves not only as a roadmap for public authorities but also as an important reminder for internationally active companies to strengthen their compliance programmes and enhance their management of foreign bribery risks.