Payment and E-Money Licensing in Turkey: A Guide for Founders

If your product moves other people’s money in Turkey — collecting card payments for merchants, holding wallet balances, sending remittances or initiating payments from bank accounts — you almost certainly fall under Law No. 6493 and need either a licence from the Central Bank of the Republic of Türkiye (CBRT, Turkish: TCMB) or a licensed partner. This guide explains the regime for foreign investors and founders. It is a map, not legal advice; a Turkish regulatory counsel is indispensable before filing.

The legal framework in brief

Date	Instrument	What it did
27 June 2013	Law No. 6493 (Official Gazette 28690)	Created the payment institution and e-money institution licences; supervision originally sat with BDDK
22 Nov 2019	Law No. 7192	Transferred licensing and supervision from BDDK to the CBRT, applied from 1 January 2020
1 Dec 2021	CBRT Regulation on Payment Services and E-Money Issuance (Official Gazette 31676)	Rewrote licensing, capital, shareholder and operating rules; defined payment initiation and account information services
1 Dec 2021	CBRT Communiqué on information systems and data sharing services	Set IT requirements and the open banking API framework (ÖHVPS)
31 Jan 2026	CBRT Communiqué on minimum equity (Official Gazette 33154)	Raised minimum equity from 30 June 2026

Since 2020, the CBRT is therefore a single point of contact for licensing, supervision and the payment systems (FAST, EFT, TR QR code) that licensed firms connect to. Membership of TÖDEB, the Payment and Electronic Money Institutions Association of Türkiye, is mandatory for licensed institutions.

Two licences: payment institution vs e-money institution

Capability	Payment institution	E-money institution
Payment processing (virtual POS, transfers)	Yes	Yes
Persistent customer balance (wallet)	No	Yes
Balance-holding prepaid cards	No	Yes
Account information / payment initiation (if in scope)	Yes	Yes
Taking deposits or lending	No	No

The practical test: if money sits in a customer balance beyond the time needed to execute a payment, you are issuing electronic money. E-money balances are not deposits and are not covered by deposit insurance; instead, e-money institutions must safeguard customer funds in segregated accounts. Deposit taking and lending require a bank licence from BDDK (including the newer branchless digital bank licence).

The service list: (a) to (g)

The CBRT registers show, for each licensed firm, which payment services it is authorised to provide. The letters follow the Turkish alphabet, so there is a “ç” between (c) and (d):

Code	Payment service
(a)	Services enabling cash to be placed on a payment account and all operations required for operating a payment account
(b)	Services enabling cash withdrawals from a payment account and all operations required for operating a payment account
(c)	Issuing or acquiring payment instruments (the CBRT notes that a (c) authorisation may be limited to acquiring only)
(ç)	Money remittance
(d)	Payment transactions where consent is given via a telecom/IT device and payment is made to the operator
(e)	Intermediation of bill payments
(f)	Payment initiation service
(g)	Account information service

E-money institutions additionally hold the right to issue electronic money under Article 18(2) of Law 6493. A licence is only as wide as its authorised services: a firm licensed for (c) acquiring cannot launch remittances without an extension. Open banking providers need (f) and/or (g); see open banking and instant payments in Turkey.

Minimum equity in 2026

The CBRT sets minimum equity by communiqué and has raised it twice in two years to keep pace with inflation:

Institution type	From 30 June 2025	From 30 June 2026
Payment institution intermediating only bill payments	TRY 15 million	TRY 20 million
Other payment institutions	TRY 30 million	TRY 40 million
Electronic money institutions	TRY 80 million	TRY 105 million

Sources: CBRT communiqué published 30 January 2025 (reported by Anadolu Agency); CBRT communiqué in Official Gazette 33154 of 31 January 2026 (summarised by Esin Attorney Partnership). According to the same summary, an institution that falls short may be given a reasonable period of up to six months to remedy it, during which its licence can be suspended, and the licence can be revoked if the shortfall is not cured.

Plan for the TRY figure to rise again: a business plan that just clears today’s threshold may not clear next year’s.

How to apply: the practical path

The formal requirements come from Law 6493 and the 2021 Regulation. In practice, an application covers the following building blocks:

1. Corporate form. A Turkish joint-stock company (anonim şirket) with registered shares, capital paid in cash.
2. Qualifying shareholders. Shareholders holding 10% or more must meet the fit-and-proper criteria applied to bank founders under the Banking Law. Foreign parents should prepare to document the full ownership chain and source of funds.
3. Management and staff. Qualified board and senior management, adequate personnel, internal control, risk management and a complaints function.
4. Information systems. IT and security infrastructure meeting the CBRT’s information systems communiqué, typically evidenced by independent audit reports. Cross-border data transfer rules (KVKK Article 9, amended in 2024) affect cloud architecture.
5. Safeguarding. A funds-protection model for customer money.
6. AML/KYC. Policies aligned with MASAK rules. Since the September 2026 amendment, remote onboarding may use biometrics and NFC chip verification, and foreign nationals can be onboarded with an ICAO 9303-compliant NFC passport.

The CBRT reviews the file and can consult other bodies such as MASAK; once licensed, the firm appears on the CBRT’s public register with its authorised services. Preparation plus review commonly takes many months and often more than a year. Many foreign founders therefore validate the product on a licensed partner’s rails first (a Turkish e-money institution’s API or a bank’s banking-as-a-service offering) and file for their own licence once volume justifies it.

Acquiring an existing licensed company is another route; it still requires regulatory approval of the new qualifying shareholders and, above certain thresholds, Competition Authority clearance. In May 2025, for example, Albaraka Türk acquired a majority stake in the licensed payment institution Valenspara via a venture capital fund after Competition Authority approval (Webrazzi).

How many licensed firms are there?

Register	Active	Revoked (listed separately)	Ended by merger	Snapshot
Payment institutions	20	10	2	25 Sep 2026
Electronic money institutions	55	14	1	25 Sep 2026

At year-end 2025 the registers showed 24 payment institutions and 62 e-money institutions. The drop in 2026 is mostly enforcement: the CBRT revoked the licences of Payco and Junomoney (Official Gazette, 26 August 2026), TRPOS (9 September 2026) and Papel (23 September 2026). Some revocations were linked to illegal betting and money-laundering investigations. A revocation can also be reversed: Papara’s licence was revoked on 31 October 2025 and reinstated on 21 January 2026 after a court stay.

The CBRT register also marks some services with a red cross rather than a tick, without explanation on the page; we read this as a suspended or restricted service. Always check the live register before signing with a partner. The Turkish licence lookup and e-money register mirror the CBRT lists with dates.

Adjacent licences you may need

Product	Licence	Authority
Deposits, loans, BaaS	Bank or digital bank	BDDK
Consumer finance / BNPL	Financing company or bank partnership	BDDK
Brokerage, investment apps	Investment firm licence	SPK
Crowdfunding platform	Listing by SPK	SPK
Crypto exchange or custody	Crypto asset service provider authorisation	SPK

Crypto and payments do not mix: since 30 April 2021, payment and e-money institutions may not intermediate for crypto platforms, and crypto may not be used for payments (CBRT regulation, Official Gazette 31456).

Founder checklist

• Draw every money flow and ask “whose account does the money sit in, and for how long?”
• Decide between partner-first and licence-first before fundraising; budget for rising equity floors.
• Map your service letters (a)–(g) to the product roadmap so you do not need an extension on day one.
• Budget for IT audit, AML and safeguarding from the start, not after the MVP.
• Track the regulation timeline and the Turkish regulation tracker; secondary rules change several times a year.

For market context, see Turkey fintech market 2026 in numbers.