Fintech in Türkiye is a licensing question before it is a product question. Whether a business moves money, issues stored value, holds crypto-assets for customers, runs crowdfunding campaigns or builds credit into a checkout, a different regulator, statute and permission sits behind it, and that answer shapes the company’s capital, shareholders, systems and timetable long before launch. Vircon Legal advises fintechs, crypto-asset service providers, crowdfunding platforms and the investors behind them, with the founder side as our centre of gravity: the team working out which licence it actually needs, raising the round that pays for it, or taking a Turkish product across a border.
Who regulates what
The first map we draw with a fintech client: which activity, which authority, which instrument.
| Activity | Regulator | Main instrument |
|---|---|---|
| Payment institutions and electronic money institutions, including payment initiation and account information services | Central Bank of the Republic of Türkiye (TCMB) | Law No. 6493, as amended by Law No. 7192 (licensing authority moved to TCMB from 1 January 2020) |
| Crypto-asset service providers: platforms, custody institutions and other providers designated by the Board | Capital Markets Board (SPK) | Capital Markets Law No. 6362, Arts. 35/B and 35/C, added by Law No. 7518 (Official Gazette 2 July 2024) |
| Equity- and debt-based crowdfunding platforms | Capital Markets Board (SPK) | Law No. 6362, Art. 35/A; Crowdfunding Communiqué (III-35/A.2), Official Gazette 27 October 2021 |
| Banks, including branchless digital banks and banking offered to fintechs as a service model | Banking Regulation and Supervision Agency (BDDK) | Banking Law No. 5411; Regulation on the Operating Principles of Digital Banks and Service Model Banking, Official Gazette 29 December 2021 |
| Financing companies (alongside financial leasing and factoring companies) | Banking Regulation and Supervision Agency (BDDK) | Law No. 6361 |
| Anti-money laundering and customer identification | Financial Crimes Investigation Board (MASAK) | Law No. 5549 and the Regulation on Measures, Official Gazette 9 January 2008; for crypto-asset service providers also Law No. 6362, Art. 35/C |
Two points in that table shape most fintech business plans. Law No. 6493 names banks, electronic money institutions, payment institutions and the postal operator PTT as the payment service providers and bars anyone else from providing payment services (Art. 13), so a product that provides payment services needs a licensed home, its own or a partner’s. And a crypto-asset service provider may not be established or start operating without SPK permission (Law No. 6362, Art. 35/B), which makes the licence route, rather than the token or the app, the critical path.
What we advise on
Our fintech and payments practice covers:
- Payment and e-money licensing: choosing between a payment institution and an electronic money institution licence, the TCMB application file, shareholder and management qualifications, capital and safeguarding of customer funds, and the partner-bank and agent arrangements that sit around the licence
- Crypto-asset service providers (KVHS): SPK licensing for platforms and custody, client agreements, listing procedures, advertising and campaign rules, transfer messaging under the travel rule, and the ongoing compliance programme after authorisation
- Crowdfunding: platform listing with SPK, equity- and debt-based campaign structures, investment committee and campaign documentation, and the companies raising through platforms
- BNPL and lending products: whether a deferred-payment or credit feature is in fact a loan, which licence or partner it needs, and how consumer-facing rules attach to it
- Open banking and data sharing: payment initiation and account information services, which Law No. 7192 added to the payment services listed in Law No. 6493, and the data-sharing rules TCMB is empowered to set for them
- AML/KYC and remote onboarding: MASAK obligations, customer identification, risk-based onboarding and remote identity verification for app-first products
- KVKK and information systems: personal data processing and cross-border transfers under the KVKK regime, and the information-systems and technology requirements that regulators attach to a licence
- Funding rounds and token instruments: SAFE and priced rounds for fintechs, the shareholder and share-transfer rules a licence brings into a round, token warrants, future token sales and public token offerings
- Cross-border: Turkish fintechs entering the EU under MiCA and PSD2, with an eye on the PSD3 and Payment Services Regulation package, on which the co-legislators have reached provisional agreement but which is pending formal adoption as of October 2026, and foreign fintechs assessing Türkiye
The founder side of a licence
Most of the value we add sits before the application rather than after it. The licence decides how much capital the company must hold, who can sit on its cap table and board, and which systems it must run, so it belongs in the first financial model and the first term sheet, not in a later workstream. A round priced without the licence in view can promise investors rights that later have to be reconciled with the regulator’s rules on shareholders and share transfers. A product launched through a partner can turn out to need its own permission once it grows. All of it is cheaper to settle early.
Our Payment & E-Money Licence Checklist and CASP License Obligation Checklist set out the questions a Turkish fintech is asked on each route.
Representative work
- Remedi Finance, a financial-services and DeFi-adjacent platform, on its pre-seed round backed by Turkish and U.K. angels
- Upsonic, which builds AI agents for fintech and banking institutions, on its pre-seed round backed by U.S. angels, Inveo and Vestel
- Fongogo, which operated in crowdfunding and alternative financing, on its USD 163,296 seed round from a multi-angel syndicate
- Gameness on its public coin offering
- Best In Slot, Bitcoin-native digital-asset infrastructure, on its investment round from Hyperithm, Sora Ventures and UTXO Management
- Covalent, for which we managed the SAFE round and the parallel token warrant process
- Angelic on its future token sales backed by Animoca Brands, Solana Ventures and 37 investors
- Janus Interactive on its token sale led by Evox Capital
- Goart Metaverse on its pre-seed round led by Islamic Coin
In the sector
We also take part in the sector’s own conversations. Our Managing Partner Erdem Mümtaz Hacıpaşaoğlu chaired and acted as rapporteur of the Regulation Committee at the İSTKA-FINTECH Open Innovation Workshop, spoke on the Building the Future by Binance TR stage at Webrazzi Fintech 2025 and, at Webrazzi Fintech 2024, on panels on digital asset custody and Web3 startups in Türkiye. He gave the KVKK and GDPR session for fintechs at Finext, contributed to Craftgate’s 2025 Fintech Trends report, discussed the Travel Rule on an OKX Türkiye broadcast, was on the faculty of the Fintelogy crypto-asset compliance certificate programme, and wrote CoinDesk Türkiye columns on the crypto-asset amendment to the Capital Markets Law and SPK principle decisions. The thread goes back to 2018 and a talk on crowdfunding and ICOs at the Istanbul Bar Association’s fintech session.
Building a crypto-asset platform or custody business? See our CASP / Crypto Compliance service for SPK licensing and ongoing compliance.
Reading
- Türkiye Raises the Fintech Capital Bar Again: new minimum equity floors for payment and e-money institutions
- The CASP Licence in Türkiye: an application guide in build order
- The Law of BNPL in Turkey: when a payment feature is in fact a loan
- AI Credit Scoring: the four-floor compliance stack for fintechs
- Türkiye’s Crypto Advertising and Sweepstakes Rules: the banned pages of the growth playbook
- The Digital Precious Metals Communiqué: Türkiye’s first official RWA move
- Real-World Asset Tokenization and Turkey: the token is easy, the law is hard
- Crypto Licence in Portugal vs Türkiye: MiCA CASP authorisation and the Turkish CASP licence compared
- Payment & E-Money Licence Checklist and CASP License Obligation Checklist: the two licence routes, item by item
Related practice areas
This practice works alongside Crypto Assets, Web3 & Regulated Digital Markets, Crowdfunding, Privacy & Cybersecurity, Startup Law and US Company Formations & Flip-Ups, because a fintech question rarely sits in one bucket.
Sources. Law No. 6493 on Payment and Securities Settlement Systems, Payment Services and Electronic Money Institutions, Arts. 3, 13, 14 and 18 (Official Gazette 27.06.2013, No. 28690; Art. 13 as amended, in the consolidated text); Law No. 7192, Arts. 8, 9, 10, 17 and 18 (Official Gazette 22.11.2019, No. 30956); Law No. 7518 amending Capital Markets Law No. 6362, adding Arts. 35/B and 35/C (Official Gazette 02.07.2024, No. 32590); Crowdfunding Communiqué (III-35/A.2), Arts. 1 to 3 (Official Gazette 27.10.2021, No. 31641); Regulation on the Operating Principles of Digital Banks and Service Model Banking, Arts. 1 and 2 (Official Gazette 29.12.2021, No. 31704); Law No. 6361, Arts. 3, 4 and 7 (Official Gazette 13.12.2012, No. 28496); Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism, Arts. 1 to 3 (Official Gazette 09.01.2008, No. 26751); European Parliament Legislative Observatory, procedures 2023/0209(COD) and 2023/0210(COD); Council of the EU, state of play of financial services legislative proposals, doc. 13589/26 of 2 October 2026.
This article is general information and not legal advice; a specific situation should be assessed with counsel.