TURKEY Law and Practice Contributed by: Sera Somay, Merve Kurdak and Doğa Pınarlı Dedebaş, Paksoy
Paksoy Orjin Maslak, Eski Büyükdere Cad No:27 Kat:11 Maslak/İstanbul Turkey Tel: +90 212 366 4700 Email: contact@paksoy.av.tr Web: paksoy.av.tr
1. Fintech Market 1.1 Evolution of the Fintech Market
2. Fintech Business Models and Regulation in General 2.1 Predominant Business Models The main fintech business models currently predomi - nant in the market include: • payment and e-money institutions;
Over the past 12 months, the Turkish fintech market has continued to expand in various sectors while reg - ulatory authorities, including the Central Bank of the Republic of Türkiye (CBRT), have strengthened super - vision of payment and e-money institutions through licensing actions, enhanced oversight practices, and increased minimum capital requirements aimed at improving financial resilience. After the first regulation in relation to crypto-assets in 2021 that prohibited their use in payments, cryp - to-assets and crypto-asset service providers were brought into a formal regulatory framework in 2024 through amendments to the Capital Markets Law No. 6362 (CML) and decisions of the Capital Mar - kets Board of Türkiye (CMB). In particular, towards the end of 2024, crypto-asset service providers were classified as financial institutions and became sub - ject to anti-money laundering (AML) and countering the financing of terrorism (CFT) obligations, and in 2025, the CMB issued detailed secondary legislation regulating the licensing, financial, administrative and technical processes of crypto-asset service providers (“CMB Communiqués”). We expect the next 12 months to be shaped by regu - latory compliance costs, increased supervisory inten - sity and ongoing licensing processes, with new mar - ket entrants anticipated in both the crypto-asset and payment services segments. While there is no fintech- specific artificial intelligence regulation in Türkiye, we believe that fintech firms may make use of advanced data analytics and automated tools, primarily in areas related to risk management and compliance.
• open banking; • digital banking; • Banking-as-a-Service (“BaaS”); and • crypto-asset service providers.
These business models are open to new market entrants, and new fintech companies continue to be established and licensed in each of these areas. At the same time, legacy players, including banks and other financial institutions, as well as large e-commerce or technology companies, are adapting to these mod - els by expanding their offerings and by establishing subsidiaries or affiliated entities licensed to operate in these fintech verticals. 2.2 Regulatory Regime In Türkiye, financial markets are governed by highly detailed legislative framework based on laws, sec - ondary legislation and regulatory authority deci - sions, under which different regulatory regimes apply depending on the relevant business model. Legacy players are generally subject to different regu - latory regimes depending on the nature of their activi - ties: • Banks are primarily governed by the Banking Law No. 5411 (“Banking Law”) and extensive second - ary legislation, and are regulated and supervised
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