A lending or buy now, pay later (BNPL) product in Türkiye needs a licensed lender behind it. Outside banking, the main route is a financing company (finansman şirketi) under Law No. 6361, licensed and supervised by the Banking Regulation and Supervision Agency (BDDK) and its Board. The licence comes in two steps, an establishment permit and an activity permit, and needs at least TRY 50 million of paid-in cash capital. This guide is current as of November 2026. Our fintech law hub maps the other licences.
What a financing company may and may not do
Law No. 6361 defines a financing contract as one that finances the purchase of goods or services by paying the seller directly, in the buyer’s name and for the buyer’s account, when the goods or services are delivered; the buyer repays the financing company (Art. 39(1)). It must first sign a general contract with each seller it finances, in writing or at a distance (Art. 39(2)). That is checkout credit, as our BNPL article explains.
- No general cash loans. Cash credit is allowed only as additional financing within a customer transaction, capped in total at 1% of paid-in capital; the BDDK Board may cut this to zero or raise it to 5% (Art. 9(1)(b)). A consumer cash loan app does not fit this licence.
- No deposits. Funding comes from securities issues, borrowing on international markets, shareholders, banks and money and organised markets; it may not take deposits or otherwise collect money for consideration (Art. 9(1)(ç)).
- No agents. A financing company may not organise outside its branches or appoint agents, although transactions or services through information systems within a scope the Board sets do not breach this (Art. 8(1)). Using a bank’s or another company’s premises with its own staff and systems follows the branch rules, except for product promotion and document exchange under a contract (Regulation Art. 6(10)).
- No unrelated business. It may not act outside its main field (Art. 9(1)(a)), and since an August 2025 amendment it may only set up or join subsidiaries that are credit or financial institutions, with Board permission (Regulation Art. 6(11)).
There is no separate “consumer finance company” licence; consumer lending runs under this licence, with consumer law on top.
Carrying on financing activity without the permits carries two to five years’ imprisonment and a judicial fine of up to 5,000 days (Art. 46(1)). Names or advertising implying a licence carry three months to one year (Art. 46(2)), and the BDDK can order online content removed or blocked (Art. 46(4)).
Establishment conditions
The BDDK Board grants the establishment permit by at least five members voting the same way (Art. 4(1)). The Law and the BDDK Regulation on the Establishment and Operating Principles of Financial Leasing, Factoring and Financing Companies (Official Gazette 24.4.2013, No. 28627) set these conditions:
| Requirement | Rule |
|---|---|
| Legal form | Joint-stock company; shares issued for cash and all registered (Art. 5(1)(a)-(b)) |
| Trade name | Must include “Finansman Şirketi” (Art. 5(1)(c)) |
| Capital | At least TRY 50 million paid in cash, free of any collusion; the Board may raise it (Art. 5(1)(e), 5(3)). Law No. 7292 of 2021 raised it from the original TRY 20 million |
| Founders | Not bankrupt; no 10% stake in banks taken over by the Savings Deposit Insurance Fund or in finance firms whose licence was revoked; no disqualifying convictions; financial strength; transparency; integrity (Art. 6(1)), also for 10% shareholders and controllers of corporate founders (Art. 6(2)) |
| Management | Board of at least three including the general manager; general manager with seven years’ and deputies with five years’ experience in business or finance, plus a bachelor’s degree; half the board plus one must meet the general manager’s experience test (Art. 13(2)-(3)) |
| Business plan | Activity programme with business plans, financial projections, a three-year budget and organisational structure (Art. 5(1)(ğ); Regulation Art. 4(1)(a)) |
The file is document heavy: notarised founder declarations, criminal records, sworn financial adviser reports on individual founders committing 10% or more, certified statements of corporate founders, source of funds evidence, ownership charts up to individuals, and board CVs (Regulation Art. 4(1)). Foreign bank or financial institution founders add five years of consolidated audit reports and a document from their competent bodies that their activities are not prohibited or restricted at home (Art. 4(2)). If the BDDK flags missing documents and they are not supplied within six months, the application lapses (Art. 4(5)).
From establishment permit to first loan
- Establishment permit from the Board, then incorporation and trade registry registration.
- Activity permit applied for within six months of the establishment permit (Art. 7(2); Regulation Art. 5(1)). The BDDK checks cash capital, internal control, accounting, IT and reporting systems and staffing (Art. 7(3); Regulation Art. 5(2)).
- Entry fee of 5% of the minimum capital paid to the state budget before the permit is published, which is TRY 2.5 million on the current TRY 50 million floor (Art. 7(3)(b); Regulation Art. 5(3)).
- Publication of the activity permit in the Official Gazette, from which it takes effect (Art. 7(1); Regulation Art. 5(2)).
- After launch: join the Financial Institutions Association within one month (Art. 40(1)) and start operating within one year; otherwise the Board cancels the permit (for membership, after an unheeded one-week warning) (Art. 50(1)(a)-(b)).
Ongoing rules include equity of at least 3% of total assets, below which no new financing contract may be signed (Regulation Art. 12), an internal control function (Art. 13), and Board permission for acquiring 10% or more of the shares or control (Law Art. 11(1)); unapproved transfers cannot be entered in the share ledger (Art. 11(5)), which matters to venture investors.
Consumer credit rules for BNPL
For consumer borrowers, Law No. 6502 on Consumer Protection applies. Deferring payment for interest or a similar benefit is consumer credit (Art. 22(1)), valid only if made in writing or at a distance (Art. 22(3)). Key duties: a pre-contract information form (Art. 23), a 14-day withdrawal right (Art. 24(1)), fixed rates in fixed-term contracts (Art. 25(1)), cost reductions on early repayment (Art. 27), and acceleration only after two consecutive missed instalments and a 30-day notice (Art. 28(1)).
For BNPL the key article is linked credit (Art. 30). Where credit and purchase form an economic unit, for example because the lender used the seller to prepare the credit, withdrawing from the sale (with timely notice to the lender) also ends the credit (Art. 30(3)). In our reading, financing company BNPL will usually be linked credit, because the credit pays a named seller for specific goods. If the goods are not delivered or are defective, seller and lender are jointly liable for refunds, the lender for one year and up to the credit amount (Art. 30(4)).
The BDDK Regulation adds maturity caps for financing companies: 60 months for general consumer credit, 12 months for computers, 6 months for tablets, and 12 or 3 months for mobile phones depending on whether the price is up to or above TRY 3,500 (Art. 11/A(2)). Loans above these caps are deducted from equity (Art. 11/A(4)), and the Board may change the caps (Art. 11/A(5)). Law No. 6361 sets no interest ceiling, but lets the President (or the TCMB, by delegation) fix or free maximum rates for financing companies (Art. 51(2)); the TCMB’s card rate power (Law No. 5464 Art. 26) is separate. Check for any rate decision or macroprudential measure at launch.
Digital onboarding, credit data and AML
Financing contracts may be made at a distance or by electronic methods the Board accepts (Art. 39(3)). The BDDK’s remote identification regulation for financing and similar companies (Official Gazette 11.1.2022, No. 31716) allows onboarding by live video call with a trained customer representative (Art. 4(1)), using biometric data only with explicit consent (Art. 6(2)) and NFC chip verification of the ID card (Art. 7(2)). Online services need two-factor authentication (Art. 12(1)), and a contract made electronically under Article 13(2) satisfies written form (Art. 13(3)).
Credit data runs through the Risk Center at the Banks Association of Türkiye, which credit institutions and financial institutions approved by the Board must join and supply with customer data (Banking Law No. 5411, Additional Art. 1). Financing companies are also obliged parties for anti-money laundering purposes (MASAK Measures Regulation Art. 4(1)(ç)).
Bank partner, financing company or payment institution?
| Model | Who lends | Main constraint |
|---|---|---|
| Bank partner | The bank (Law No. 5411 Art. 4) | Banks cannot outsource credit assessment or credit decisions (Support Services Regulation Art. 4(1)(b)) |
| Financing company partner | The licensed financing company | Platform signs the general contract as seller or provides technology; the lender cannot appoint agents (Art. 8(1)) |
| Own financing company | The fintech itself | TRY 50 million capital, two BDDK permits, purchase financing only, 3% equity ratio |
| Payment or e-money institution | Nobody | May not lend (Law No. 6493 Arts. 14(4), 20(4)); intermediated amounts may not be split into instalments (TCMB Regulation Art. 16(1)) |
A payment licence does not open BNPL, but a product can pair a payment or e-money licence for wallets and collections with a lender for the credit leg. Our BaaS and embedded finance guide covers the partnership side.
Where to start
- Map the product: does every credit pay a seller directly, or is any of it cash to the customer?
- Decide partner or own licence, and budget TRY 50 million capital plus a TRY 2.5 million entry fee.
- Line up founders and 10% shareholders who pass Article 6, a qualified general manager, the activity programme and source of funds evidence.
- Design maturities, the pre-contract form, withdrawal and linked credit flows to Law No. 6502 and Article 11/A.
- Build remote identification, two-factor authentication, Risk Center reporting and AML controls before applying for the activity permit.
- Check the BDDK’s list of financing companies and the Official Gazette for current licensees and capital changes.
How much capital does a financing company need in Türkiye?
At least TRY 50 million of paid-in cash capital (the BDDK Board may raise it) plus a 5% entry fee. Capital must also fit the business plan and the 3% equity to assets ratio.
Can a payment institution offer BNPL instalments?
No. Payment and e-money institutions may not lend, and the TCMB Regulation bars them from splitting the amounts they intermediate into instalments. The credit must come from a bank or a licensed financing company.
Can a financing company give cash loans to consumers?
Only marginally: cash credit within a customer transaction is capped in total at 1% of paid-in capital unless the Board changes the ratio.
Sources. Law No. 6361 on Financial Leasing, Factoring, Financing and Savings Financing Companies (Official Gazette 13.12.2012, No. 28496, consolidated), Arts. 4-9, 11, 13, 17, 39, 40, 46, 50, 51; original text of Law No. 6361, Art. 5; BDDK Regulation on the Establishment and Operating Principles of Financial Leasing, Factoring and Financing Companies (Official Gazette 24.4.2013, No. 28627, consolidated to 27.8.2025, No. 32999), Arts. 4-6, 11/A, 12, 13; BDDK Regulation on Remote Identification Methods and Electronic Contracting for Leasing, Factoring, Financing and Savings Financing Companies (Official Gazette 11.1.2022, No. 31716), Arts. 4, 6, 7, 12, 13; Law No. 6502 on Consumer Protection (Official Gazette 28.11.2013, No. 28835, consolidated), Arts. 22-28, 30; Law No. 5464 on Bank Cards and Credit Cards (Official Gazette 1.3.2006, No. 26095), Art. 26; Banking Law No. 5411 (Official Gazette 1.11.2005, No. 25983 bis), Art. 4 and Additional Art. 1; Regulation on Banks’ Procurement of Support Services (Official Gazette 5.11.2011, No. 28106), Art. 4; Law No. 6493 (Official Gazette 27.6.2013, No. 28690), Arts. 14, 20; TCMB Regulation on Payment Services and Electronic Money Issuance and Payment Service Providers (Official Gazette 1.12.2021, No. 31676, consolidated), Art. 16; MASAK Measures Regulation (Official Gazette 9.1.2008, No. 26751), Art. 4.
This article is general information and not legal advice; a specific situation should be assessed with counsel.
