PROVIDING PAYMENT/E-MONEY SERVICES IN TÜRKİYE?
STEPS TO BE FOLLOWED TO OBTAIN AN OPERATING LICENCE OF PAYMENT AND E-MONEY INSTITUTION
With the rapid rise of fintech investments in Türkiye, the payments industry has undergone significant growth. As a result, many companies seeking to operate as licensed payment or e-money institutions are now asking the critical question: How can we legally start operations in Türkiye? To do so, companies must complete a formal licensing process governed by Turkish financial regulations. This article provides a step-by-step overview of how to obtain an operating license in Türkiye.
For companies considering providing cross-border payment services without a license, please refer to our article on the "international cooperation" model, which outlines how global institutions may operate under Turkish law without direct licensing.
1.Scope Of Legal Regulations and Competent Authority
Law No. 6493 on Payment and Securities Settlement Systems, Payment Services and E-money Institutions (the “Law”), enacted in 2016, serves as the principal legal framework for licensing and regulating payment and e-money institutions (“Institutions”) in Türkiye. The Law is supplemented by the Regulation on Payment Services and E-money Issuance and Payment Service Providers (the “Regulation”), which sets forth the secondary legal framework.
The Central Bank of the Republic of Türkiye (“CBRT”) is designated as the competent regulatory authority responsible for granting operating licenses to Institutions. In addition to licensing, CBRT is authorized to supervise institutional compliance, conduct audits, and suspend or revoke licenses where necessary.
2.Services That Can Be Provided Under The Law
The services regulated under the Law can be examined under two headings as "payment services" and "e-money services". Institutions authorized to provide only payment services referred as “Payment Institutions”; institutions authorized to provide e-money services referred as “E-Money Institutions”.
In accordance with the systematics of the Law, payment services are regulated in Article 12 of the Law and e-money issuance is regulated in Article 18 of the Law. When applying, Institutions must specify the particular services they intend to provide, referencing the relevant subparagraphs of Article 12 and Article 18.
2.1. Payment Services
Although the Law does not define “payment services” directly, Article 12 provides an exhaustive list of services considered as such. These include:
- Operation of a payment account
- Transfers related to a payment account
- Issuance and acceptance of payment instruments
- Mobile payments / DCB (direct carrier billing)
- Invoice payment services
- Open Banking services (payment initiation and consolidated account services)
2.2. E-money Issuance
Within the scope of the Law, e-money issuance is the creation of monetary value that is stored electronically and used for payment purposes by people other than the issuer, by accepting funds in return. E-money services are the entirety of activities that enable the issuance, distribution, storage, repayment and use of e-money in payment transactions. These services enable the circulation of e-money in the market as a means of payment and enable electronic money to function within the financial system. Notably, the issuance of e-money is not considered a payment service in itself.
2.3. Activity Limitation and Exceptional Services under the Law
Institutions are subject to activity restrictions within the scope of the Law. In other words, Institutions can only provide services regulated by the Law and for which they have received permission from CBRT; they cannot engage in other commercial activities.
However, an exception is regulated for Institutions with Article 15 of the Regulation, which regulates certain activities that can be provided other than payment services and e-money issuance.
These activities are briefly as follows:
- Services where technical service providers do not own the transferred funds at any point in the transaction
- Services within the scope of limited network exception
- Payment transactions between representatives or branches
- Payments made between the parent company and its subsidiaries or between subsidiaries
- Ancillary services that are complementary to payment services such as processing of card data, preventing abuse and fraud, which secure and facilitate payments
- Value-added services and qualified services defined in the Regulation
- Training and consultancy services related to payment services.
- Services to be provided as an interface provider within the scope of digital banking legislation
- Ancillary services that may increase the use of the Institution's payment services, such as routing to the systems of another financial institution
- Services to be provided within the scope of mediating activities related to the purchase and sale of precious metals and precious stones, subject to the amount limits set out in the Regulation.
3.Eligibility Criteria for Application
To be eligible to apply for a license from CBRT, an Institution must meet the following requirements:
- Be established as a joint stock company (A.Ş.)
- Fulfilling the minimum capital requirement (find details in section 5.2.)
- Ensure that any shareholder with a 10% or greater interest, or with controlling influence, meets the qualifications for bank founders under Law No. 5411
- Have all shares issued for cash and fully registered
- Meet the minimum capital requirement, as specified in CBRT’s financial thresholds (provided in the annex)
- Maintain an organizational structure with qualified management, sufficient personnel, and the technical infrastructure to support operations
- Establish a functioning complaints and objections unit
- Implement measures to ensure continuity, data security, and confidentiality in service delivery
- Maintain a transparent shareholding structure and organizational chart that facilitates regulatory oversight
4.Stages of the Licensing Process
The licensing process consists of three distinct phases:
4.1. Incorporation and Notification Application
As stated in Section 3, Institutions must be established as joint stock companies. In this context, a joint stock company must first be incorporated in order to apply for an operating license to CBRT.
Following the establishment of the applicant company, the company's title, purpose and subject must be amended in accordance with the payment and e-money services at the trade registry office. Before this change, a notification must be made to CBRT and a letter stating that the application has been made must be received from CBRT.
If CBRT confirms the completeness of the preliminary application, it will issue a confirmation letter. This letter enables the applicant company to proceed with registration before the Trade Registry Directorate, using a trade name that includes the legally mandated designation as a "payment institution" or "e-money institution."
4.2. Investigation Application
Within six months following the initial confirmation, the applicant company must reapply to CBRT to initiate the investigative review. CBRT requires submission of detailed documentation, including:
- Organizational structure
- Technical workflows and IT architecture
- Internal policy documents
- Business plans and compliance procedures
Following a thorough review, CBRT issues a decision regarding the inspection results.
4.3. Final Approval Application
No later than 120 days after receiving inspection approval, the applicant company must submit a final application to CBRT. At this stage, the following must be completed:
- The applicant company’s systems and staff must be fully operational and ready for live deployment
- An independent audit report and a facility inspection report must be submitted
- The license fee must be paid, and (if applicable) professional liability insurance or a collateral deposit must be provided
- Documentation verifying compliance with minimum equity requirements must be included
Following the document review, CBRT will conduct an on-site inspection to assess the physical and technical readiness of the applicant company. If all conditions are met, CBRT will grant an operating license to the applicant company. The license becomes effective upon publication in the Official Gazette.
Please be noted that Institutions must notify CBRT within 10 days of the actual commencement of operations.
5.Application Fees, Capital, Equity and Guarantee Requirements
The financial requirements applicable to Institutions vary based on the type and scope of the services intended to be offered. Below is a breakdown of the key financial thresholds that must be met, depending on the classification of the Institution:
5.1. Application and License Fees
Regardless of the scope of the license, all applicants are subject to the same initial costs:
Application Fee: 500,000 TL + %5 Banking and Insurance Transactions Tax
License Fee: 1,000,000 TL + 5 Banking and Insurance Transactions Tax
These fees apply uniformly to all applicants, including those seeking to provide consolidated account services, invoice payment intermediation, standard payment services, or e-money issuance.
5.2. Minimum Capital Requirements
The minimum paid-in capital required varies according to the license scope:
Institutions providing only consolidated account services: Not applicable (N/A)
Institutions providing payment order initiation services: 2,000,000 TL
Institutions providing only invoice payment intermediation: 1,000,000 TL
Payment Institutions: 2,000,000 TL
E-money Institutions: 5,000,000 TL
5.3. Minimum Equity Requirement
Institutions are required to maintain a minimum equity, which may scale based on the volume of payment transactions processed:
Institutions providing only consolidated account services: Not applicable (N/A)
Institutions providing payment order initiation services: 30,000,000 TL
Institutions providing only invoice payment intermediation: 15,000,000 TL
Payment Institutions: 30,000,000 TL
E-money Institutions: 80,000,000 TL
Please be noted that CBRT has the authority to determine the minimum equity obligation and in practice, this amount is determined every January. The above-mentioned amounts are the amounts determined in January 2025 and will enter into force as of 30/6/2025.
5.4. Minimum Guarantee
A mandatory financial guarantee must be deposited or professional liability insurance must be obtained. The required amounts vary by license scope:
Institutions providing only consolidated account service institutions: 1,000,000 TL (via deposit or insurance)
Institutions providing payment order initiation services: 3,000,000 TL
Invoice payment intermediary institutions: 2,000,000 TL
Payment Institutions: 3,000,000 TL
E-money Institutions: 5,000,000 TL
Please be noted that there are additional regulations that determine the calculation of this liability depending on the number of customers.
5.5. Professional Liability Insurance
Professional liability insurance is not mandatory for most categories, provided that the minimum guarantee is deposited with CBRT. However, there is a specific exception:
Institutions providing only consolidated account services are allowed to substitute the guarantee requirement by maintaining professional liability insurance of equivalent value (1,000,000 TL), instead of depositing a financial guarantee.
For all other Institutions, the required guarantee must be deposited in accordance with the methods specified in the legislation; professional liability insurance cannot be used as an alternative.
6.Conclusion
While Türkiye offers an expanding market for payment and e-money services, obtaining a license involves a highly structured and regulated process. Companies should seek legal and technical guidance early in the application process to ensure full compliance with CBRT expectations.
As we discussed in our article, in order to operate as a payment and e-money institution in Türkiye, companies must fulfill the conditions that are strictly regulated by the legislation which detailed in our article, and these conditions must be maintained throughout their operations.
If you are considering launching a licensed payment or e-money institution in Türkiye or wish to explore alternative cross-border models, our team is available to assist with structuring, documentation, and regulatory liaison.
For more information on this subject, please contact our attorneys, Mr. Gokhan Ugur Bagci and Mr. Ömer Büyüktosun.