Swift ended the coexistence of legacy MT messages and ISO 20022 for cross-border payments on 22 November 2025, then deferred the next step, mandatory structured postal addresses, which had been due in November 2026. The Financial Stability Board (FSB) considers it unlikely that satisfactory global improvements will be achieved by the G20’s end-2027 timetable for cheaper, faster and more transparent payments. For Turkish payment institutions and exporters, the domestic rules stay the same: a payment institution needs a licence from the Central Bank of the Republic of Türkiye (CBRT) to offer remittance, FX is tightly fenced, and until 31 January 2027 at least 35% of certified export proceeds must be sold to the bank. This is the position as of October 2026.
The trend in one paragraph
Cross-border payments still pass through chains of correspondent banks, and each hop adds cost and delay. ISO 20022 is a structured message format designed to carry richer payer and payee data along the chain. Each corridor still runs on national licensing, FX and AML rules, and the Swift migration reaches Turkish firms through their banks and partner contracts.
ISO 20022: where the Swift migration stands
| Milestone | Status (October 2026) |
|---|---|
| End of MT/ISO 20022 coexistence for cross-border payments | Ended 22 November 2025 |
| Structured or hybrid postal addresses in CBPR+ payment messages, with unstructured addresses rejected | Planned for November 2026, deferred on 27 August 2026. No new date yet; Swift will give an update by December 2026 at the latest |
| Deferred Standards Release 2026 (MT messages except Category 1, securities and funds, tracker, exceptions and investigations) | 12 June 2027 (Swift update of 21 September 2026) |
| Harmonised ISO 20022 data requirements of the BIS Committee on Payments and Market Infrastructures (CPMI) | Operators and PSPs encouraged to implement them by end-2027 (FSB, October 2025) |
Swift extended the timeline rather than dropping the requirement, so capturing addresses in separate fields now is sensible.
The G20 targets for end-2027
| Challenge | Retail (B2B, P2B, B2P, P2P) | Remittances |
|---|---|---|
| Cost | Global average no more than 1%, no corridor above 3%, by end-2027 | Average cost of sending USD 200 no more than 3%, no corridor above 5%, by 2030 (UN SDG) |
| Speed | 75% of payments available to the recipient within one hour, the rest within one business day | The same, in every corridor |
| Transparency | Every provider to disclose total cost (fees, FX rate, conversion charges), expected delivery time, payment status tracking and terms of service | |
In October 2025 the FSB reported that only 35.4% of retail payment services credited recipients within one hour and 67.3% within one business day; P2P costs have stayed at about 2.5% since 2023. On 12 March 2026 it kicked off a new implementation phase built on jurisdictional and regional action plans, with the end-2027 deadline still in place. The FSB says its activities “shall not be binding or give rise to any legal rights or obligations”. The targets do feed into international standards: the FATF finalised its revision of Recommendation 16 on payment transparency in June 2025, for full implementation by end-2030. In Türkiye, a payment service provider must already state the exchange rate (or reference rate) for a single payment, and any different rate it actually uses (Regulation on Payment Services, Arts. 39(1)(ç) and 40(1)(ç)).
Remittance in Türkiye is a licensed payment service
Law No. 6493 lists money remittance (para havalesi) as a payment service (Art. 12(1)(ç)). It defines it as a transfer of funds to the recipient, or to the recipient’s provider, without an account opened for either party (Art. 3(1)(y)). Payment service providers are banks, e-money institutions, payment institutions and PTT (Art. 13(1)); no one other than the CBRT and these providers may offer payment services (Art. 13(2)). A payment institution needs a CBRT licence (Art. 14(1)). Acting without one carries one to three years’ imprisonment and a judicial fine of up to 5,000 days (Art. 28(1)). Adding remittance to an existing licence needs separate CBRT permission if it was not in the original application (Regulation, Art. 15(1)). See our payment and e-money licence page.
The Regulation offers two routes abroad. An agent resident abroad, for activities abroad, requires notice to the CBRT, per country and with a supporting report, at least 30 days before the first agency contract (Art. 18(30) and (31)). A joint service with a foreign legal entity requires CBRT permission for that entity, which must be licensed at home (Art. 19(4) and (7)), and may cover only payments where at least one party is abroad. The foreign entity cannot be the sole face of the service or run a website targeting Turkish residents, and the Turkish institution stays liable to customers (Art. 19(1), (2) and (5)).
FX rules for payment and e-money institutions
- Payments between Turkish residents through Turkish providers must be made in Turkish lira, with no FX trading by the institution (Arts. 66(3) and 15(4)).
- Where one party is abroad, the parties may agree the currency, subject to Decree No. 32 on the Protection of the Value of Turkish Currency (Art. 66(1)). The institution may trade FX only as part of the payment service; for account-based payments, not above the payment amount, and the currency may not remain in the customer’s account after the end of the next business day (Art. 15(4)).
- As a principle, residents do not hold FX payment accounts. Outgoing FX may stay in the account until the end of the next business day, and incoming FX for one month at most. The CBRT may extend that period for specific transaction types, by no more than one month (Art. 66(4)).
An open question is how these limits apply to marketplace and payment facilitator payouts to Turkish sellers; the answer depends on whose account holds the funds and when conversion happens.
Exporters: 180 days, 35% and the payment institution route
The CBRT Export Circular, issued under Decree No. 32 and Communiqué No. 2018-32/48, contains four rules that matter here:
- Repatriation: as a rule, proceeds must be brought into Türkiye within 180 days of the actual export date, and an export proceeds acceptance certificate (İBKB) must be issued within the same period (Arts. 4(1) and 8(1)).
- Payment institutions: proceeds may arrive through a payment service provider, but only a bank can accept them as export proceeds: within 30 days of withdrawal or transfer to a bank, against the institution’s letter or written confirmation that they came from abroad (Art. 8(3)).
- Mandatory sale: until 31 January 2027, at least 35% of proceeds tied to an İBKB or a foreign exchange purchase certificate (DAB) must be sold to the bank. The bank sells that amount on to the CBRT the same day, and the exporter receives the Turkish lira equivalent (Temporary Art. 4). Earlier versions ended on 31 July 2025 and 31 October 2025 (Temporary Arts. 2 and 3), so watch for a decision before end-January.
- Small exports: for certain exports of up to USD 5,000, including micro exports, the exporter may use the proceeds freely (Art. 22(1)).
Residents providing services to non-residents (a SaaS company selling abroad, for example) may use the FX received freely. If they sell it to a bank, the bank sells at least 35% to the CBRT and pays the seller in Turkish lira (Invisible Transactions Circular, Art. 5(1) and (2)).
The data that travels with the payment
Since 7 October 2026, domestic and cross-border wire transfer messages of TL 30,000 or more (previously TL 15,000) must carry verified originator data: name, account number or reference, and one further identifier such as an address or ID number, plus the beneficiary’s name and account number, which need not be verified (Measures Regulation, Art. 24(1), as amended by Presidential Decision No. 11845). Below the threshold, both parties’ names and account numbers are still required, without verification (Art. 24(2)). An institution receiving a message without the Art. 24(1) data must return the transfer or obtain the missing data from the sending institution (Art. 24(4)). See our MASAK article. Structured ISO 20022 fields make compliance easier, but they do not replace verification.
On EU corridors, Regulation (EU) 2023/1113, applicable since 30 December 2024, covers transfers of funds in any currency sent or received by a payment service provider established in the EU (Art. 2(1)). Its payer data set is fuller: name, account number, and address including country, official personal document number and customer identification number, or alternatively date and place of birth (Art. 4(1)). For transfers from outside the EU, the EU payee’s provider must detect missing payer or payee data (Art. 7(2)(b)) and, on a risk-sensitive basis, reject the transfer or request the information (Art. 8(1)).
Records stay in Türkiye for at least ten years (Law No. 6493, Art. 23(1)), as must primary and secondary systems and backup centres (CBRT Information Systems Communiqué, Art. 21(1)). Where one party is abroad, data may be shared with foreign third parties only as far as the transaction needs, on the customer’s request or instruction, with the data still stored in Türkiye and KVKK Article 9 respected (Art. 21(4)).
Where to start
For a PSP adding corridors:
- Check that your licence covers remittance.
- Per corridor, choose an agent abroad (30-day notice) or a foreign partner (CBRT permission).
- Build FX holding limits and the TL-only domestic rule into the ledger.
- Capture structured addresses now.
- Apply the TL 30,000 originator data rule to inbound and outbound messages, and the EU data set on EU corridors.
- Document data flows abroad under Communiqué Art. 21(4) and KVKK.
For an exporter:
- Track the 180-day deadline for each shipment.
- For marketplace or payment institution collections, get the institution’s letter and arrange bank acceptance within 30 days.
- Plan your cash flow for the 35% sale.
See also our FAST and karekod article and the fintech law hub.
Did the November 2026 structured address deadline move?
Yes. On 27 August 2026 Swift agreed to extend the structured address migration and promised an update by December 2026 at the latest; other payments changes planned for November will be phased separately.
Can export proceeds be collected through a payment institution?
Yes, but only a bank can accept them as export proceeds, within 30 days and against the institution’s letter or written confirmation that the funds came from abroad (Export Circular, Art. 8(3)).
Are the G20 targets binding on Turkish fintechs?
No. They are G20-endorsed targets coordinated by the FSB, whose activities are not binding. They do shape standards such as FATF Recommendation 16, and Turkish exchange rate disclosure duties already apply.
Sources. Law No. 6493 (Official Gazette 27.6.2013, No. 28690), Arts. 3, 12-14, 23, 28; Regulation on Payment Services and Electronic Money Issuance (Official Gazette 1.12.2021, No. 31676), Arts. 15, 18, 19, 39, 40, 66; CBRT Information Systems Communiqué (Official Gazette 1.12.2021, No. 31676), Art. 21; CBRT Export Circular, Arts. 4, 8, 22, Temporary Art. 4 (Decree No. 32; Communiqué No. 2018-32/48, Official Gazette 4.9.2018, No. 30525); CBRT Invisible Transactions Circular (18.5.2026), Art. 5; Regulation on Measures for the Prevention of Laundering Proceeds of Crime and Financing of Terrorism (Official Gazette 9.1.2008, No. 26751), Art. 24, as amended by Presidential Decision No. 11845 (Official Gazette 7.10.2026, No. 33393); Regulation (EU) 2023/1113 (OJ L 150, 9.6.2023), Arts. 2, 4, 7, 8; FSB 2021 progress report (Table 1), 2025 progress report and 12.3.2026 release; Swift ISO 20022 programme and deferral notice (27.8.2026, updated 21.9.2026).
This article is general information and not legal advice; a specific situation should be assessed with counsel.
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