Operating a standalone crowdfunding platform in Türkiye takes two decisions from the Capital Markets Board (SPK): permission to establish the company and, after that, a place on the Board’s list of platforms. Article 35/A of the Capital Markets Law No. 6362 makes the permission mandatory, and the Crowdfunding Communiqué (III-35/A.2, Official Gazette 27 October 2021, No. 31641) sets the conditions. For 2026 the minimum capital is TRY 15,000,000. This guide takes the operator’s view, as of November 2026; for the issuer’s side, see our guide to raising equity through a licensed platform.
Two steps: establishment permission, then listing
Article 35/A(2) of Law No. 6362 requires Board permission before a crowdfunding platform is established and starts operating. The Communiqué splits this into two applications. The founders first apply for establishment permission with the draft articles of association and evidence that they meet the fit and proper conditions (Art. 5(1)-(2)). The company then applies for listing with the documents in Annex 1 (Art. 5(3)-(5)). Only listed platforms may carry out crowdfunding, and each must state on its website whether it is authorised for equity, debt or both (Art. 5(11)).
Development and investment banks, participation banks and broadly authorised brokerage firms can also be listed, and only four listing conditions apply to them: an investment committee, agreements with the Central Registry Agency (MKK) and the escrow agent, the MKK risk data link for debt crowdfunding, and an investor communication channel (Art. 5(6)). The SPK list dated 4 May 2026 shows 18 platforms, four of them brokerage firms or a bank. Every entry is listed for equity-based crowdfunding only.
Capital, shareholders, board and investment committee
The capital figure in the Communiqué (TRY 1,000,000) is revalued yearly; SPK Bulletin 2025/68 set it at TRY 15,000,000 for 2026.
| Requirement | Rule |
|---|---|
| Joint-stock company, all shares registered, “Kitle Fonlama Platformu” in the trade name, objects limited to equity and/or debt crowdfunding | Art. 5(1)(a), (c), (ç), (d) |
| Capital of at least TRY 15,000,000 (2026), fully paid in cash; capital and equity not below it | Art. 5(1)(b); Bulletin 2025/68 |
| Equity test applied at half for two years after listing | Art. 5(10) |
| Board of at least three, one holding an individual participation investor (business angel) licence | Art. 5(1)(f); Art. 6(3) |
| Founders, shareholders and directors: no bankruptcy, no listed convictions, no SPK trading ban, the honesty and reputation the business requires | Art. 6(1) |
| Acquisitions reaching 10% or crossing 10%, 20% or 50%, transfers falling below those ratios, and transfers of board-nomination privileges need Board approval | Art. 8(2)-(3) |
The investment committee needs at least three members, a majority with five years’ experience in fields such as finance, entrepreneurship, law or technology, one board member holding the business angel licence and one member with the SPK Level 3 licence (Art. 9(1)). Debt platforms add a member with a credit rating licence (Art. 9(2)). A lost condition must be shown to be restored within 10 business days, and a vacancy reported within 2 business days (Art. 9(5)-(6)).
Infrastructure, onboarding and the 2026 investor limits
Before listing, a standalone platform needs internal control and risk management, accounting and operations units, adequate records staff, and the information systems infrastructure that SPK’s rules require of narrowly authorised brokerage firms (Art. 5(5)(ç)-(e)). It must sign agreements with MKK and the escrow agent and integrate its systems with theirs (Art. 5(5)(f)). The escrow agent is Takasbank or another portfolio custodian, holding investor money blocked until release to the funded company or refund (Art. 4(1)(d)).
Onboarding under Article 14 covers identity verification through the e-Devlet method under MKK rules, a membership agreement with the Annex 5 terms, a signed general risk disclosure form, an appropriateness check that rejects unsuitable applicants, MKK confirmation of qualified investor status and immediate forwarding of income declarations to MKK. MKK checks the limits below against the latest declaration the platform has sent (Arts. 15(2), 18(3)).
| Limit for non-qualified individuals | 2026 amount |
|---|---|
| Calendar-year limit, equity (Art. 15(1)) and debt (Art. 18(1)) | TRY 500,000 |
| With a declared annual net income: 10% of that income, capped at | TRY 2,000,000 |
| Debt crowdfunding, per project (Art. 18(2)) | TRY 200,000 |
| Equity target above which 5% must come from qualified investors (Art. 16(5)) | TRY 9,000,000 |
Running campaigns: evaluation, conflicts, fees and prohibitions
The committee adopts an objective evaluation policy for feasibility (equity) and credibility (debt) reports, which the board approves and publishes (Art. 9(8)). A campaign goes live only with committee approval, supported by a report on each criterion published with the information form and any dissent (Art. 11(7)). The platform must confirm that each investor has read the approved form before accepting a funding request (Art. 11(9)).
A board-approved conflicts of interest policy is a listing condition (Art. 5(5)(h)). Committee members may not vote on projects they or close relatives are connected to, may take no economic benefit from issuers and may fund no more than 5% of a target they evaluated (Art. 9(10)-(11)). No campaigns for the platform itself, for companies it holds 20% or more of, or for companies 20% or more owned by its shareholders, directors, committee members or their close relatives (Art. 12(6)). The platform may itself fund up to 20% of each target and 50% of its equity in total (Art. 11(1)(c)).
Fees, commissions and whether escrow balances earn interest must be published on the website (Art. 11(3)(f)), and fees are a mandatory term of the issuer and member agreements (Annexes 4 and 5). Platforms may not give investment advice on projects, fund real estate projects or projects to invest in other companies, raise money from Turkish residents for persons resident abroad, or broker secondary trading unless they are broadly authorised brokerage firms (Art. 12(2)-(4), (7)). Platform advertising may feature only completed campaigns (Art. 11(14)).
Extra conditions for debt-based crowdfunding
Since 2020, Article 35/A(1) of Law No. 6362 provides that banking legislation does not apply to debt-based crowdfunding. A debt platform needs a two-way data link with MKK’s Investor Risk Tracking System (Art. 5(5)(g)) and a published credit rating system and policy, with a credit score for each project (Art. 24). Money may be raised only against crowdfunding debt instruments, never under loan agreements (Art. 19(1)). Interest may not exceed by more than 50% the weighted average rate of two government bond benchmarks, maturity is capped at five years and bullet repayment is not allowed (Art. 19(5)). On the 4 May 2026 list, no platform was authorised for debt.
Liability, reporting, data protection and AML
Under Article 35/A(6) of Law No. 6362 and Article 29(2) of the Communiqué, everyone who signs the information form is jointly liable for losses from false, misleading or incomplete information in it. Investment committee members sign the form with the issuer’s representatives (Art. 11(10)), so the platform’s own people are inside that liability. Board members answer for the platform’s obligations (Art. 29(1)). Project promotion may not be misleading or exaggerated and must match the form (Art. 28(6)).
Recurring duties include half-yearly and annual campaign reports filed within 30 days and published (Art. 11(15)), annual financial statements by the end of the fourth month (Art. 11(16)) and notice of any lost listing condition within 2 business days (Art. 10(1)). Platforms must apply to join the Capital Markets Association of Türkiye within three months of authorisation (Law No. 6362, Art. 74(1)). Where money is raised from the public through crowdfunding platforms without Board permission, the Board can order content removal or access blocking (Art. 99(4)).
Sharing platform data with third parties, public bodies included, is subject to the KVKK (Law No. 6698) (Art. 11(17)), and members’ explicit consent is needed to collect risk information and share it where necessary (Art. 14(2)(g)). On AML, the obliged parties listed in Article 4(1) of the Regulation on Measures under Law No. 5549, as consolidated after the 7 October 2026 amendment, do not include crowdfunding platforms. Banks and brokerage firms are listed, so a bank or brokerage firm acting as a platform is an obliged party in its own right. See our MASAK guide for fintechs for what that involves.
The EU contrast and where to start
Under Regulation (EU) 2020/1503 (ECSPR), applicable since 10 November 2021, a legal person applies to the competent authority of the Member State where it is established, which decides within three months of a complete application (Art. 12(1), (8)). Prudential safeguards are the higher of EUR 25,000 and a quarter of the previous year’s fixed overheads (Art. 11(1)); an authorised provider can serve other Member States by notification (Art. 18), and offers above EUR 5,000,000 over 12 months are outside the regime (Art. 1(2)(c)). A Turkish listing gives no EU passport, and under Article 13 of the Communiqué a foreign platform targeting Turkish residents, for example through a Turkish-language website, falls under the Turkish rules.
The Communiqué sets no deadline for the Board’s decisions, but it does set deadlines for the platform: apply for listing within 6 months of establishment permission or lose the right to be listed, and become operational within 6 months of listing or be removed from the list (Art. 10(2)-(3)).
- Choose equity only or equity and debt; debt adds the credit rating licence, the MKK risk link and a rating policy.
- Line up TRY 15,000,000 (2026) in cash and check every founder, shareholder and director against Article 6.
- Recruit the licensed board and committee members before filing.
- Draft the articles, conflicts and evaluation policies, and the membership and crowdfunding agreements.
- Start MKK and escrow agent onboarding early; their integration letter is part of Annex 1.
- Build onboarding (e-Devlet verification, risk form, appropriateness test, income declarations) with its KVKK documentation.
- Diarise the post-listing deadlines: operational within 6 months, association membership within 3 months, half-yearly reports within 30 days.
Crowdfunding sits alongside payments, e-money and crypto in our fintech law hub, and our crowdfunding practice page covers investors too.
Frequently asked questions
What is the minimum capital for a crowdfunding platform in Türkiye in 2026?
TRY 15,000,000, fully paid in cash, as revalued by SPK Bulletin 2025/68. The equity test is applied at half for the first two years after listing.
Is a crowdfunding platform liable for a misleading information form?
Everyone who signs the information form is jointly liable for losses from false, misleading or incomplete information in it, and the platform’s investment committee members are among the signatories.
Are crowdfunding platforms obliged parties under MASAK rules?
Article 4(1) of the Regulation on Measures does not list crowdfunding platforms as of November 2026, but banks and brokerage firms acting as platforms are obliged parties in their own capacity.
Sources. Capital Markets Law No. 6362, Arts. 35/A, 74 and 99 (Official Gazette 30 December 2012, No. 28513; Art. 35/A added by Law No. 7061, Official Gazette 5 December 2017, No. 30261, and amended by Law No. 7222; consolidated text); SPK Crowdfunding Communiqué (III-35/A.2), Arts. 4-16, 18, 19, 24, 28, 29 and Annexes 1, 4 and 5 (Official Gazette 27 October 2021, No. 31641; SPK consolidated text); SPK Bulletin 2025/68 (31 December 2025); SPK list of crowdfunding platforms (4 May 2026); Regulation on Measures under Law No. 5549, Art. 4 (Official Gazette 9 January 2008, No. 26751; consolidated text); Law No. 6698 on the Protection of Personal Data (Official Gazette 7 April 2016, No. 29677); Regulation (EU) 2020/1503, Arts. 1, 11, 12 and 18 (OJ L 347, 20.10.2020).
This article is general information and not legal advice; a specific situation should be assessed with counsel.
