On 26 August 2026 the Central Bank of the Republic of Türkiye (TCMB) raised the per-transaction limit of FAST, its 24/7 instant payment system, to TRY 300,000 for transfers, request-to-pay payments and dynamic TR Karekod (QR code) payments at merchants. It is the latest step in a five-year build-out: a national QR format made mandatory by regulation, phone-number addressing, request to pay for businesses, and a TCMB push for card-accepting merchants to take QR payments too. In the EU, euro-area banks have had to send instant euro transfers since 9 October 2025, and payment and e-money institutions follow by 9 April 2027. Here is what applies to merchants, PSPs and fintechs as of October 2026.
The trend in one paragraph
Account-to-account (A2A) payments move money directly between bank or payment accounts, without a card network in the middle. Instant schemes make the transfer final in seconds, around the clock. Once the payer can start it by scanning a QR code or approving a request in an app, A2A becomes a real alternative to cards at the till and at online checkout. Merchants gain speed and cost; they lose the card world’s dispute tools. PSPs face questions of access to the rails, a mandatory QR standard and loss allocation.
FAST and its layer services
FAST went live on 8 January 2021. TCMB built and operates it independently of the EFT system; it runs 7/24, settles only Turkish lira, and carries payments between customers of different institutions. Participants are banks, payment and e-money institutions and PTT; payment and e-money institutions joined directly from 2023, and TCMB’s participant list shows 50 participants as of October 2026, eleven of them payment or e-money institutions. See our FAST glossary entry for the short version.
| Layer service | What it does | Status and limit (TCMB) |
|---|---|---|
| Kolay Adresleme (easy addressing) | Pays to a mobile number, e-mail, ID number, tax ID or passport number linked to an IBAN; operated by BKM | Launched with FAST on 8 January 2021; one account per easy address, maximum five per person |
| FAST-TR Karekod | Payer scans a QR code shown by the merchant or payee; the app starts a FAST payment | TRY 300,000 for dynamic-verified merchant payments since 26 August 2026 |
| Ödeme İste (request to pay) | Payee sends a request; on approval a FAST payment goes out, at once or on a set date | Launched 5 February 2024; corporate use, partial and early payment and deferral from 18 January 2025; TRY 300,000 |
| Güvenli Ödeme İşlemi (secure payment) | A FAST participant holds the funds until a notary registers the sale; first used for second-hand vehicles | Launched 31 May 2024; TRY 5,000,000 |
One of the four request-to-pay models is built for merchant and e-commerce checkout: the shop sends the request, the buyer must answer at once and the payment executes immediately. TCMB says limits may be revised, so do not hard-code them.
TR Karekod: one QR format, by regulation
QR payments are governed by TCMB’s Regulation on the Generation and Use of TR Karekod in Payment Services (Official Gazette 21 August 2020, No. 31220), issued under Articles 12 and 18 of Law No. 6493. Every payment transaction within Law No. 6493 that is made with a QR code must use TR Karekod (Art. 4(1)); TCMB may cap amounts and inspect PSPs, system operators, merchants and outsourcing providers (Art. 4(2)-(3)). Codes are generated by PSPs holding a generator code assigned by BKM, or by TCMB-approved system operators, and generation may be outsourced (Art. 5). PSPs must keep the code data intact, take safety measures, put static-code security duties for merchants into the framework contract and notify both parties once the payment completes (Art. 8). Merchants must tell customers that QR payment is accepted, in the format TCMB sets, and protect static codes (Art. 9). TR Karekod is not mandatory where a foreign-issued instrument is used domestically, one party is resident abroad and a foreign PSP’s infrastructure is used (Art. 10).
What TCMB has asked of acquirers
Take-up at the till lagged the technology. In its instruction of 2 May 2024, TCMB noted that over 80% of POS and cash register devices could display FAST TR Karekod, yet few merchants accepted it. It decided to apply Article 4(4) of the Payment Services Regulation (Official Gazette 1 December 2021, No. 31676), as amended in 2023: a PSP with an existing framework contract may add FAST TR Karekod acceptance without fresh consent, after informing the merchant under Article 44(1)-(2), and must not provide it if the merchant declines. No fee, commission or expense may be charged before the merchant starts using the service.
On 29 August 2025, with device coverage above 90%, TCMB asked FAST participants that provide card acceptance to complete the contractual steps by 31 December 2025 so their card-accepting merchants are ready for FAST TR Karekod, unless a merchant declares in writing or electronically that it does not want it, or TCMB considers FAST technically impossible there. Participants still developing got six months from completion. TCMB pointed to administrative fines under Article 27(1) of Law No. 6493. As of early October 2026, TCMB’s legislation page lists no later instruction on this point.
A2A versus cards: refunds, chargebacks and fraud
| Issue | FAST / TR Karekod | Cards |
|---|---|---|
| Revocation | Payer cannot revoke once its PSP has received the order, unless agreed (Payment Services Regulation Art. 64(1)) | Same rule, plus scheme dispute rules |
| Disputes | No card-style chargeback in TCMB’s FAST materials; for mistaken payments TCMB sends users to their institution and says it has no role in refunds | Chargeback under scheme rules and the acquiring contract |
| Refunds | A new transfer from the merchant; set the terms in your contract | Usually a refund on the card |
| Unauthorised payments | Correction request to the PSP without delay once the customer learns of it, and at the latest within 13 months; PSP must prove authorisation (Art. 54) | Same Art. 54 regime |
No chargeback means fewer “friendly fraud” losses for merchants, but consumer-law refund and withdrawal duties still apply in full. Instant, irrevocable transfers are also the favourite target of impersonation scams; who bears that loss is covered in our article on AI-enabled payment fraud and liability.
The EU Instant Payments Regulation
Regulation (EU) 2024/886 amended the SEPA Regulation (EU) No 260/2012. PSPs offering credit transfers must offer instant ones, accounts must be reachable 24 hours a day on any calendar day, and the payee’s PSP must make funds available within 10 seconds. Instant transfers may not cost more than other credit transfers of a corresponding type (Art. 5b). The payer’s PSP must offer verification of payee before the payer authorises (Art. 5c). PSPs screen their users against EU targeted sanctions at least daily instead of per transaction (Art. 5d), and users may set amount limits (Art. 5a(6)).
| Who | Receive | Send | Verification of payee |
|---|---|---|---|
| PSPs in euro-area Member States | 9 January 2025 | 9 October 2025 | 9 October 2025 |
| PSPs in non-euro Member States | 9 January 2027 | 9 July 2027 | 9 July 2027 |
| Payment and e-money institutions, euro area | 9 April 2027 (send and receive) | Art. 5c(9) sets no separate date | |
The Regulation also amended the Settlement Finality Directive so payment and e-money institutions can join designated payment systems (transposition by 9 April 2025). For a Turkish group this matters in three ways: an EU-licensed subsidiary must meet the 2027 deadline; a Turkish merchant collecting euro into an EU account will face name checks against its IBAN, so invoice names must match the account; and EU payers will expect instant euro at standard prices. More on EU payments reform is on our fintech law hub.
What is still unclear
TCMB’s instructions require readiness and bar pre-use fees, but do not set merchant pricing after use begins. A2A refunds are left to contract; TCMB’s published FAST materials contain no dispute rulebook comparable to the card schemes’. The 31 December 2025 deadline has passed, and how TCMB treats participants that missed it is not public. A non-bank that builds checkout flows around request to pay should also check whether its role amounts to a licensed payment service under Law No. 6493.
Where to start
- Inventory every QR code you generate or display and check it against the TR Karekod and FAST TR Karekod rulebooks.
- Acquirers: confirm the Article 44 notices, record merchant opt-outs, and charge no pre-use fees.
- Merchants: show the QR acceptance notice, secure static codes and write an A2A refund policy into your terms.
- Add fraud controls suited to irrevocable payments and test your Article 54 complaint process.
- EU entity or euro collections: plan for 9 April 2027, price parity and payee-name matching.
Must a merchant in Türkiye accept FAST TR Karekod?
The 29 August 2025 instruction targets FAST participants that provide card acceptance: they had to make their card-accepting merchants ready by 31 December 2025. A merchant may decline in writing or electronically. A merchant that does accept QR payments has the Article 9 duties to inform customers and protect static codes.
Can a payer reverse a FAST payment like a card chargeback?
Not in the card sense. The order cannot be revoked once the payer’s PSP has received it, unless agreed (Art. 64(1)). For unauthorised or incorrectly executed payments the customer may seek correction from its PSP, notifying it without delay and at the latest within 13 months (Art. 54).
What is the FAST limit as of October 2026?
Since 26 August 2026, TRY 300,000 per transaction for transfers, request-to-pay and dynamic-verified FAST TR Karekod merchant payments, and TRY 5,000,000 for the secure payment service, according to TCMB’s FAST site.
Sources. TR Karekod Regulation (Official Gazette 21.8.2020, No. 31220), Arts. 4, 5, 8, 9, 10; Payment Services Regulation (Official Gazette 1.12.2021, No. 31676), Arts. 4(4) (amended by Official Gazette 7.10.2023, No. 32332), 44, 54, 64; TCMB instructions of 2.5.2024 and 29.8.2025; TCMB press release 2021-01; TCMB FAST site (FAQ, participants, announcements); Regulation (EU) 2024/886 (OJ L, 19.3.2024), Arts. 5a to 5d of Regulation (EU) No 260/2012.
This article is general information and not legal advice; a specific situation should be assessed with counsel.
Author
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View all postsMümtaz is the Managing Partner of Vircon Legal, which he founded in 2016. He advises founders, investors and operators on financing rounds, M&A, cross-border incorporations and regulated verticals such as crypto-asset infrastructure, fintech and games, bringing a former startup founder's perspective to every engagement. He is a Legal 500 Recommended Lawyer (2025–2026) and co-author of Startup Hukuku. Canonical profile: https://mumtazhacipasaoglu.com · Open-access legal guides: https://github.com/mumtazhpo
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