Name
Global FinTech Guide
Country _ Name
Turkey
SectionTitle
Payment services
Body
FinTechs belonging to this category offer alternative payment services which are supposed to provide a faster and cheaper way for national, European, and international payments for private and business customers by using new technologies.

For example, payment service providers hereby offer solutions to easily integrate several payment services in online shops.

Some FinTechs furthermore provide real cash register systems and online-reservation solutions for restaurants and shops providing their own payment services or making use of the payment services of FinTechs described above.

Introduction

Attitude of the country towards modern payment services

The Law on Security Settlement Systems, Payment Services and Electronic Money Institutions No 6493 ('Payment Law') applies to payment systems, security settlement systems, payment institutions, and electronic money institutions operating in Türkiye. Only banks, digital banks and payment service providers authorised by the Central Bank of the Republic of Türkiye ('CBRT') are allowed to carry out payment services in Türkiye. In the last couple of years, the use of payments services has grown rapidly, making some of the FinTech companies fastest growing companies in Türkiye. The governmental approach to the payment services is positive and encouraging.


Legal affairs

Obligations and requirements to provide payment services or ancillary services described above

As per the Payment Law, payment system and securities settlement system can only be operated with a license acquired from the CBRT. Payment system is defined under the Payment Law as 'the structure that has common rules and provides the infrastructure required for clearing and settlement transactions carried out in order to realize fund transfers arising from transfer orders among three or more participants' and securities settlement system is defined as 'the structure that has common rules and provides the infrastructure required for the clearing and settlement transactions carried out in order to realize securities transfers arising from transfer orders among three or more participants'.
Moreover, the following activities are defined as payment services under Article 12 of the Payment Law:

  • All the transactions required for operating a payment account including the services enabling cash to be placed on and withdrawn from a payment account.
  • Execution of payment transactions, including transfers of funds on a payment account with the user's payment service provider, direct debits, including one-off direct debits, payment transactions through a payment card or a similar device, credit transfers including standing orders.
  • Issuing or acquiring payment instruments.
  • Money remittance.
  • Execution of payment transaction, where the consent of the payer to execute a payment transaction is given by means of any telecommunication, digital or IT device and the payment is made to the telecommunication, IT system or network operator, acting only as an intermediary between the payment service user and the supplier of the goods and services.
  • Corresponding services enabling bill payments.
  • At the request of the payment service user, the payment initiation service related to the payment account at another payment service provider.
  • Upon approval of the payment service user, the online provision of consolidated information of one or more payment accounts held at payment service providers by payment service users.
  • Other transactions and services reaching the level to be determined by the Bank in terms of total size or impact in payments.
Payment services, above, can only be provided by banks or payment service providers (banks, electronic money institutions, payments institutions and Posta ve Telgraf Teskilati Anonim Sirketi). According to the Payment Law, payment institutions are legal persons authorised pursuant to the Payment Law to provide and execute payment services.

As per Article 4 of the Payment Law, only companies incorporated in Türkiyecan provide payment services by obtaining a license from the CBRT.

According to the Regulation on Payment Services and Electronic Money Issuance and Payment Service Providers ("Regulation"), the licensing application is conducted in three phases. In the first phase, obtaining an operating permit and commercial title from the CBRT is required; subsequently, the process proceeds to the document review stage, where the documents specified in Article 11/4 of the Regulation are prepared and submitted to the CBRT. In the final stage, known as the approval phase, the CBRT completes the document review and provides written notification to the company regarding the approval. Following this notification, the application for the final approval stage is submitted to the CBRT within 20 days at the latest. During the final approval stage, compliance with the requirements specified in the Regulation is verified through a petition. Once the necessary technical and document reviews confirm compliance with the statutory requirements, the license can be obtained.

Operating Permit Application Phase:
It is mandatory for the company applying for the license to have indications in its title indicating that it is a payment institution or an electronic money institution. Before the company name containing these indications is registered in the trade registry, the notification letter and forms specified in Annex-11-A, Annex-11-B, Annex-11-C, and Annex-11-D of the Regulation must be submitted to the CBRT to initiate the application process. Along with the notification letter, a draft of the articles of association and the application form, a receipt showing the payment of the application fee of TRY 500,000 (approx. EUR 10,666) and the relevant statutory obligations to be paid must be attached to the designated account determined by the CBRT. A document confirming that the application has been made is issued by the CBRT and delivered to the applicant. Within 6 months following the notification of the document to the applicant by the CBRT, an application must be made to the CBRT for the informative review (documentation phase).

Documentation Phase: The following documents must be submitted with the request for the license:

  • The decision of the board of directors to apply for an operating permit,
  • Activity program and business plan signed by the members of the board of directors and the general manager of the company, explaining in detail the matters in Annex-1 of the Regulation regarding the activities planned to be carried out with the applicant company and t the answers to the questions in Annex-10 of the Regulation and the organisational structure created for the realisation of these activities,
  • The latest independently audited financial statements of the company, in case the capital increase has been made after the preparation of the financial statements, a report approved by Certified Public Accountants, according to the Law on Certified Public Accountant and Sworn-in Certified Public Accountant numbered 3568, stating that the capital has been paid in cash and free of all kinds of collusion,
  • A declaration to be prepared and signed before a notary public by the partners holding qualified shares and exercising control, in accordance with the samples in Annex-2 and Annex-3 of Regulation.
  • An explanation regarding the publication of the company’s articles of association in the Official Gazette of the Republic of Türkiye, along with a sample of the form submitted to the CBRT in accordance with the first paragraph, and a sample of the document prepared by the CBRT within this scope, as well as an explanation regarding the registration procedures carried out following the submission of the form to the Bank.
  • Description of the rules and definitions to be applied in collecting statistical data on executed transactions, performance outcomes, and fraudulent activities,
  • Undertakings that restructuring applications through reconciliation have not been approved and no decision has been made to defer bankruptcy regarding the legal entity shareholders of the company and the legal entities controlling the company, and undertakings that the capital of the company has been funded from its own sources and has been provided and deposited in cash without any form of collusion, along with relevant bankruptcy concordat documents obtained from the relevant trade registry directorate regarding these individuals and the companies in which they directly hold at least %33 ownership, and documents related to Findeks credit ratings (Annex-4)
  • Undertakings regarding the non-approval of restructuring applications through reconciliation and the absence of decisions to postpone bankruptcy proceedings for the company and the legal entity shareholders controlling the company, along with assurances that the company’s capital has been funded from its own resources and has been provided and deposited in cash, free from any kind of collusion, and relevant documents such as the bankruptcy-concordat certificate obtained from the relevant trade registry directorate for these individuals and the companies in which they directly hold at least thirty-three percent, along with documents related to Findeks credit rating (Annex- 5),
  • Undertaking of real person shareholders with direct or indirect shares of ten percent or more and real persons holding the control that they are not convicted of the crimes specified in subparagraph (d) of the first paragraph of Article 8 of the Law No. 5411, and criminal record documents containing archive records (Annex-6),
  • Undertaking of the shareholders of the company, who have direct or indirect shares of ten percent or more, and the real and legal persons holding the control that they do not have a direct or indirect share of ten percent or more or does not have control in the banks, where Article 71 of Law No. 5411 is applied or banks that were transferred to the Savings Deposit Insurance Fund before the Law No. 5411 came into force, and documents to be obtained from the Savings
Approval Phase: If the document review phase is approved by the CBRT, an application for final approval must be submitted to the CBRT within 20 days after the written notification of approval. The CBRT is authorized to extend the 20-day period up to 60 days upon the reasonable justification provided by the applicant company. During the final approval phase, an examination is conducted to determine whether the conditions specified in the Regulation are met. In this regard, for example, whether the company's capital has been paid in cash free from any encumbrances, whether the minimum equity capital requirement has been met, whether appropriate internal control, risk management, accounting, information systems, and reporting systems have been established, whether an adequate personnel structure has been established for these units, whether job descriptions and authorities and responsibilities of personnel have been determined, whether necessary measures have been taken for the continuity of activities, information security, and confidentiality, and whether procedures for monitoring, addressing, and tracking security incidents and customer complaints have been established are examined.

In addition, in the event that the partners of the company with a direct or indirect share of ten percent or more and the partners holding the control are a bank or financial institution established abroad:

  • Samples of decisions taken from authorised bodies regarding operating in Türkiye,
  • Consolidated independent audit report for the last year,
  • The document obtained from the competent supervisory authority stating that it is not prohibited from operating in the country where it is established or operates, or that there is no restriction on its activities,
  • Detailed information and documents about the fields of activity, organisational structure, organisational structure in and outside the country where it is established, its activities in international financial markets as specified in its Articles of Association, and, if any, the report prepared by the rating companies and including the predicted rating.
According to Article 15 of the Payment Law, the application should be resulted within 6 months. However, this time period is not definite and may take longer based on complexity of the structure. Also, the CBRT may request additional information and documents, which may extend the period. As per Article 14 of the Payment Law, the minimum capital for payment institutions is TRY 1 million (approx. EUR 21,333) for institutions exclusively carrying out their businesses on bill payment intermediation, TRY 2 million (approx. EUR 42,666) for other payment services, TRY 5 million (approx. EUR 106,666) for issuing electronic money and TRY 5 million (approx. EUR 106,666) for system operators.
Application for license to CBRT is free of charge. However, the cost may be as much as EUR 15.000 or more including incorporation, translation of documents, notary public fees, legal fees, and other ancillary costs. Also, the minimum capital requirements apply.

Additional comments regarding the legal situation for payment services or what FinTech’s must be aware of in this business area
As per Article 23 of the Payment Law, the system operator, payment institutions and electronic money institutions shall be required to keep all the documents and records related to the matters within the scope of this Law for at least ten years in Türkiye, in a secure and accessible manner.
Moreover, Article 16 of the Communique on Management and Supervision of Information Systems of Payment Institutions and Electronic Money Institutions, all primary and secondary systems must be kept in Türkiye.


Economic conditions

Market size for payment services and biggest payment service providers

According to the World Bank’s data on GDP growth, Türkiye is observed to be the second fastest growing country among the OECD member states with a growth rate of %5.27 over the past 10 years. It’s GDP ranks 7th in Europe and 1st in the Middle East and North Africa Region according to IMF’s 2025 data. . According to the TürkiyeFintech Ecosystem Status Report for 2024 published by Presidency of the Republic of TürkiyeFinance Office, as of February 2025, there are reportedly 731 active FinTech companies operating in Türkiye. In 2024, the Turkish FinTech ecosystem attracted a total investment of USD 194 million. Among the most notable transactions were the investments in Paynet and Midas, which secured USD 87 million and USD 45 million, respectively. According to the CBRT’s data there are 27 payment services FinTechs and 65 e-money FinTechs, a total of 92 accredited payment and e-money service providers as of July 2025.

Additional comments regarding the economic situation for payment services or what FinTech’s must be aware of in this business area

The benefits of the Turkish FinTech market cannot be underestimated since the industry of financial technology in Türkiyeis not mature and regarding its economic volume, still seems to be limited at this stage. By having this economic volume, this implies an asset which provides lots of possibilities for creativity and development in new technologies and FinTech industry.
FinTech start-ups, which produce creative, innovative, and sometimes disruptive solutions thanks to the use of technology in the financial services sector, are demanding in Türkiyeas well as all over the world.



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