The capital threshold for building a fintech in Türkiye has risen for the second year in a row. A Central Bank communiqué published in the Official Gazette on 31 January 2026 (No. 33154) reset, with effect from 30 June 2026, the minimum equity requirements for payment and electronic money institutions, and the numbers are not creeping; the e-money floor that stood at TRY 80 million under the 2025 communiqué is now TRY 105 million. Every team with a licence on its roadmap needs to reopen the financial model against this table.
The new floors
| Institution type | Regulation base amount | From 30.6.2025 | From 30.6.2026 |
|---|---|---|---|
| Payment institutions executing only bill payments | TRY 3m | TRY 15m | TRY 20m |
| Other payment institutions | TRY 5m | TRY 30m | TRY 40m |
| Electronic money institutions | TRY 13m | TRY 80m | TRY 105m |
Account information service providers presenting consolidated account data sit outside these increases; their regime runs separately. It is also worth remembering that the figures are tracked as equity, not as capital paid once at incorporation: this is a floor carried continuously and tested in Central Bank reporting.
What the increase signals
Two resets in consecutive years, leaving the e-money floor at roughly eight times the regulation’s base amount, are more than an inflation adjustment; they signal the Central Bank tightening the market toward fewer, better-capitalised players. Setting the e-money floor at more than two and a half times the general payment institution floor is a deliberate spread as well: models that hold wallets and balances will carry a far heavier base than models that merely move flows. For an early-stage team the practical conclusion is plain: an e-money licence is no longer a seed-budget item; it takes a serious round, or a partnership with a licensed institution through BaaS, agency or white-label structures.
Existing licence holders and pending applicants
The higher floors are not only a newcomer’s problem. Existing institutions will need to keep equity above the new bases, with the adaptation calendar and reporting detail to be tracked through Central Bank secondary rules and announcements. Teams mid-application should update the capital commitments and funding projections in their business plans; a file written on the old numbers, sent back for correction, is the slowest version of the process.
From when do the new floors bind?
The communiqué was published in the Official Gazette on 31 January 2026 and the new amounts apply from 30 June 2026. The previous amounts (TRY 15m, 30m and 80m) were set by the communiqué of 30 January 2025 (No. 32798) and applied from 30 June 2025. For new applications, assume the current amounts apply.
Any link to the crypto-side CASP capital requirements?
No; these are separate regimes. Payment and e-money institutions fall under Law No. 6493 and Central Bank supervision, while crypto-asset service providers sit under the Capital Markets Board. Groups pursuing both licences plan capital as the sum of two separate floors; for the current CASP side, see our CASP licence guide.
Where to start
If fintech is on your roadmap, update three answers: does your financial model carry the new floor for your target licence; is starting with a licensed partner smarter for the first two years than licensing directly; and if you already hold a licence, how far above the new floor does your equity buffer sit? Carry the three answers into your investor update too; the capital floor is no longer a compliance footnote but a main line of the runway calculation.
More on this area: our Fintech & Payments Law page and the payment and e-money licence page.
