Fintech 2026

TURKEY Trends and Developments Contributed by: Sera Somay, Merve Kurdak and Doğa Pınarlı Dedebaş, Paksoy

established under the majority ownership of an exist - ing bank, is Ziraat Dinamik Banka A.Ş., an affiliate of T.C. Ziraat Bankası A.Ş., which obtained its operating licence in October 2024. According to the official web - site of the BRSA, there are currently five digital banks operating in Türkiye, three operating as deposit banks and two operating as participation banks. One of the largest players in the Turkish digital banking sector, Enpara Bank A.Ş., holds a conventional deposit bank licence rather than a digital banking licence, despite essentially operating as a digital bank in practice. In addition to fully digital banks, conventional banks in Türkiye are also actively engaged in digital banking activities. According to the Banks Association of Türkiye’s Report on Digital, Internet and Mobile Banking Statis - tics, as of September 2025 there were 126,104 million active digital banking customers (individual and cor - porate), defined as users that had conducted transac - tions within the last three months. This represents an increase of 8,802 million customers compared with the previous year. The procedures and principles governing BaaS are set out under the Digital and Service Banking Regu - lation. For a service to qualify as a BaaS, custom - ers must access the banking services offered by the bank through the interface provided by an interface provider, and such access must be established via open banking services. The BRSA is authorised to determine the technical criteria applicable to open banking services. There are no restrictions as to which banks may act as BaaS. However, banks may provide services only within the scope of their authorised activities; accord - ingly, a bank may not offer, through an interface pro - vider, any banking service that it is not authorised to provide directly. Decisions relating to the banking services to be offered to customers, such as credit allocation decisions, must be taken by the BaaS, and the relevant transactions must be recorded on the bal - ance sheet of the relevant BaaS. 1.3 Service model banking 1.3.1 Regulatory framework

The Digital and Service Banking Regulation further requires interface providers to be established as cap - ital companies in Türkiye, and to operate a mobile application or internet platform capable of enabling the provision of banking services. Banks are not per - mitted to act as interface providers. 1.3.2 BaaS market in Türkiye Getir Teknolojik Hizmetler A.Ş. (“GetirFinans”) is the first entity to carry out service model banking activities in Türkiye. Fibabanka A.Ş. announced via the Pub - lic Disclosure Platform (PDP) in August 2024 that it had obtained the necessary BRSA approvals to com - mence service model banking activities through the interface provided by GetirFinans. The GetirFinans interface enables users to access Fibabanka’s prod - ucts and services, including account opening, credit cards, money transfers, investment services and loan transactions. Migros Ticaret A.Ş., one of Türkiye’s largest supermarket chains, announced via the PDP in January 2026 that the BRSA had approved the application for its subsidiary, Money Finansal Teknoloji Hizmetleri A.Ş., to provide banking services as a ser - vice model interface provider for Colendi Bank A.Ş. These recent developments signal a growing adoption of BaaS in Türkiye. 2. Payment and E-Money Institutions 2.1 Regulatory framework Payment and e-money institutions operate under the Payment Services Law, introduced in June 2013, together with the Regulation on Payment Services, Electronic Money Issuance, Payment Institutions and Electronic Money Institutions (“Payment Services Regulation”), alongside applicable secondary legis - lation. Moreover, payment institutions and electronic money institutions, along with other financial entities such as banks, non-bank card issuers, financing and factoring companies and crypto-asset service provid - ers, are classified as obligors under Turkish anti-mon - ey laundering legislation. Accordingly, they are subject to a broad range of obligations, including customer due diligence and know-your-customer (KYC) require - ments, transaction monitoring, the establishment of internal compliance programmes, record-keeping and suspicious transaction reporting.

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