On 26 October 2026 the Capital Markets Board of Türkiye (SPK) reset the amounts used to classify professional clients and qualified investors. The financial asset threshold for individuals who request professional client status rose from TRY 10 million to TRY 50 million, and the transaction volume threshold from TRY 5 million to TRY 25 million; the amounts for legal entities were also reset. For the startup ecosystem the key sentence comes last: the carve-out granted in December 2025 to venture capital investment funds (GSYF) and real estate investment funds (GYF) has been removed. Qualified investors buying units of these funds are now subject to the general amounts.
What changed?
The decision is best read together with the first step taken in December 2025. Through Principle Decision i-SPK.37.7 of 18 December 2025 (No. 65/2354), the SPK raised the amounts tenfold but kept the earlier amounts for qualified investors buying GSYF and GYF units. The 26 October 2026 decision raises the general amounts fivefold and removes that carve-out.
| Criterion | Before December 2025 | Decision of 18.12.2025 | Decision of 26.10.2026 |
|---|---|---|---|
| Individuals: total financial assets | TRY 1 million | TRY 10 million | TRY 50 million |
| Individuals: transaction volume | TRY 500,000 | TRY 5 million | TRY 25 million |
| Qualified investors buying GSYF and GYF units | General amounts | Pre-December 2025 amounts kept (carve-out) | Carve-out removed; general amounts apply |
| Legal entities: total assets / annual net sales / equity (at least two) | TRY 50 million / 90 million / 5 million | TRY 500 million / 1 billion / 50 million | Reset; figures not given in the announcement |
Under Article 32 of Communiqué III-39.1, an individual qualifies as a professional client on request by meeting at least two of three criteria: at least ten transactions in each quarter of the past year in the relevant markets together with a set transaction volume, a set total of financial assets including cash and capital market instruments, or specified experience in finance or an advanced licence. This decision changes the amounts in the first two; the experience and licence criterion is unchanged. Because qualified investor conditions in several SPK communiqués refer to the professional client rules, they move with them.
Why this is a positive step
GSYF and GYF units are illiquid, long-term and often concentrated in a small number of investments. The qualified investor concept exists to make sure such products go to investors who can assess and bear their risk. A TRY 1 million threshold that stayed nominally fixed for years had largely lost that function. The decision also ends the two-tier structure created in December 2025, in which the same person could be a qualified investor for one product and not for another, and distributors had to run two sets of criteria. A single standard is clearer for investor protection and for compliance.
Who is affected?
GSYF and GYF managers. The entry threshold for individuals rises from TRY 1 million to TRY 50 million. Institutions that are professional clients by nature, such as banks, insurers, pension funds and portfolio management companies, are not affected; the investor base made up of high-net-worth individuals and mid-sized companies narrows considerably. Ongoing fundraisings, distribution channels and investor eligibility documents should be reviewed against the new thresholds. For the broader picture see our Fund Formation page.
Companies investing in GSYFs. Corporate taxpayers can use the venture capital fund they set aside under Article 325/A of the Tax Procedure Law to buy GSYF units, and they must be qualified investors to do so. In December 2025 the legal entity amounts were raised tenfold while the earlier amounts were kept for GSYF investments; with the carve-out gone, these companies must meet the current legal entity amounts. Our analysis of how family companies structure startup investments is here.
Startups. The effect is indirect but real: startups planning to raise from GSYFs should allow for longer fundraising periods for new funds and for changes in fund sizes. In crowdfunding, the 2026 limits for non-qualified investors (TRY 500,000, or TRY 2,000,000 with an income declaration) are not changed by this decision. However, the rule that equity campaigns with a target above TRY 9 million need at least 5% of the target from qualified investors depends on the qualified investor definition and may be affected. See our equity crowdfunding guide.
Points still to be clarified
The press release summarises the decision; the details will follow from the Principle Decision text published in the SPK bulletin. The main points to watch are:
- Effective date: not stated in the announcement. In December 2025 the new amounts applied from publication of the Principle Decision.
- Existing investors: the December 2025 decision expressly preserved the status of clients who had qualified under the earlier amounts. Principle Decision i-SPK.37.8 of 10 March 2026 added that, in principle, a later fall in assets does not by itself end the status. Whether this decision contains a similar transitional rule is not yet known.
- Outstanding commitments: which amounts apply when existing GSYF investors buy further units under commitments they have already given is a key question for fund managers.
- Legal entity amounts: the new figures are not in the announcement.
What to do now
- Fund managers: classify your investor list against the new thresholds, update status documents, and review your fundraising timetable and distributor workflows until the Principle Decision is published.
- Companies and family offices: if you plan a GSYF investment, compare your total assets, net sales and equity with the new amounts and plan any 325/A allocation accordingly.
- Startups: revisit the timing of GSYF money in your fundraising plan; if you plan a crowdfunding campaign above TRY 9 million, line up the qualified investor anchor early.
Frequently asked questions
What is the new threshold for qualified investors?
For individuals, total financial assets rose to TRY 50 million and transaction volume to TRY 25 million. To be treated as a professional client on request, at least two of the three criteria in Communiqué III-39.1 must be met.
Can an individual still invest in a GSYF with TRY 1 million?
The December 2025 carve-out for GSYFs and GYFs has been removed, so qualified investors buying units of these funds are subject to the general amounts. The position of existing investors will depend on the transitional rules in the Principle Decision.
When do the new amounts apply?
The press release gives no effective date. In the December 2025 change, the new amounts applied from publication of the Principle Decision in the SPK bulletin.
Are crowdfunding investors affected?
The annual limits for non-qualified investors are unchanged by this decision. Rules tied to the qualified investor definition, such as the 5% requirement in larger campaigns, may be affected through the cross-reference.
Sources. SPK press release, 26.10.2026; SPK announcement text (PDF, in Turkish); SPK Bulletin 2025/64, Principle Decision i-SPK.37.7 (18.12.2025, 65/2354).
