TURKEY Trends and Developments Contributed by: Sera Somay, Merve Kurdak and Doğa Pınarlı Dedebaş, Paksoy
Board (MASAK) with regard to the classification of crypto-asset service providers as “financial institu - tions”, required sender and recipient information in crypto-asset transfers, and the obligations imposed on crypto-asset service providers such as compliance programmes, e-notifications, KYC and remote identi - fication requirements. Subsequently, the long-awaited secondary legislation was introduced in March 2025 through the CMB’s Communiqué No. III-35/B.1 on the Establishment and Operating Principles of Crypto-Asset Service Provid - ers and Communiqué No. III-35/B.2 on the Operat - ing Procedures and Principles and Capital Adequacy of Crypto-Asset Service Providers. With the entry into force of these communiqués, a comprehensive secondary regulatory framework governing crypto- assets has been established, while a transition period has been granted to crypto-asset service providers, including deferred effective dates for certain provi - sions. 4.2 Crypto-assets market in Türkiye In accordance with the CMB’s announcement in July 2024, the “List of Operating Platforms” and the “List of Platforms Declaring Liquidation” were published on the CMB’s website. Pursuant to the transitional provi - sions set out in the above-mentioned regulations, the establishment and licensing processes for platforms and other crypto-asset service providers are being implemented on a phased basis and remain ongoing. Although the application and authorisation processes are ongoing, as of January 2026, 58 companies are listed on the CMB’s official website under the “List of Operating Platforms” as operating as crypto-asset service providers and are continuing their activities until the required CMB licences are obtained.
These regulations and the related licensing process have led to significant developments in relation to crypto-assets. Nevertheless, the current regulatory framework primarily focuses on crypto-asset ser - vice providers, consumer protection and compliance issues, while remaining silent on certain areas, such as the issuance of capital market instruments in the form of crypto-assets which may be subject to future legislative or regulatory action. Conclusion The Turkish fintech sector continues to evolve at a rapid pace, as regulatory frameworks across digi - tal banking and service banking, payment services, crowdfunding and crypto-assets become more estab - lished, and licensing and authorisation processes for market participants continue to progress. Alongside these regulatory developments, traditional financial institutions and market infrastructure providers are increasingly experimenting with blockchain-based initiatives, such as digital gold platforms, CBRT digi - tal Turkish lira pilots, distributed ledger-based KYC systems and blockchain-enabled bond issuances out - side Türkiye. Taken together with growing investment activity, broader market participation and an increas - ingly clear regulatory environment, these develop - ments suggest that the Turkish fintech ecosystem is well placed to sustain further growth and innovation in the years ahead.
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