🇹🇷Türkçe okuyucu musunuz? Bu yazının Türkçe versiyonu:Ekim 2026'da Ne Değişti? Startup, Fintech ve Teknoloji Şirketleri İçin Aylık Mevzuat Özeti →
This page brings together, in one set of tables, the rules published or brought into force in Türkiye in October 2026 that matter to startups, fintechs and technology companies. Each row says who is affected, what to do and the relevant date; the link in each row leads to our full article. We have also added two regulations published at the end of September that came onto the agenda in October, and two EU developments.
Company law and capital
| What changed | Who is affected | What to do | Date |
|---|---|---|---|
| Minimum capital deadline extended to 31 December 2027 (Ministry of Trade communiqué, Official Gazette 17.10.2026, No. 33403). Amounts and sanction unchanged. Article; for startups, folding it into a round | Joint-stock companies with capital below TRY 250,000 and limited companies below TRY 50,000 | Plan the increase; the prudent reading is that it must be registered with the trade registry by the deadline. A company that misses it is deemed dissolved. | 31.12.2027 |
| TCC Article 376 FX-loss relief extended to 1 January 2028 (Official Gazette 10.10.2026, No. 33396). Article | Companies with foreign-currency debt approaching the capital-loss or over-indebtedness thresholds | FX losses on foreign-currency obligations not yet performed can be left out of the Article 376 calculation; document the calculation with the board for the year-end 2026 and interim 2027 balance sheets. | Calculations until 1.1.2028 |
Fintech, payments, crypto and capital markets
| What changed | Who is affected | What to do | Date |
|---|---|---|---|
| MASAK identification thresholds doubled (Presidential Decision No. 11845, Official Gazette 7.10.2026). General threshold TRY 185,000 to TRY 370,000; for CASPs and for wire and crypto transfers TRY 15,000 to TRY 30,000. Article | Banks, payment and e-money institutions, crypto-asset service providers | Update the thresholds in onboarding, monitoring and transfer messages, including the Travel Rule. | In force since 7.10.2026 |
| MASAK hawala and money mule STR guides (September and October 2026). No new obligations, but they will be the yardstick in audits. Article | Payment and e-money institutions, CASPs | Add the guides’ indicators to monitoring scenarios; write into your procedure that an account is made unusable after an STR. | Now |
| SPK qualified investor threshold raised to TRY 50 million; GSYF and GYF carve-out removed (SPK, 26.10.2026). Article | Venture capital and real estate fund managers, companies investing in GSYFs, startups raising from funds | Review ongoing fundraisings and investor eligibility documents against the new thresholds. | Effective date and transition rules to follow in the Principle Decision text |
Personal data, health and location data
| What changed | Who is affected | What to do | Date |
|---|---|---|---|
| KVKK: a phone call is not a valid response to a data subject request (Authority announcement, 1.10.2026). Article | All data controllers | You may talk to the data subject while assessing the request, but give the final response in writing or electronically. | Within 30 days of each request (KVKK Art. 13) |
| KVKK Principle Decision 2026/2035 on monitoring employee email (Official Gazette 8.10.2026, No. 33394). Sixteen rules. Article | Every company with employees in Türkiye that uses email, chat or a CRM | Adopt a monitoring policy and notice; do not rely on explicit consent; keep reading message content as a last resort. | In force; the Board said it will act under KVKK Art. 18 |
| Geographic Data Permits Regulation (Official Gazette 14.10.2026, No. 33400), replacing two 2021 regulations. Article | Companies that collect, produce, share or sell location data for commercial purposes, foreign companies included | Check whether your activity needs a permit; a company found operating without one gets 15 days to apply. | In force on publication; existing permits valid until they expire |
| Electronic informed consent regulation (Official Gazette 27.10.2026, No. 33413): consent to medical intervention via e-Nabız or SMS one-time password. Article | Hospitals, healthcare facilities, health information system vendors | The electronic route is optional. If you use it, set up audit logs and qualified timestamps; do not confuse informed consent with KVKK explicit consent. | In force on publication |
Platforms: social networks and games
| What changed | Who is affected | What to do | Date |
|---|---|---|---|
| Under-15 social media ban and age verification regulation (Law No. 7578; Regulation, Official Gazette 10.10.2026, No. 33396). Regulation article, statute article | Domestic and foreign social network providers accessible from Türkiye | Age verification with an e-Devlet token for new accounts; a differentiated service for 15 to 17 year olds (no public accounts, live streaming, infinite feeds or personalised ads). | In force since 1.11.2026; existing accounts to be verified by 31.3.2027 |
| Law No. 5651 game platform regime in force (Law No. 7578, Art. 27(1)(a)). Guide | Game platforms; foreign platforms with more than 100,000 daily accesses from Türkiye must appoint a representative | Age rating, parental controls, a Türkiye representative and a 15-day information request process. The regulation setting the rating method has not yet been published. | In force since 1.11.2026 |
Published at the end of September, on the agenda in October
| What changed | Who is affected | What to do | Date |
|---|---|---|---|
| Hybrid work written into the regulation (Remote Working Regulation Art. 9(2), Official Gazette 25.09.2026, No. 33381). Article | Employers with hybrid teams | Write office and remote days and working hours into the employment contract or an addendum. | In force on publication; no transition period |
| Türkiye Green Taxonomy Regulation (Official Gazette 24.09.2026, No. 33380). Guide | Companies seeking financing; banks and other financial institutions | Reporting is voluntary for companies; banks report under the taxonomy from 1 January 2029, so the classification will come up at the credit desk. | 1.1.2029 for financial institutions |
Two EU developments
| What changed | Who is affected | What to do | Date |
|---|---|---|---|
| CJEU C-70/25: refund first in phishing cases (15.10.2026). Article | Turkish groups with an EU-licensed payment or e-money institution | In the EU entity, refund unauthorised transactions by the next business day and prove gross negligence later. In Türkiye, TCMB Regulation Art. 54(3) allows a reasonable investigation on strong suspicion. | With the judgment |
| PSD3: Council position at first reading (doc. 8535/26, 21.10.2026). PSD3 and PSR article | Payment and e-money institutions operating in the EU | Plan for re-authorisation, payee name checks and refunds for impersonation fraud. | Generally 21 months after entry into force |
Calendar: dates ahead
- 31 December 2026: the TCC Article 376 relief can be applied to the year-end 2026 balance sheet.
- 28 February 2027: the UK crypto-asset authorisation application window closes; details for Turkish platforms with UK users.
- 31 March 2027: deadline for verifying social network accounts opened before 1 November 2026 with an e-Devlet token.
- 31 December 2027: minimum capital deadline.
- 1 January 2029: green taxonomy reporting for financial institutions.
- Awaited: the text and transition rules of the SPK qualified investor Principle Decision; the regulation setting the age rating method for game platforms.
All our fintech coverage is on our fintech law page.
Frequently asked questions
Which October 2026 change matters most to startups?
The extension of the minimum capital deadline to 31 December 2027. Joint-stock companies below TRY 250,000 and limited companies below TRY 50,000 can plan the increase together with their next funding round; the amounts and the dissolution sanction are unchanged.
When did the MASAK threshold change take effect?
On 7 October 2026, on publication of the Presidential Decision. The general identification threshold is now TRY 370,000, and the threshold for CASPs and for wire and crypto transfers is TRY 30,000.
Which rules took effect on 1 November 2026?
The game platform obligations in Law No. 5651, and the under-15 social media ban with its age verification regulation. Existing social network accounts must be verified by 31 March 2027.
How often will this roundup be published?
At the start of each month, covering the previous month.
Sources. The link in each row leads to our article on the topic, with primary citations to the Official Gazette, SPK, MASAK, KVKK and EU sources.
This page is general information and not legal advice; a specific situation should be assessed with counsel.
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