Since 19 March 2026, Turkish payment institutions and electronic money institutions may put the Turkish lira balances in their customer fund protection accounts to work overnight. The Central Bank of the Republic of Türkiye (TCMB) amended the Regulation on Payment Services and Electronic Money Issuance and Payment Service Providers in Official Gazette No. 33201, effective on publication. The amendment adds a new Article 36/A on investing safeguarded funds (“nemalandırma”), moves the payment funds cut-off from 15:00 to 16:30, rewrites the e-money end-of-day rule and replaces two annexes. For a CFO, the question is no longer whether these balances can earn anything, but on what terms, with which bank, and at what liquidity cost.
Before and after 19 March 2026
Some of what was reported as new in March was already in the Regulation. The 2021 text of Article 34(3) said that investing payment funds overnight at the bank holding the protection account did not breach the safeguarding rules. Per-customer records for payment funds were also required from 2021, while the no-pledge and attachment rules (and per-customer records for e-money) date from a 2023 amendment. What March 2026 adds is a full set of conditions, the extension to e-money protection accounts and new timings.
| Issue | Before 19 March 2026 | From 19 March 2026 |
|---|---|---|
| Payment funds cut-off (Art. 34(3)) | Unpaid funds placed in the protection account as at 15:00 (half days 11:00) on the business day after receipt | 16:30 on full business days, 12:00 on half days |
| E-money end-of-day balance (Art. 35(3)) | 2021 text: the bank blocks the end-of-day balance in its account at TCMB; balance computed at 16:30 / 12:00 | Balance computed at 16:30 / 12:00 from institution records and bank movements, consistent with e-money in circulation; the blocking sentence no longer appears |
| Overnight yield | Permitted for payment funds by one sentence in Art. 34(3), with no detailed conditions; no equivalent for e-money | Art. 36/A framework for both payment and e-money protection accounts |
| Foreign currency balances | No dedicated rule | Excluded: FX protection accounts cannot be invested |
| Who uses the yield | No dedicated rule | Net yield tracked separately; the institution may use it freely |
| Bank commission | No dedicated rule | Rate and calculation method must be set out expressly in the contract |
| Attachment requests at banks | Bank holding the protection account (since 2023) | Also the bank holding the yield account |
| Licence suspended | No dedicated rule | No investment while the operating licence is temporarily suspended |
| Annexes 13 and 14 | Earlier versions | Replaced: FX notices for agents’ workplaces now state a fine of TL 719,000 to TL 3,595,000 under Law No. 1567 |
What can be invested, and where
Article 36/A(1) covers balances in both payment fund protection accounts and e-money protection accounts. Two limits follow directly from the text. First, foreign currency is out: balances in protection accounts opened in a foreign currency cannot be invested. If you hold customer funds in USD or EUR protection accounts under the currency matching rules in Articles 34(4) and 35(9), those balances stay where they are. Second, the money cannot leave the bank. Investment takes place in a yield account (“nemalandırma hesabı”) opened at the bank that already holds the protection account, and Article 35(3) now says expressly that overnight investment of the e-money protection account at that bank does not breach the safeguarding rules.
The tenor is overnight only. Under Article 36/A(5), principal protection is the governing principle and only low-risk and liquid assets may be used. The Regulation does not list those assets, so in practice the bank’s product design will decide what “low-risk and liquid” means for your balances. That is a point to settle in writing (see below), not one to assume.
The money comes back the next business day, and you pre-fund the gap
Under Article 36/A(2), principal and net yield are transferred back to the relevant protection account on the next business day, after the bank deducts its commission for the yield service and any other statutory deductions. Principal and net yield must be tracked separately.
The liquidity rule in Article 36/A(3) is the part treasury teams should read twice. While funds are invested, the institution cannot use them for any purpose. It must hold enough of its own funds to make the payments under Law No. 6493 that it has to make immediately, and it must use those funds for such payments. Once principal and net yield return to the protection account, the institution takes back an amount equal to those payments into its own accounts by the end of that day, with no interest, fee or commission-like benefit. In other words, overnight outflows are pre-funded from the institution’s own liquidity and reimbursed the next day at par. The yield has to be weighed against the cost of carrying that buffer.
One further stop: if TCMB temporarily suspends the institution’s operating licence, the safeguarded funds cannot be invested for the duration of the suspension (Article 36/A(4)). Your bank arrangements should allow investment to be switched off quickly.
Who keeps the yield
The Regulation answers this directly. The funds accumulating in the account where net yield is tracked “may be used freely by the institution” (Article 36/A(2)). The principal, of course, goes back to the protection account and keeps its protected status under Article 22 of Law No. 6493, which ring-fences these funds and accounts for fund owners on liquidation or licence revocation, regardless of priorities in other laws.
For e-money institutions, passing the yield on to holders as interest is not an option in any case. Article 20(5) of Law No. 6493 says an e-money issuer may not pay interest to the e-money holder, or provide any benefit, linked to how long the e-money is held. Product teams who see the yield as a customer feature should hear this early.
We have not found an official source on the accounting or tax treatment of the yield, beyond the Regulation’s reference to “other statutory deductions”. Confirm that point with your auditors and tax advisers before the first month-end.
Attachments, pledges and per-customer records
The rules that keep these balances out of reach of the institution’s own creditors now follow the money into the yield account. Payment funds and e-money funds cannot be pledged or shown as collateral by the institution (Articles 34(2) and 35(4)). Injunctions, attachments and similar administrative and judicial requests concerning users’ rights are handled exclusively by the institution. Requests sent to the banks holding the protection account and, after March 2026, the yield account are executed only where the bank knows the ultimate per-customer ownership of the funds, only up to the relevant fund, and the bank must inform the institution without delay.
That last condition depends on records. Article 34(5) requires per-customer records for payment funds; Article 35(4) does the same for e-money, except anonymous prepaid instruments. In our view, the daily reconciliation of your records with bank statements under Article 34(6) should now cover the yield account flows as well. The new e-money end-of-day rule in Article 35(3) leans on the same data: the balance is set from institution records and bank movements so that it matches e-money in circulation.
New cut-off times and replaced annexes
The payment funds cut-off now matches the e-money timing: unpaid payment funds are placed in protection accounts as at 16:30 on full business days and 12:00 on half days on the business day after receipt. Settlement and treasury schedules built around 15:00 can be reviewed.
Annexes 13 and 14 are the notices that an institution must have displayed at its agents’ workplaces under Article 18: foreign exchange may be bought and sold there only for payment services (Annex 13) or for payment services and e-money issuance (Annex 14), and violations can be reported to CİMER. The new versions state an administrative fine under Law No. 1567 of TL 719,000 to TL 3,595,000, revalued at the start of each calendar year. If you run an agent network, the posters need reprinting.
What to agree with the safeguarding bank
For the yield service, Article 36/A expressly requires only one contract term: the commission rate and its calculation method. The rest of the list below is our suggestion, drawn from the conditions in Article 36/A:
- commission rate and calculation method, stated expressly (mandatory);
- overnight tenor only, principal protection, and a description of the low-risk, liquid assets used;
- return of principal and net yield to the correct protection account on the next business day, with statements that show principal, gross yield, commission and statutory deductions separately;
- Turkish lira balances only, with FX protection accounts excluded at system level;
- handling of attachment requests reaching the yield account, including notice to you without delay;
- a mechanism to stop investment immediately if the licence is suspended;
- a designation of the yield account that keeps it clearly linked to, but separate from, the protection account.
Where to start
- Map your protection accounts by bank and currency; only TL balances are eligible.
- Model the liquidity buffer needed to pre-fund overnight payment obligations, and compare it with the expected net yield.
- Negotiate the yield service terms with the bank already holding your protection accounts.
- Extend daily reconciliation and per-customer records to the yield account flows.
- Move internal cut-off procedures from 15:00 to 16:30 (12:00 on half days).
- Reprint the Annex 13 or 14 notices for agent workplaces.
- Get written views from auditors and tax advisers on the yield before the first month-end.
For the wider rulebook, see our fintech law hub and the payment and e-money institution licence page. Treasury decisions this year also sit next to the new capital floors we covered in our piece on 2026 minimum equity for payment and e-money institutions.
Can foreign currency customer funds earn overnight yield?
No. Article 36/A(1) excludes balances in payment fund and e-money protection accounts opened in a foreign currency. Only Turkish lira balances can be placed in the yield account.
Can we invest safeguarded funds with a different bank offering a better rate?
No. The yield account must be opened at the bank that holds the protection account, and the e-money rule refers to overnight investment at that same bank.
Does the yield have to be passed on to customers?
The Regulation says the funds accumulating in the net yield account may be used freely by the institution. For e-money institutions, Article 20(5) of Law No. 6493 separately prohibits paying holders interest or any benefit linked to the holding period.
What happens to customer payments while funds are invested overnight?
The institution must hold enough of its own funds to make immediately payable payments and use them. After principal and net yield return the next business day, it reimburses itself the same amount by end of day, without interest, fee or commission.
Sources. Regulation Amending the Regulation on Payment Services and Electronic Money Issuance and Payment Service Providers, Arts. 1 to 5 (Official Gazette 19 March 2026, No. 33201) text and Annexes 13 and 14; Regulation on Payment Services and Electronic Money Issuance and Payment Service Providers, Arts. 18, 34 and 35 (Official Gazette 1 December 2021, No. 31676) original text; amending Regulation of 7 October 2023 (Official Gazette No. 32332) text; Law No. 6493, Arts. 20 and 22 (Official Gazette 27 June 2013, No. 28690) text, as amended by Law No. 7192 (Official Gazette 22 November 2019, No. 30956) text.
This article is general information and not legal advice; a specific situation should be assessed with counsel.
