Money is moving onto ledgers in three forms: private stablecoins, tokenised bank deposits and central bank money for wholesale settlement. On 21 September 2026 the Eurosystem launched Pontes, which settles wholesale tokenised asset transactions in central bank money. The EU has applied its stablecoin rules since 30 June 2024, and the US GENIUS Act takes effect by 18 January 2027 at the latest. Türkiye has none of these regimes. What it has is a 2021 ban on using crypto assets in payments, a crypto-asset licensing law with no stablecoin category and a MASAK communiqué that caps stablecoin withdrawals from platforms. Here is what that means, as of October 2026, for Turkish fintechs, treasurers and founders.
Three forms of tokenised money
What separates them is who owes the holder money. A stablecoin is a token a private issuer promises to keep at a stable value, usually against the dollar or euro. A tokenised deposit is a bank deposit recorded on a distributed ledger, so the claim stays a claim on the bank. Central bank digital money is a liability of the central bank itself, in a retail form for the public or a wholesale form for banks and market infrastructures.
| Feature | Stablecoin | Tokenised deposit | Central bank digital money |
|---|---|---|---|
| Issuer | Private issuer (in the EU, e-money tokens only by credit institutions or e-money institutions) | A bank | The central bank |
| Legal nature | EU: asset-referenced or e-money token, the latter deemed electronic money. US: “payment stablecoin” | A deposit. The EBA says tokenisation “does not per se alter” that qualification; MiCA excludes deposits | Central bank money. TCMB calls the digital Turkish lira “a form of fiat money”, not a crypto asset |
| Interest | Banned for e-money tokens (MiCA Art. 50) and US payment stablecoins (GENIUS Act Sec. 4(a)(11)) | Possible, as with any deposit | TCMB’s main scenario is non-interest-bearing |
| Turkish status (October 2026) | Crypto asset under Law No. 6362; cannot be used in payments (TCMB Regulation); platform withdrawals capped (MASAK Communiqué No. 29) | No specific rule; deposit-taking reserved to credit institutions (Banking Law Art. 60) | Digital Turkish lira in its second R&D phase; no circulation decision announced |
The Turkish starting point: no crypto in payments
TCMB’s Regulation on the Disuse of Crypto Assets in Payments (Official Gazette 16 April 2021, No. 31456) has applied since 30 April 2021; the consolidated text still matches the original. Article 3(2): crypto assets “shall not be used directly or indirectly in payments”. Article 3(3): no service may be provided that involves such use. Article 4(1): payment service providers may not build business models that use crypto assets directly or indirectly in payment services or e-money issuance. Article 4(2): payment and e-money institutions may not intermediate fund transfers to or from crypto trading, custody, transfer or issuance platforms.
Its crypto-asset definition excludes anything classed as “fiat money, deposit money, electronic money, payment instrument, securities, or other capital market instruments”. In our reading a dollar stablecoin falls inside the definition. Whether a licensed lira e-money product on a ledger would fall outside it is unclear.
Stablecoins in Turkish crypto and AML law
Law No. 7518 (Official Gazette 2 July 2024, No. 32590) added a broad crypto-asset definition to Capital Markets Law No. 6362, Article 3(1)(bb): intangible assets created and stored electronically with distributed ledger or similar technology, distributed over digital networks, that “can represent value or rights”. Crypto-asset service providers need a Capital Markets Board (SPK) licence under Article 35/B. Under Article 99/A(1), a foreign platform targeting Turkish residents is an unlicensed provider; a workplace in Türkiye, a Turkish-language website or marketing to Turkish residents each suffices. Law No. 6362 has no separate stablecoin category, so a USDT or USDC balance is simply a crypto asset. See our CASP compliance page.
The nearest thing to a stablecoin rule is MASAK General Communiqué No. 29 (Official Gazette 28 June 2025, No. 32940). Article 4(4) covers crypto assets that “aim to maintain a stable value by referencing another value, right or a combination of them, including one or more official currencies”. Withdrawals intermediated by platforms, including transfers to other platforms, are capped at the equivalent of USD 3,000 a day and USD 50,000 a month, and the caps may be doubled where Article 24/A(1) of the Measures Regulation (full travel-rule data) applies. Article 4(3), which applies to all crypto assets, adds a 48-hour wait after purchase, swap or deposit (72 hours for a first withdrawal) for withdrawals to unhosted wallets or to foreign providers without data-sharing duties. The wider picture is in our MASAK obligations guide.
A lira stablecoin and the e-money question
This section is our analysis, not a regulator’s position. Law No. 6493 Article 3(1)(ç) defines electronic money as monetary value issued against funds received, stored electronically, used for payment transactions and accepted as a means of payment by persons other than the issuer. A redeemable lira token used by third parties for payments fits closely. Article 18(1) reserves e-money issuance to banks, PTT and e-money institutions licensed by TCMB, and Article 28 punishes acting like an e-money institution without a licence with one to three years’ imprisonment and a judicial fine of up to 5,000 days. Taking repayable funds from the public could also engage Banking Law No. 5411 Article 60, which reserves deposit-taking to credit institutions.
A licence does not end the problem. The same token would very likely be a crypto asset under Law No. 6362, and the TCMB Regulation bars payment service providers from using crypto assets in e-money issuance. MiCA bridged this overlap by deeming e-money tokens to be electronic money; Türkiye has no equivalent. SPK Communiqué III-35/B.2 Article 16(4) also requires a platform selling or distributing as a token an asset that falls within another authority’s remit to confirm that authority’s requirements are met, so a platform distributing a lira token would have to confirm compliance with TCMB rules too.
Tokenised deposits are simpler. The EBA’s December 2024 report found that recording a deposit claim on a ledger “does not per se alter the fundamental nature of the claim and thus its regulatory qualification as a deposit”. Turkish law has no tokenised deposit rule; a Turkish bank’s deposit on a ledger would, on ordinary principles, remain a deposit under the Banking Law. Whether the TCMB payments ban could reach such a token is untested, although its definition excludes “deposit money”.
Digital Turkish lira and wholesale central bank money
TCMB’s Second Phase Progress Report (24 November 2025) describes the digital Turkish lira as “the digital form of the Turkish lira”, issued by the central bank and accessed through financial intermediaries in a two-tier structure, and states that “digital money is not a crypto asset”. If a circulation decision is made, a third phase will handle the legal processes. On 3 August 2026 TCMB announced that 23 projects from 12 banks and 6 payment and e-money institutions had reached the third stage of its ecosystem call, with development and sandbox testing; 15 of them involve tokenisation.
The euro area has moved further on wholesale. According to the ECB, Pontes “enables wholesale transactions in tokenised assets to be settled in central bank money”, with full implementation expected by 2028. Under Appia, the Eurosystem aims to deliver a blueprint for an integrated DLT-based ecosystem by 2028. TCMB’s progress report announces no comparable wholesale settlement service.
EU and US rules a Turkish firm will meet
MiCA (Regulation (EU) 2023/1114) has applied Title III (asset-referenced tokens) and Title IV (e-money tokens) since 30 June 2024. An e-money token references one official currency; under Article 48(1) it may be offered to the public in the Union only by its issuer, which must be an authorised credit institution or e-money institution, or by others with the issuer’s written consent, and Article 48(2) deems it electronic money. Holders may redeem at par at any time, without a fee (Art. 49). Issuers may not grant interest (Art. 50). An asset-referenced token issuer must be an authorised EU-established entity or a credit institution (Art. 16(1)).
The GENIUS Act (Public Law 119-27) was approved on 18 July 2025. Under Section 20 it takes effect on the earlier of 18 months after enactment (18 January 2027) or 120 days after final implementing regulations. Only permitted issuers may issue payment stablecoins in the US; they must hold reserves “on an at least 1 to 1 basis” and may not pay interest or yield. Three years after enactment, digital asset service providers may not offer non-permitted payment stablecoins to US persons, subject to Sections 3(c) and 18. The definition excludes deposits, “including a deposit recorded using distributed ledger technology”.
Three practical scenarios
Treasury holding USDT or USDC. The rules above govern payments, service providers and platforms; none is addressed to a company simply holding crypto assets. The constraints sit around the holding: buy through an SPK-licensed platform, plan liquidity around the Communiqué No. 29 caps and remember that the asset is a claim on a foreign private issuer.
Accepting stablecoins from foreign customers. Article 3(2) of the TCMB Regulation does not exempt cross-border sales or foreign payers, and your payment or e-money institution cannot route funds to or from crypto platforms (Art. 4(2)). Until official guidance says otherwise, invoice and collect in fiat through regulated channels; the customer can convert outside Türkiye.
Issuing a lira-backed token. A non-bank issuer would face the e-money monopoly, the deposit-taking ban and the TCMB payments ban at once; a licensed institution still faces the last. The realistic route is dialogue with TCMB and SPK and, for licensed institutions, the tokenisation track of the digital Turkish lira ecosystem. See our payment and e-money licence page.
Where to start
- Test each payment flow against Articles 3 and 4 of the TCMB Regulation; stop any crypto settlement of sales.
- Keep crypto custody with SPK-licensed providers and build the Communiqué No. 29 caps into liquidity planning.
- For EU users, offer only tokens from MiCA-authorised issuers.
- Before designing a lira token, get a written analysis under Laws No. 6493, 5411 and 6362.
- Track TCMB’s digital Turkish lira work and the GENIUS Act rulemaking; our fintech law hub follows both.
Can a Turkish company pay a supplier in USDT?
No. Article 3(2) of the TCMB Regulation on the Disuse of Crypto Assets in Payments prohibits using crypto assets directly or indirectly in payments, and in our reading a dollar stablecoin is a crypto asset under that Regulation.
Does Türkiye have a specific stablecoin law?
No, as of October 2026. Law No. 6362 treats stablecoins as crypto assets without a separate category. MASAK Communiqué No. 29 caps platform withdrawals, but there is no Turkish equivalent of MiCA’s e-money token regime.
Is the digital Turkish lira live?
No. TCMB’s November 2025 report places it in a second R&D phase; legal processes would follow in a third phase if a circulation decision is made. Selected banks and payment and e-money institutions are sandbox-testing projects under TCMB’s ecosystem call.
Sources. TCMB Regulation on the Disuse of Crypto Assets in Payments (Official Gazette 16.4.2021, No. 31456), Arts. 3-5 (TCMB English translation); Capital Markets Law No. 6362 (Official Gazette 30.12.2012, No. 28513), Arts. 3(1)(bb), 35/B and 99/A, as amended by Law No. 7518 (Official Gazette 2.7.2024, No. 32590); MASAK General Communiqué No. 29 (Official Gazette 28.6.2025, No. 32940), Art. 4; Measures Regulation (Official Gazette 9.1.2008, No. 26751, as amended to 7.10.2026, No. 33393), Art. 24/A; Law No. 6493 (Official Gazette 27.6.2013, No. 28690), Arts. 3(1)(ç), 18 and 28; Banking Law No. 5411 (Official Gazette 1.11.2005, No. 25983 bis), Art. 60; SPK Communiqué III-35/B.2 (Official Gazette 13.3.2025, No. 32840), Art. 16(4); TCMB Digital Turkish Lira Second Phase Progress Report (24.11.2025); TCMB Press Release 2026-33 (3.8.2026); Regulation (EU) 2023/1114 (MiCA) (OJ L 150, 9.6.2023), Arts. 2(4), 3(1)(6)-(7), 16, 48-50 and 149; EBA Report on Tokenised Deposits (December 2024); ECB press release on Pontes (21.9.2026); GENIUS Act, Public Law 119-27, Secs. 2(22), 3, 4(a) and 20.
This article is general information and not legal advice; a specific situation should be assessed with counsel.
