TURKEY Trends and Developments Contributed by: Caghan Tansel, TANSEL
Türkiye’s TSRS are aligned with the IFRS sustainability disclosure architecture. The scope thresholds have been updated: the relevant financial and employee thresholds now refer to TRY1 billion in total assets, TRY2 billion in annual net sales and 500 employees, subject to the applicable scope rules. The updated thresholds apply to accounting periods beginning on or after 1 January 2025. For crypto businesses, TSRS analysis should not be treated as a narrow “mining” issue. Larger CASPs and infrastructure providers may need to assess energy use, cloud and data-centre emissions, governance of climate-related risks, third-party service-provider exposure and any claims made in relation to tokenised carbon credits or sustainability-linked products. The practical risk is reputational as much as regu- latory. Institutional partners, banks, custodians and investors increasingly expect digital-asset business- es to show that sustainability claims are measurable, auditable and not merely marketing-driven. Practical Checklist for Incoming Projects A practical checklist for incoming projects is as fol- lows. • Map the service perimeter. Determine whether the project provides exchange, brokerage, custody, wallet, transfer, staking, tokenisation, advisory or related services. • Confirm the licensing route. Distinguish between transitional status, CMB operating permission and any ancillary permissions required for payment, e-money, banking or investment services. • Budget for capital early. Treat Turkish minimum capital and capital-adequacy requirements as a core funding item, not as a late-stage filing cost. • Build a custody strategy before launch. Identify authorised custody partners, segregation mechan- ics, reconciliation processes, audit expectations and business-continuity arrangements. • Design MASAK controls from day one. Know-your- customer (KYC), remote identification, Travel Rule messaging, sanctions screening, PEP controls,
source-of-funds review, suspicious transaction reporting and information-retention systems should be embedded into the product architecture. • Avoid premature Turkish-facing marketing. Foreign platforms should not rely on informal reverse- solicitation assumptions without analysing Turkish targeting, language, payment rails, onboarding flows and user-acquisition practices. • Separate investment use cases from payment use cases. The 2021 payment ban remains in force, so checkout, merchant acquiring and payment inter- mediation require particular caution. • Plan for tax uncertainty. No specific crypto transac- tion tax is currently in force, but future proposals remain possible and ordinary tax rules may apply. • Test TSRS scope. Larger platforms and infra- structure providers should assess whether they fall within sustainability reporting thresholds and whether energy or climate-related disclosures are needed. • Monitor Digital Turkish Lira standards. Wallets, settlement tools and tokenised-fiat infrastructure should be built with modularity so they can adapt if future CBDC interoperability standards emerge. Outlook Türkiye’s 2026 digital asset market is best described as regulated but opportunity-rich. Retail demand remains high, institutional infrastructure is develop- ing, and the legal framework is now detailed enough for serious compliance planning. The cost of entry has increased, particularly for licensing, custody, capital and AML systems. Yet, that cost is also creating a more credible market. The winners are likely to be platforms and infrastruc- ture providers that treat regulation as part of the prod- uct – not as a filing exercise after launch. In Türkiye, the next phase of Web3 growth will belong to busi- nesses that can combine user demand with institu- tional-grade compliance, local custody readiness, MASAK-compatible controls and a clear strategy for operating alongside both the CMB framework and the Central Bank’s evolving digital-money agenda.
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