Regulatory AlertsTurkey: fintech & payments regulation
RegulatedTurkey: CBRT regulates payments/crypto; CMB regulates capital markets; strict licensing required
- Lead regulator
- Central Bank of the Republic of Turkey (CBRT)
- Also involved
- CMB (capital markets/crowdfunding) · MASAK (AML/CFT supervision)
- Core law
- Payment and Securities Settlement Systems Law No. 6493 (2013)
- Entry capital
- TRY 5m (Payment Institution); TRY 50m (Payment Service Provider)
- Approval timeline
- 6-12 months for full licensing; 3-6 months for approval-in-principle
- Customer assets
- Segregated accounts required; commingling prohibited
- Data protection
- KVKK (Law No. 6698) · Personal Data Protection Authority (KVKK)
- Sandbox
- Yes - CBRT Regulatory Sandbox
Turkey maintains a strict, dual-track regulatory environment for fintech. The Central Bank (CBRT) exclusively governs payment institutions, e-money institutions, and crypto asset service providers under Law No. 6493 and subsequent Communiqués. The Capital Markets Board (CMB) regulates capital market activities, including equity crowdfunding and investment firms, under Law No. 6362. The regime is characterized by high capital requirements, mandatory local infrastructure, and a prohibition on unlicensed crypto trading services for retail users.
Which licence do you need?
| Your activity | Requirement | Capital | Timeline | Authority |
|---|---|---|---|---|
| Payment processing / gateway | LicencePayment Institution / Payment Service Provider Must establish local payment system infrastructure | TRY 5m (PI) / TRY 50m (PSP) | 6-12 months | CBRT |
| E-money & wallet issuance | LicenceE-Money Institution Issuance of electronic money requires specific license | TRY 5m | 6-12 months | CBRT |
| Domestic money transfer | LicencePayment Institution Domestic transfers fall under payment institution scope | TRY 5m | 6-12 months | CBRT |
| Cross-border remittance | LicencePayment Institution / Payment Service Provider Cross-border payments require CBRT authorization | TRY 5m / TRY 50m | 6-12 months | CBRT |
| Agent network | LicencePayment Institution Agent networks must be authorized by the licensed PI | TRY 5m | 6-12 months | CBRT |
| Open banking / account information | LicencePayment Institution / E-Money Institution API access requires CBRT approval under Open Banking Regulation | TRY 5m | 6-12 months | CBRT |
| Foreign-exchange services | LicencePayment Institution / Payment Service Provider FX services are part of payment services; strict capital applies | TRY 5m / TRY 50m | 6-12 months | CBRT |
New — what changed recently
- 2023-06-01Communiqué on Crypto Asset Service Providers — CBRT mandated licensing for crypto asset service providers, prohibiting unlicensed trading and custody services.
- 2022-01-01Open Banking Regulation Implementation — CBRT enforced mandatory API standards for banks and payment institutions to enable third-party access.
- 2021-09-01CMB Equity Crowdfunding Communiqué — CMB established specific licensing and capital requirements for equity crowdfunding platforms.
Market-entry checklist
- 1Secure CBRT LicenseApply for Payment Institution or E-Money Institution license with TRY 5m+ capital.
- 2Establish Local InfrastructureSet up payment system infrastructure within Turkey as mandated by Law No. 6493.
- 3Register with MASAKRegister as a reporting entity with the Financial Crimes Investigation Board for AML/CFT compliance.
- 4Comply with KVKKImplement data protection measures aligned with the Personal Data Protection Law and register with KVKK.
- 5Obtain CMB Approval (if applicable)If offering equity crowdfunding, secure CMB license and meet TRY 5m capital requirement.