TURKEY Law and Practice Contributed by: Caghan Tansel, TANSEL
1.2.2 Access to Banking There is no general prohibition on CASPs obtain- ing ordinary banking services in Türkiye; in fact, the 2025 CMB framework assumes that platforms will use banks for fiat-side operations, including the requirement that customer cash funds be held in bank accounts. However, firms cannot freely choose all types of financial partners for every function. Crypto- asset custody must be provided through platforms or CMB-authorised custody institutions, and payment/e- money institutions are subject to a specific restriction under the Central Bank’s 2021 regulation: they may not intermediate fund transfers to or from platforms providing crypto-asset trading, custody, transfer or issuance services. This means that banks may be used for general cash accounts and fiat settlement, but payment institutions and e-money institutions cannot be used to recreate crypto payment rails or to intermediate prohibited flows. In practice, access to banking services is possible but may be operationally challenging. Banks are likely to apply enhanced onboarding, AML, sanctions, source- of-funds and transaction-monitoring standards, especially because CASPs are now subject to both the CMB licensing regime and MASAK compliance expectations. As a result, a CASP’s ability to obtain and maintain banking relationships will usually depend on its regulatory status, CMB application or licence position, MASAK controls, ownership transparency, custody arrangements and the relevant bank’s own risk appetite. The main restriction is therefore not a blanket banking ban but the combination of the Cen- tral Bank’s payment/e-money intermediation prohibi- tion and stricter banking compliance expectations for crypto-related clients. 1.2.3 ESG/Sustainable Finance There are no ESG or sustainable-finance disclosure rules in Türkiye that apply specifically to digital assets merely because an asset is tokenised or a business uses blockchain. CASPs are primarily regulated under the CMB’s 2025 CASP framework, which focuses on licensing, governance, operations, custody, capital adequacy and audit rather than crypto-specific ESG disclosure. However, digital-asset businesses may fall within Türkiye’s general sustainability reporting regime
if they are otherwise within scope and meet the rel- evant size criteria. The Turkish Sustainability Reporting Standards (TSRS), aligned with IFRS S1 and S2, make sustain- ability reporting mandatory for certain undertakings; the applicable thresholds were increased for finan- cial periods beginning on or after 1 January 2025 to TRY1 billion in total assets, TRY2 billion in annual net sales revenue and 500 employees, with at least two thresholds generally needing to be exceeded for two consecutive reporting periods. Accordingly, larger exchanges, custodians, infrastructure providers or tokenisation businesses may need to address cli- mate, governance and risk-related disclosures under the TSRS, while smaller digital-asset projects will usu- ally face ESG issues through investor expectations, banking due diligence, anti-greenwashing concerns and general advertising or consumer-protection rules rather than a bespoke digital-assets ESG regime. 1.2.4 Tax Türkiye has not yet enacted a comprehensive tax regime specifically tailored to blockchain or digital assets. A March 2026 omnibus bill proposed cryp- to-specific measures, including a transaction tax on crypto-asset sales and transfers carried out or inter- mediated by crypto-asset service providers, but those provisions were removed before the bill was enacted as Law No 7577. As a result, as of May 2026, crypto- asset activity is generally analysed under ordinary Turkish tax rules rather than a bespoke digital-assets tax code. The main uncertainties are: • whether gains of individual investors should be treated as incidental capital gains, commercial income or another income category; • how corporate taxpayers should value, account for and recognise crypto-assets; • whether and when VAT may apply to token trans- fers or platform services; • how staking, mining, DeFi, airdrops and NFTs should be classified; and • what withholding, reporting or platform-level tax obligations may be introduced in future legislation.
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