Name
Global FinTech Guide
Country _ Name
Turkey
SectionTitle
DLT and cryptocurrencies
Body
FinTechs belonging to this category offer financial services using crypto currencies. This category also includes FinTechs utilising blockchain and distributed ledger technologies (DLT) upon which Bitcoin and Ethereum are based, among others. FinTechs develop and do research in this field in order to create new services – e.g. crypto currency exchange markets, wallet providers, NFTs-related services, new payment services, "smart contracts" or new clearing and settling services.

Introduction

Attitude of the country towards financial services using crypto currencies

On 16 April 2021, the CBRT published the country's first crypto-asset regulation, Regulation on the Use of Crypto-Assets in Payments, effective 30 April 2021, in Official Gazette numbered 314561. According to the regulation:

  • Crypto-assets cannot be used, directly or indirectly, to purchase goods and services in Türkiye.
  • Crypto-assets cannot be used in the provision of payment services or issuance of e-money.
  • Intermediary financial services to crypto-asset platforms and service providers, including funds transfers, and custodial, settlement, and issuance services are prohibited.
  • Development of financial services business models involving crypto-assets is prohibited.
Having said that, on 2 July 2024, the Law on Amendments to the CML No. 7518 ('Crypto Law') was published in Official Gazette numbered 32590. Pursuant to the Crypto Law, the CMB is the regulatory and supervisory authority over crypto asset service providers ('CASPs'). Additionally, on 13 March 2025, the secondary legislation applicable to CASPs (specifically Communiqué No. III-35/B.1, Communiqué No. III-35/B.2, Communiqué No. VII-128.10, and Communiqué No. III-62.2.b) have been published.

In its announcement dated 5 August 2024, the CMB, published the “List of Operating Entities” on its official website for entities that had submitted applications under the CMB’s 2 July 2024 announcement. The CMB also clarified that inclusion in the “List of Operating Entities” does not imply regulatory authorization under the applicable legislation. The entities on this list must submit a separate application for authorization once the secondary legislation comes into effect.

In this regard, the entities listed in the “List of Operating Entities” published by the CMB were required to apply for an operating license by 30 June 2025, by fulfilling the operational requirements set by the CMB. The entities that fail to apply by this deadline shall be subject to the liquidation provisions.


Legal affairs

Obligations and requirements to provide financial services using crypto currencies described above

CASPs are regulated under the Crypto Law and the secondary legislation. The Communiqué on the Establishment and Operating Principles of Crypto Asset Service Providers (‘Communiqué No. III-35/B.1’) and the Communiqué on the Operating Procedures and Principles and Capital Adequacy of Crypto Asset Service Providers (‘Communiqué No. III-35/B.2
’), published in Official Gazette numbered 32840 on 13 March 2025, have introduced secondary legislation for CASPs, with various transition periods provided for CASPs to ensure compliance with these regulations.
Under the Communiqué No. III-35/B.2, the services and activities that CASPs can carry out with the authorization of the CMB are as follows:

  • Receiving and executing orders related to crypto assets, their exchange, transfer of crypto assets, and the custody services required for these activities,
  • Facilitating the initial sale or distribution of crypto assets,
  • Storage, management of crypto assets or their private keys, or other custody services as determined by the CMB,
  • Providing investment advisory services related to crypto assets,
  • Engaging in other services and activities as determined by the CMB.
Having said that, CASPs must fulfil the following conditions in order to be granted authorization by the CMB for their establishment:

  • They must be established as joint-stock companies.
  • All of their shares must be registered shares.
  • Their shares must be issued in exchange for cash contributions.
  • Provided that CASPs’ capital must be fully paid in cash and their equity must not be less than this amount, platforms must have an initial share capital of at least TRY 150,000,000 (approx. EUR 3,193,954), while custody institutions must have an initial share capital of at least TRY 500,000,000 (approx. EUR 10,646,516). (e) For custody institutions, if the total amount of client assets they hold in custody is up to TRY 1,000,000,000 (approx. EUR 21,293,032), no additional equity is required. However, if the total amount of client assets exceeds TRY 1,000,000,000 (approx. EUR 21,293,032), the custody institution must maintain equity equivalent to 1.5% of the excess amount in addition to its initial share capital. If the equity amount is TRY 1.500.000.000 (approx. EUR 31,939,548), no additional equity is required.
  • Their articles of association must comply with the provisions of the CML and related regulations, and their scope of activities must be exclusively determined as the performance of the activities for which they are authorized by the CMB.
  • Their founders must meet the requirements specified in the CML and related regulations.
  • The shareholding structure must be transparent and clear.
  • (i) Platforms must include the phrase “crypto asset trading platform” in their trade names, while institutions providing crypto asset custody services must include the phrase “crypto asset custody institution” in their trade names.
Under the Communiqué No. III-35/B.1, the conditions that CASPs must fulfil to obtain an operating license from the CMB have been specified in detail. It is stipulated that CASPs that have been granted an establishment license by the CMB will forfeit their right to obtain an operating license if they fail to submit an application for an operating license within 6 months following the granting of establishment license. Furthermore, it is stated that, if deemed appropriate by the CMB, CASPs will be granted an authorization certificate specifying the services and activities which they are authorized to perform, and that operations cannot be commenced prior to obtaining the authorization certificate.
The Crypto Law and the secondary regulations also include provisions regarding organizational structure, principles regarding personnel and managers, board of directors, integration with the Central Securities Depository of Türkiye (‘CSD’), framework agreement, obligation for approval or notification in case of changes in shareholding structure, outsourcing of services, custody services, principles regarding platform activities, listing principles, custody services and transfer principles, and transitional provisions.

Additional comments regarding the legal situation for financial services using crypto currencies or what FinTech’s must be aware of in this business area

FinTechs intending to operate in the crypto asset sector in Türkiye must be aware of the strict legal and regulatory obligations enforced by the CMB. In accordance with the CML, engaging in CASP activities without prior authorization constitutes a criminal offense, punishable by three to five years of imprisonment and a judicial fine ranging from five thousand to ten thousand days.

Importantly, foreign-based platforms are also subject to these rules if they are deemed to be offering services to Turkish residents. Activities such as opening a physical office in Türkiye, launching a Turkish-language website, or engaging in promotional or marketing efforts directly or indirectly through local entities will be considered as targeting Turkish residents. Additionally, offering crypto-related services that are prohibited under Turkish law to residents in Türkiye –even from abroad– will also be deemed unauthorized activity. Therefore, foreign FinTechs must ensure that they do not unintentionally fall within the scope of these regulations, as doing so may trigger criminal liability under Turkish law.


Economic conditions

Market size for financial services using crypto currencies and biggest companies in this business area

According to the Presidency of the Financial Office of Türkiye, in 2024, a total of 107 FinTech companies established in Türkiye were focusing on crypto assets and blockchain technologies. Additionally, according to Chainalysis, Türkiye ranks as the largest crypto market in MENA and 7th globally, receiving USD 136.8 billion in value between July 2023 and June 2024.

Additional comments regarding the economic situation for financial services using crypto currencies or what FinTech’s must be aware of in this business area
Following the implementation of the Crypto Law and relevant secondary legislation, the adoption of crypto assets by customers has continued to increase markedly.



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