Providing payment services or issuing electronic money in Türkiye requires a permit from the Central Bank of the Republic of Türkiye (TCMB), which has licensed and supervised payment and e-money institutions under Law No. 6493 since 1 January 2020. Since 30 June 2026 the minimum own funds floor has been TRY 40 million for most payment institutions and TRY 105 million for e-money institutions, and 2026 amendments allow overnight investment of safeguarded funds and expressly provide for biometric or e-ID verification in remote onboarding. Vircon Legal, as part of its fintech law practice, works with founders and foreign PSPs and EMIs from the licence choice to the final approval file and beyond.
Talk to us → Payment and e-money licence checklist
Which licence do you need?
A payment institution provides the payment services listed in Article 12 of Law No. 6493. An electronic money institution issues e-money and may also provide those services. Either way, the permit covers only the services TCMB names in its final approval, so the scope you apply for matters as much as the licence type.
| Payment institution | E-money institution | |
|---|---|---|
| Legal basis | Law No. 6493, Art. 14 | Law No. 6493, Arts. 18 and 20 |
| What it may do | The Art. 12 services in its permit; payment accounts only for payment transactions | Issue e-money at par against funds received, plus the payment services in its permit |
| Key limits | No lending, deposits or interest; no payment instrument linked to a payment account for use at merchants | No lending, deposits or interest on e-money; redemption by the end of the next business day |
| Paid-in capital (statute) | TRY 1 million (bill payment), TRY 2 million (others); none for account information only | TRY 5 million |
| Minimum own funds from 30 June 2026 | TRY 20 million (bill payment only), TRY 40 million (others, except account information only) | TRY 105 million, and at least 2% of average outstanding e-money |
| Minimum collateral at TCMB | TRY 2 million (bill payment only), TRY 3 million (others), rising with customer numbers | TRY 5 million, rising with customer numbers |
Article 12(1) lists: operating payment accounts, including cash in and out; money transfers, including direct debits, card payments and standing orders; issuing or acquiring payment instruments; money remittance; payments authorised through a telecom or IT device where the operator only intermediates; bill payment intermediation; payment initiation; account information; and other services reaching a level set by TCMB. A merchant-facing wallet with funds passing through the provider requires an e-money authorisation (Regulation, Art. 4/A).
Requirements
- Legal form: a joint-stock company with shares issued for cash and all registered, and a trade name showing it is a payment or e-money institution. The statutory capital must be fully paid in cash early in the process.
- Capital and own funds: paid-in capital is the statutory minimum above. Own funds, calculated at the end of June and December, must not fall below either the fixed floor in the TCMB communiqué of 31 January 2026 or a volume-based figure (4% of the first TRY 50 million of payment volume, then lower rates). TCMB may raise the calculated amount by up to 50%.
- Shareholders: holders of 10% or more and controllers must meet the qualifications the Banking Law No. 5411 requires of bank founders, at least one shareholder must meet the qualified shareholder conditions, and the structure must not obstruct supervision.
- Management: a board of at least three including the general manager, who needs a bachelor’s degree and seven years’ experience in business administration or finance. Non-executive internal control and risk staff report to the board twice a year.
- Information systems and data localisation: under TCMB’s information systems communiqué, primary and secondary systems and backup centres must be in Türkiye, as must the systems outsourced providers use for payment transactions. Records are kept in Türkiye for at least ten years.
- Safeguarding: customer funds are segregated, cannot be pledged and go into a safeguarding account at a Turkish bank (payment funds unpaid by 16:30 on the next business day; e-money funds by the end of the business day), reconciled daily. Collateral is also held at TCMB.
- Association membership: every institution must apply to the Payment and Electronic Money Institutions Association of Türkiye within one month of its permit.
- MASAK: compliance with Law No. 5549 and its secondary legislation, customer identification, money laundering and terrorist financing risk in the risk framework, and checks against use for illegal betting (see our MASAK note).
- Outsourcing: the payment service and e-money issuance cannot be outsourced; IT, marketing, call centre and similar functions can, under a written contract reported to TCMB.
Process and timeline
The periods below are regulatory; overall duration depends on the file and TCMB’s review.
- Pre-application notice: before registering the trade name, file the EK-11 forms and draft articles with TCMB and pay the non-refundable TRY 500,000 application fee. Gaps must be cured within three months; TCMB then issues an application certificate.
- Intelligence review: filed within six months of the certificate, with the business plan and programme of operations, notarised shareholder declarations, criminal records, sworn financial adviser reports and the EK-15 checklist.
- Final approval: filed within 120 days of the intelligence approval (extendable by up to 60 days), with an independent audit report on capital, own funds, internal control, risk management, accounting and complaint units, its information systems part prepared by an auditor on BDDK’s list for bank IS audits; proof of insurance and collateral; an Interbank Card Center (BKM) document for payment initiation or account information; and an office report. TCMB then inspects management, staff, office, equipment and records on site.
- Decision: TCMB decides within six months of a complete file and gives reasons for a refusal. Gaps not cured within six months at either stage end the application. The permit takes effect on publication in the Official Gazette.
- Launch: notify TCMB within ten days of starting operations and pay the TRY 1 million licence fee. A permit not used within a year may be revoked.
Recent changes
- Own funds (Official Gazette 31 January 2026, No. 33154): floors of TRY 20 million, 40 million and 105 million, up from 15, 30 and 80 million, in force since 30 June 2026.
- Overnight investment (Official Gazette 19 March 2026, No. 33201): new Article 36/A allows Turkish lira balances in safeguarding accounts to be invested overnight at the safeguarding bank (foreign currency accounts excluded), with principal protection and only low-risk, liquid assets. Principal and net return go back the next business day; the return can be used freely. The safeguarding cut-off moved from 15:00 to 16:30 (11:00 to 12:00 on half days).
- Remote identification (Official Gazette 4 September 2026, No. 33360): Article 41(4) now covers remote framework contracts with verification by biometric methods or identity documents with electronic verification capability. The same-day communiqué amendment makes NFC chip reading the primary check, with OCR or card reader fallbacks, and allows non-Turkish nationals to be identified remotely with an NFC passport meeting ICAO 9303.
What Vircon Legal handles
- Licence mapping: matching your product to the Article 12 services and choosing between a payment institution, an e-money institution or an agent or partner model.
- Corporate set-up: company formation, share structure and a capital plan against both capital tests.
- Shareholder and management file: declarations, undertakings and supporting documents, including documents from abroad.
- Business plan and policies: programme of operations, fund flows, safeguarding, internal control, risk, complaints, outsourcing and agent policies.
- AML and onboarding: the MASAK framework and remote identification flows under the 2026 rules.
- Contracts: framework, merchant, agent, safeguarding bank and outsourcing agreements.
- TCMB process and after: coordinating auditors and filings, answering TCMB requests, then Association membership, share transfer and scope approvals and change notifications.
Documents we will ask for
- Product description with fund flows, target customers and markets
- Group chart up to the ultimate natural person owners
- Source of capital and financial statements of corporate shareholders
- CVs of the proposed board members and general manager
- Any foreign licence and a home supervisor letter (for foreign groups)
- Technology architecture, hosting plan and intended outsourcing providers
Frequently asked questions
We are a licensed EMI abroad. Can we serve customers in Türkiye under that licence?
No. Payment services require a TCMB permit held by an institution established in Türkiye, and unlicensed activity carries one to three years’ imprisonment. The options are a licensed Turkish subsidiary or cooperation with a Turkish institution under Article 19 of the Regulation, which is limited to payments where the sender or recipient is abroad, needs TCMB permission for the foreign partner, and bars that partner from being the sole visible face of the service or running a website aimed at Turkish residents.
Can we start through an agent model instead of our own licence?
A licensed institution may provide services through agents over physical or electronic channels. Each agent signs a written contract and must be registered in the Association’s list, notified within 15 business days, before it is used. The licensed institution remains the provider, must select and monitor agents with care and holds extra collateral of TRY 500,000 per 1,000 agents.
Can a payment institution issue e-money or run a wallet?
It cannot issue e-money: only banks, the postal operator PTT and licensed e-money institutions may do so. A digital wallet requires at least an authorisation to issue payment instruments, but a payment institution may not issue a payment instrument linked to a payment account for use at merchants, and a merchant-facing wallet with funds passing through the provider needs an e-money authorisation. Any new service area after the permit needs TCMB approval.
Do BNPL or crypto products fit under these licences?
No. Payment and e-money institutions may not lend and may not split the amounts they process into instalments, so BNPL structures need another legal basis. TCMB’s 2021 regulation bans crypto assets in payments and bars these institutions from handling fund transfers to or from crypto platforms; crypto services sit in a separate regime (see our CASP licence guide).
Sources. Law No. 6493, Arts. 12-18, 20-23, 25, 28 and Additional Art. 1 (consolidated text), as amended by Law No. 7192 (Official Gazette 22 November 2019, No. 30956); TCMB Regulation on Payment Services and Electronic Money Issuance and Payment Service Providers, Arts. 4, 4/A, 6, 11, 15-16, 18-19, 21-27, 33-36/A, 41 (Official Gazette 1 December 2021, No. 31676; consolidated text), amended in No. 33201 and No. 33360; TCMB Information Systems Communiqué, Arts. 21-22 (same Gazette; amended in No. 33360); TCMB own funds communiqué (Official Gazette 31 January 2026, No. 33154); TCMB Regulation on the Non-Use of Crypto Assets in Payments, Arts. 3-4 (Official Gazette 16 April 2021, No. 31456).
This article is general information and not legal advice; a specific situation should be assessed with counsel.