A payment or e-money institution licensed in the EU, the UK or elsewhere cannot rely on that licence to serve customers in Türkiye. Turkish law reserves payment services to banks, PTT and payment and e-money institutions licensed by the Central Bank of the Republic of Türkiye (TCMB), and the TCMB Regulation on Payment Services speaks of licensed institutions “established in Türkiye”. Unlicensed activity is a crime. There is, however, a regulated way in: a cooperation with a Turkish licensed institution under Article 19 of the Regulation, which TCMB had approved for four partnerships when we checked in October 2026. The position below is as of November 2026.
The rule: Turkish licence, criminal sanction
Under Law No. 6493, payment service providers are banks, e-money institutions, payment institutions and PTT, and “persons other than the Bank [TCMB] and payment service providers may not provide payment services” (Art. 13). A payment institution may operate only with TCMB’s permission (Art. 14(1)). Issuing e-money is prohibited for anyone other than banks, PTT and e-money institutions licensed under the Law (Art. 18(1)). The Regulation adds that payment services are carried out by banks, PTT and “institutions established in Türkiye” that TCMB has licensed (Art. 4(2)).
Acting like a payment or e-money institution without the required permission carries one to three years’ imprisonment and a judicial fine of up to 5,000 days for natural persons and for the officers of legal entities (Art. 28(1)). The same applies to using words in a trade name, documents, advertisements or public statements that create the impression of being such an institution (Art. 28(2)), and a workplace where the offence is committed may be closed for two to six months, permanently on repetition (Art. 28(3)). Prosecution of these offences requires a written application by TCMB to the public prosecutor (Art. 37(1)).
TCMB uses that route. In a 2021 press announcement it said payment services may be provided in Türkiye “only on condition that the necessary licences have been obtained” and that it applies to public prosecutors regarding unlicensed businesses. Its April 2022 guide on reporting unlicensed providers warns that people who use them may themselves become subject to investigations. Our fintech law hub maps the wider framework.
Is there a territorial test?
Not an explicit one. Neither Law No. 6493 nor the Regulation defines when a foreign provider is providing services “in Türkiye”, and we found no TCMB guidance on reverse solicitation or on foreign providers serving Turkish residents from abroad. The texts do show what TCMB looks at. Article 19(2) bars even a TCMB-approved foreign partner from being the sole visible face of the service, from using its brand to suggest a Turkish licence, and from setting up a website “targeting customers resident in Türkiye”. In our reading, the risk factors are onboarding Turkish residents as customers, holding funds or accounts for them, marketing in Turkish, and pricing in Turkish lira.
The EU contrast is sharp. PSD2 applies to payment services “provided within the Union” (Art. 2(1)), grants authorisation only to a legal person “established in a Member State” (Art. 11(1)), and lets an authorised institution serve another Member State through a notification to its home supervisor (Art. 28). That passport stops at the EU’s external border, and nothing in Turkish law recognises it.
Law No. 6493 gives TCMB no power to block websites, and Law No. 5651 on internet publications contains no reference to Law No. 6493. The general procedure in Article 8/A of Law No. 5651 allows a judge, or in urgent cases the President of the Cybersecurity Presidency (which took over this role from the ICTA (BTK) under Law No. 7590) on the request of the Presidency or relevant ministries, to remove content or block access on listed grounds, including prevention of crime. We found no published use of it against a foreign payment service.
Partnering with a Turkish licensed institution under Article 19
A Turkish payment or e-money institution may offer payment services to its Turkish customers together with a foreign legal entity that TCMB has approved (Regulation Art. 19(1), (7)). The main conditions:
- Cross-border only. The cooperation covers only payments where the payer or the payee is abroad; services where both are in Türkiye are excluded (Art. 19(1)).
- Home licence. The foreign entity must be authorised to provide payment services or issue e-money in its home country (Art. 19(4)).
- Application. The file includes the draft contract, a business plan covering the Turkish office, staff, complaint handling and marketing, the home licence, the latest consolidated audit report and a home-supervisor AML document (Art. 19(7)).
- Liability and capital. The Turkish institution stays responsible to Turkish customers, the transactions count in its collateral and own funds calculations (Art. 19(5)), and TCMB may impose extra own funds and collateral (Art. 19(10), (11)) or require the cooperation to end (Art. 19(9)).
- Data and funds. Records stay in Türkiye (Art. 19(12)). The foreign entity’s systems need not be in Türkiye if every transaction passes through the Turkish institution’s systems and it keeps the audit trail (Art. 19(13); Information Systems Communiqué Art. 21(1)). Funds received from the foreign partner count as payment funds (Art. 34(1)).
TCMB’s published list of approvals showed four cooperations in October 2026, pairing two Turkish institutions with four foreign entities.
Other models
- Back-end cooperation. Cooperations in which no direct or indirect customer relationship arises between the Turkish customer and the foreign entity fall outside Article 19 (Art. 19(3)). A foreign provider acting purely as the Turkish institution’s settlement or payout partner fits here.
- Agent abroad. A Turkish institution may appoint agents resident abroad for its activities abroad, notifying TCMB per country at least 30 days before the first contract (Art. 18(30), (31)). A foreign payment service provider appointed as agent must face no restriction on payments activity in its own country (Art. 18(35)).
- Technical service provider. Services such as data processing, security and IT supply are not payment services where the provider never owns the transferred funds (Law Art. 12(2)(ğ)). A gateway or software vendor that never touches funds can serve Turkish institutions on this basis, subject to their outsourcing rules: payment services themselves cannot be outsourced (Regulation Art. 21(1)), and a provider abroad must not obstruct TCMB’s access and audit (Art. 21(7)).
- Merchant of record. A foreign company that sells its own goods or services to Turkish buyers collects its own revenue, not other people’s money. In our reading that is not a payment service; if it collects for Turkish sellers, it needs a licensed partner unless the narrow commercial-agent exclusion applies (Law Art. 12(2)(b)).
- Own Turkish licence. A Turkish joint-stock subsidiary licensed by TCMB (Law Arts. 14, 18). Since 30 June 2026, minimum own funds are TRY 40 million for most payment institutions and TRY 105 million for e-money institutions; primary and secondary systems and backups must be in Türkiye (Information Systems Communiqué Art. 21(1)). See our payment and e-money licence page.
Decision table: which model needs a Turkish licence?
The table reflects our reading of the texts; TCMB has not ruled publicly on these models.
| Model | Turkish licence or approval needed? |
|---|---|
| Foreign provider onboards Turkish residents directly (accounts, wallets, transfers, payouts) | Yes. Without one, high risk under Law Arts. 13, 18(1) and 28. |
| Foreign provider serves only a merchant abroad; Turkish buyers pay with their own Turkish-issued cards | Lower risk: the provider’s customer is the merchant abroad. No TCMB guidance; avoid marketing payment services to Turkish residents. |
| Joint service with a Turkish institution, foreign brand visible to Turkish customers | No licence for the foreign entity, but TCMB approval under Art. 19(7); cross-border flows only. |
| Back-end partner of a Turkish institution, no customer relationship | No Art. 19 approval (Art. 19(3)); the Turkish institution’s outsourcing and AML rules apply. |
| Agent abroad of a Turkish institution | No; the Turkish institution notifies TCMB (Art. 18(31)). |
| Gateway or software vendor that never owns funds | No (Law Art. 12(2)(ğ)). |
| Merchant of record selling its own products | Generally no; collecting for Turkish sellers changes this. |
| Turkish subsidiary | Yes: full TCMB licence. |
Exporters, wallets and MASAK
Turkish exporters often receive marketplace payouts into foreign wallets. Under the TCMB Export Circular, proceeds must as a rule be brought into Türkiye within 180 days of export (Art. 4(1)). They may arrive through the payment service providers listed in Article 13 of Law No. 6493, that is Turkish providers, and a bank must then accept them as export proceeds within 30 days (Art. 8(3)). For certain exports of up to USD 5,000, including micro exports, the exporter may use the proceeds freely (Art. 22(1)). In our reading, a balance held in a foreign wallet is not yet repatriated. Our cross-border payments article covers the FX side.
On AML, payment and e-money institutions are obliged parties, together with their branches, agents and representatives (MASAK Measures Regulation Art. 4(1)(e)). For correspondent relationships with foreign financial institutions they must check the counterparty’s AML record and controls, obtain senior management approval and allocate duties by contract (Art. 23(1)). Since 7 October 2026, wire transfers of TL 30,000 or more must carry verified originator data (Art. 24(1)). See our MASAK article.
Where to start
- List what you do for Turkish residents: accounts, wallets, transfers, payouts, e-money.
- Pause Turkish-targeted marketing of payment services until the model is settled.
- Decide: Article 19 partnership (cross-border flows), back-end role, agent abroad, or a Turkish subsidiary.
- For Article 19, prepare the Article 19(7) file with your Turkish partner and plan a Turkish office and complaint channel.
- Map data: records in Türkiye, transactions routed through the Turkish institution’s systems.
- Align AML: correspondent due diligence and the TL 30,000 wire rule.
- For exporters: confirm how wallet balances reach a Turkish bank within the deadlines.
FAQ
Does an EU payment or e-money licence allow serving customers in Türkiye?
No. The PSD2 passport works between EU Member States (Art. 28). In Türkiye, payment services are reserved to TCMB-licensed institutions established in Türkiye, banks and PTT (Law No. 6493 Art. 13; Regulation Art. 4(2)). The licensed alternative is a TCMB-approved cooperation under Regulation Article 19.
Can a foreign partner keep its own brand in an Article 19 cooperation?
Only alongside the Turkish institution. The foreign entity cannot be the sole visible face of the service, cannot use its brand to suggest a Turkish licence and cannot run a website targeting Turkish residents (Regulation Art. 19(2)).
Can TCMB block a foreign payment website?
Law No. 6493 gives TCMB no such power. Its tool is a written application to the prosecutor (Art. 37). Access blocking would need the general procedure in Law No. 5651 Article 8/A.
Sources. Law No. 6493 (RG 27.6.2013/28690), Arts. 12, 13, 14, 18, 28, 37; TCMB Regulation on Payment Services and Electronic Money Issuance and Payment Service Providers (RG 1.12.2021/31676, consolidated), Arts. 4, 18, 19, 21, 34; TCMB Information Systems Communiqué (RG 1.12.2021/31676), Art. 21; TCMB Communiqué on minimum own funds (RG 31.1.2026/33154); TCMB list of Article 19(7) approvals; TCMB press announcement 2021-38 (10.9.2021); TCMB guide on reporting unlicensed payment services (April 2022); TCMB Export Circular, Arts. 4, 8, 22; MASAK Measures Regulation (RG 9.1.2008/26751), Arts. 3, 4, 23, 24, as amended by Presidential Decision No. 11845 (RG 7.10.2026/33393); Law No. 5651 (RG 23.5.2007/26530, as amended by Law No. 7590, RG 31.7.2026/33326), Arts. 2, 8/A; Directive (EU) 2015/2366 (PSD2) (OJ L 337, 23.12.2015), Arts. 2, 11, 28.
This article is general information and not legal advice; a specific situation should be assessed with counsel.
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