TURKEY Trends and Developments Contributed by: Caghan Tansel, TANSEL
Why Türkiye Still Matters for Web3 Türkiye entered 2026 as one of the most active digital- asset markets in the region – but also as a market that has decisively moved from regulatory ambiguity to supervised growth. Its current trajectory is more nuanced than before: strong retail demand, growing institutional interest, and a licensing-led regulatory model supervised primarily by the Capital Markets Board of Türkiye (CMB, or Sermaye Piyasası Kurulu ). The legal turning point came in 2024, when Law No 7518 amended the Capital Markets Law No 6362 and brought crypto-asset service providers (CASPs) within the CMB’s regulatory and supervisory perimeter. That framework was followed in March 2025 by the CMB’s principal secondary legislation on CASP establish- ment, operations, services, custody, listing standards, capital adequacy, internal systems, audit and related obligations. The commercial case remains strong. Chainalysis ranked Türkiye 14th globally in its 2025 Global Crypto Adoption Index, with particularly strong scores in cen- tralised exchange activity. Domestic survey data also indicates that crypto awareness is now near-universal, while the share of people trading crypto rose from 27% in 2024 to 31% in 2025. For international investors, the opportunity is therefore real – but it is now inseparable from licensing, custody, anti-money laundering (AML), governance and local compliance planning. Key Takeaways Key takeaways for 2026 include the following. • Licensing is the core gatekeeper. CASPs target- ing the Turkish market must analyse whether they require CMB authorisation and should not rely on the transitional “active providers” list as a substi- tute for licensing. • The 2025 CMB communiqués changed the operat- ing model. Governance, capital, custody, internal systems, listing governance, audit and proof-of- reserves are now part of the market-entry analysis. • AML expectations have intensified. MASAK’s 2025 framework and guidance focus on customer due diligence, remote identification, Travel Rule imple-
mentation, transaction limits, suspicious transac- tion reporting and risk-based controls. • Türkiye remains outside the Financial Action Task Force (FATF) grey list. The FATF removed Türkiye from increased monitoring in June 2024, and sub- sequent FATF updates did not re-list Türkiye. • No crypto-specific transaction tax is currently in force. A 2026 proposal for a crypto-asset transac- tion tax was discussed but removed before enact- ment. General Turkish tax rules may still apply depending on the taxpayer, activity and asset classification. • Payment use cases remain restricted. The 2021 Central Bank regulation prohibiting the direct or indirect use of crypto-assets in payments remains the main barrier for checkout, merchant-acquiring and payment-intermediation models. • Digital Turkish Lira work is relevant but separate. The Central Bank’s CBDC (Central Bank Digital Currency) project continues through second-phase work on programmable payments, offline payments and interoperability, but it should not be confused with private crypto-assets. • Sustainability reporting thresholds have changed. The Turkish Sustainability Reporting Standards (TSRS) regime now uses higher financial and employee thresholds, making ESG analysis rele- vant for larger CASPs, infrastructure providers and tokenisation projects. Market Dynamics: High Adoption, More Institutional Discipline Türkiye’s crypto market continues to be supported by a young, mobile-first investor base, high familiarity with digital finance and a long-standing search for alterna- tive stores of value. The market is no longer driven only by early adopters: domestic survey data suggests that one in three people in Türkiye trades crypto, that awareness has remained at 99% since 2023, and that one in five crypto users started trading within the six months preceding the 2025 survey period. At the same time, the market is maturing. Users are not only trading short-term volatility; survey results indicate that a large share of crypto users view digital assets as a long-term investment tool, while younger users – particularly the 25–34 years old age group – continue to represent a meaningful share of activity.
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