Since 1 January 2022, Türkiye has had a separate rulebook for banks without branches. The BDDK Regulation on the Operating Principles of Digital Banks and Service Model Banking (Official Gazette 29 December 2021, No. 31704) lets a new entrant apply for a full banking licence under Banking Law No. 5411 and run it only through digital channels, in exchange for higher capital, a narrower customer base and extra information systems scrutiny. This guide, current as of November 2026, compares that route with a payment or e-money licence or a bank partnership.
What a digital bank is, and what it is not
The Regulation defines a digital bank as a credit institution that offers banking services through electronic banking distribution channels instead of physical branches (Art. 3(1)(i)). As a deposit or participation bank it may, unless the Regulation says otherwise, do everything those banks do, under all banking rules plus the Regulation (Art. 4(1)). It takes deposits (or participation funds) and lends, which separates it from a payment or e-money institution licensed by the Central Bank (TCMB) under Law No. 6493.
An existing bank does not need this licence to go digital: it may serve customers partly or fully online, or under a separate brand within the same entity and permit, without a new application, and may close branches only under a plan the BDDK approves (Art. 14(1)).
The restrictions that come with the licence
- Credit customers. A digital bank’s credit customers may only be financial consumers and SMEs (Art. 5(1)). Interbank and money and capital market transactions counted as credit, loans to other banks and foreign currency loans to larger firms are not a breach (Art. 5(2)).
- No branches. Beyond its head office, a digital bank may not open branches or organise through agencies or representative offices, and may not offer physical safe deposit or custody services (Art. 5(3)). It must keep at least one physical complaints office (Art. 6(1)) and may use its own or other ATM networks (Art. 6(2)).
- Unsecured consumer loans. Excluding credit card use and overdraft accounts, total unsecured cash consumer loans to one customer may not exceed four times the customer’s declared and verified average monthly net income, or TRY 10,000 where income cannot be established; the Board may change both figures (Art. 5(4)).
- Uptime. The committed availability for internet and mobile banking may not be below 99.8%, published on the home page (Art. 7(1)).
The restrictions are not permanent. If a digital bank raises its paid-in capital to TRY 2.5 billion, the Board may, on application, lift them fully or under a transition plan, after which the bank may do everything other credit institutions do; the Board may also raise this figure (Art. 5(6)).
Licensing requirements: the Banking Law plus the digital layer
A digital bank first meets the conditions for any new bank. Under Article 7 of the Banking Law it must be a joint-stock company with registered shares issued for cash, qualified founders and board members, a transparent shareholding structure, and an activity programme with business plans, financial projections, a three-year budget and internal control, risk management and internal audit. Under Article 8 each founding shareholder must, among other things, not be bankrupt or in concordat, not have held a qualifying stake in failed banks, have no conviction for listed offences, and have the necessary financial strength, reputation, honesty and competence; a legal-person founder’s natural-person qualifying shareholders must meet the same core conditions.
The Regulation adds its own layer on top of the general conditions in the BDDK Regulation on Banks’ Transactions Subject to Permission and Indirect Shareholding (İTİY) (Art. 8(1)).
- Capital. The general minimum in the Banking Law is TRY 30 million (Art. 7(1)(f)). For a digital bank, the published text sets minimum paid-in capital for the operating permit at TRY 1 billion, paid in cash and free of collusion; the Board may increase it (Art. 9(1)).
- Tech and telecom owners. Where controlling shareholders provide technology, e-commerce or telecommunications services, the Board may require them (or their controllers) to be resident in Türkiye and to have a data exchange agreement with the Risk Centre (Art. 8(2)).
- Management. The most senior information systems executive must be appointed at least at deputy general manager level, and at least one board member must have at least ten years’ professional experience in information systems management (Art. 10(1)).
- Business plan. The plan must also name financial inclusion target groups (such as students, homemakers, under-18s and SMEs), analyse market size and gaps, and give five-year pricing, customer, break-even and financial projections (Art. 11(1)(a)).
- Activity programme. It must add the system and network architecture, the IS strategy plan, IS risk, security, continuity and outsourcing processes, IS outsourcing providers with a risk assessment, the complaints workflow, channel security and authentication, and remote identification controls (Art. 11(1)(b)).
- IS adequacy. The operating permit requires a favourable opinion of the BDDK unit that audits information systems on site; it may ask for an independent IS audit report from a BDDK-authorised firm (Art. 12(1)). As for all banks, primary and secondary systems must be kept in Türkiye (Regulation on Banks’ Information Systems and Electronic Banking Services, Art. 25(1)).
The application path: founding permit, then operating permit
A bank needs two separate Board decisions.
Stage 1: founding permit (kuruluş izni). The Board grants it by the affirmative vote of at least five of its seven members (Banking Law Arts. 6 and 83). Article 4 of the İTİY sets the file; its 2006 text (since amended) lists, among others, notarised founder declarations, draft articles, court and criminal record certificates, financial statements, tax returns and a source-of-funds undertaking from founders committing 10% or more. The decision must be notified within three months of the application or of completion of missing documents; if deficiencies are not cured within six months the application lapses (Banking Law Art. 6).
Stage 2: operating permit (faaliyet izni). After incorporation and trade registry registration, the bank applies with a declaration (İTİY Art. 7(1)), within nine months of the founding permit or the founding permit is cancelled (Banking Law Art. 11(b)). The BDDK checks cash capital, staff, equipment and managers, and that at least a quarter of the entry fee to the Savings Deposit Insurance Fund (10% of the Article 7 minimum capital) has been paid (Art. 10). The decision is due within three months of the first application; the BDDK may give up to six months to cure deficiencies, after which the founding permit becomes void if the bank still falls short. The permit is published in the Official Gazette (Art. 10).
After the permit. The operating permit is cancelled if the bank does not start within six months, and activities may be restricted if it does not join the relevant banks’ association within one month and ignores a BDDK warning (Art. 12).
In practice the gap between the stages has varied. The BDDK’s list of banks (checked 8 October 2026) flags six digital banks; their permits under the Regulation:
| Bank | Founding permit (Board decision) | Operating permit (Board decision) | Official Gazette |
|---|---|---|---|
| Hayat Finans Katılım Bankası A.Ş. | 21.4.2022, No. 10165 (as Hayat Katılım Bankası A.Ş.) | 23.3.2023, No. 10543 | 25.3.2023, No. 32143 |
| T.O.M. Katılım Bankası A.Ş. | 4.8.2022, No. 10282 | 30.3.2023, No. 10561 | 31.3.2023, No. 32149 |
| FUPS Bank A.Ş. | 28.9.2022, No. 10347 and 2.11.2023, No. 10715 | 31.10.2024, No. 10979 | 5.11.2024, No. 32713 |
| Ziraat Dinamik Banka A.Ş. | 23.3.2023, No. 10542 | 31.10.2024, No. 10980 | 5.11.2024, No. 32713 |
| Colendi Bank A.Ş. | 3.8.2023, No. 10639 | 31.10.2024, No. 10997 | 5.11.2024, No. 32713 |
| Adil Katılım Bankası A.Ş. | 23.5.2024, No. 10914 | 11.9.2025, No. 11267 | 20.9.2025, No. 33023 |
Digital bank, payment or e-money institution, or service model?
| Digital bank | Payment / e-money institution | Interface provider (service model) | |
|---|---|---|---|
| Authority and law | BDDK; Law No. 5411 and Reg. 31704 | TCMB; Law No. 6493 | BDDK Board permission as the service bank’s support service provider (Reg. 31704 Art. 13(6)) |
| Deposits and lending | Yes, credit limited to financial consumers and SMEs | No lending; e-money funds are not deposits | No; the service bank decides and books on its own balance sheet |
| Capital | TRY 1 billion paid-in (published text) | Statutory capital plus TCMB own funds floors (from 30.6.2026: TRY 20m, 40m or 105m by type) | No figure in Reg. 31704; Board may set extra conditions |
| Customer contract | With the digital bank | With the institution | With the service bank |
Service model banking is covered in our BaaS and embedded finance article; the TCMB route is on our payment and e-money licence page.
Where to start
- Confirm you need a bank: without deposits or lending, a TCMB licence or a service bank partnership may be enough.
- Check every founder and indirect qualifying holder against Article 8; gather court, criminal record and tax documents early.
- Budget TRY 1 billion of cash capital, the Fund entry fee and, if you plan to grow out of the restrictions, TRY 2.5 billion.
- Recruit the deputy GM for information systems and a board member with ten years’ IS management experience before filing.
- Build the five-year business plan around a defined financial inclusion target group and a market gap analysis.
- Prepare the IS architecture, outsourcing risk assessments and remote ID controls for the BDDK review, with systems in Türkiye.
- Diary the deadlines: nine months to apply for the operating permit, six months to start operating, one month to join the association.
More on the Turkish fintech licence map in our fintech law hub.
Can a digital bank lend to large companies?
In principle no: credit customers may only be financial consumers and SMEs, with exceptions such as foreign currency loans to larger firms. The Board may lift the restrictions once paid-in capital reaches TRY 2.5 billion (Regulation Art. 5).
How long does the BDDK process take by law?
The founding permit decision is due within three months of a complete application. The operating permit application must follow within nine months, and that decision is due within three months, plus any cure period of up to six months (Banking Law Arts. 6, 10 and 11). Actual timelines have varied.
Can a technology or e-commerce group own a digital bank?
Yes, if it and its qualifying shareholders meet the founder conditions of Banking Law Article 8. If controlling shareholders are technology, e-commerce or telecom firms, the Board may also require them to be resident in Türkiye and to share risk data with the Risk Centre (Regulation Art. 8(2)).
Sources. Banking Law No. 5411 (RG 1.11.2005/25983 bis), Arts. 6, 7, 8, 10, 11, 12, 83; Regulation on the Operating Principles of Digital Banks and Service Model Banking (RG 29.12.2021/31704), Arts. 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15; Regulation on Banks’ Transactions Subject to Permission and Indirect Shareholding (RG 1.11.2006/26333), Arts. 4, 6, 7; Regulation on Banks’ Information Systems and Electronic Banking Services (RG 15.3.2020/31069), Art. 25; BDDK Board decisions No. 10543 (RG 25.3.2023/32143), No. 10561 (RG 31.3.2023/32149), No. 10979, No. 10980, No. 10997 (RG 5.11.2024/32713) and No. 11267 (RG 20.9.2025/33023); BDDK list of banks; Law No. 6493 (RG 27.6.2013/28690), Arts. 14, 18, 20; TCMB Communiqué on minimum own funds (RG 31.1.2026/33154).
This article is general information and not legal advice; a specific situation should be assessed with counsel.
