Fintech License in Türkiye (Turkey): Payment Institution and E-Money Applications for Foreign Entrants

To get a fintech license in Turkey, you apply to the Central Bank of the Republic of Türkiye (TCMB) for either a payment institution or an electronic money institution license. You can hold it only through a joint-stock company incorporated in Türkiye. There is no passporting: a license you hold in the EU, the UK or the Gulf does not travel. The application runs in two stages, carries fixed fees set in the Central Bank's regulation, and must be concluded within six months of a complete file. This guide walks a foreign founder through the license categories, the money you must put on the table, the shareholder tests, and the three realistic routes into the Turkish payments market.

Who licenses fintech in Türkiye, and what actually needs a license?

Since the start of 2020 there has been one regulator for payments. Law No. 7192 of 12 November 2019 amended Law No. 6493 on Payment and Securities Settlement Systems, Payment Services and Electronic Money Institutions, replacing the Banking Regulation and Supervision Agency (BDDK) with the Central Bank throughout. Guidance still naming the BDDK as the fintech regulator is out of date.

Article 12 sets out what counts as a payment service: operating a payment account, executing transfers and card payments, issuing or acquiring payment instruments, money remittance, payments made through a technology or telecoms operator acting purely as an intermediary, and intermediation in bill payments. The 2019 amendment added two open-banking services — payment order initiation, and account information delivered online with the user's consent — plus a catch-all letting the Central Bank designate other transactions as payment services once they reach a size it determines.

That second clause is why a foreign fintech cannot simply serve Turkish customers from its home entity. Article 12(2) does carve out activities that are not payment services — cash paid directly to the payee, transactions through a commercial agent, technical providers that never hold the funds, and instruments usable only at the issuer's premises or within a limited network. But those carve-outs can be withdrawn. Under Article 12(5) the Central Bank may bring the commercial-agent and limited-network exclusions back into scope once their total size or reach hits a level it sets, and Article 18(5) gives it the same power over closed-loop prepaid instruments. Our banking and finance team usually begins here, mapping the product against Article 12 before anyone drafts an application.

Payment institution license or e-money license in Turkey — which do you need?

The two categories are not tiers of the same thing. A payment institution moves money; an electronic money institution issues a stored monetary value that third parties accept as a means of payment. If your product loads a balance the customer can spend at merchants other than you, you are issuing electronic money, and the payment-institution license will not cover it.

Those figures are the floors in Articles 14 and 18 of Law No. 6493, repeated in the 2021 Regulation. Treat them as an entry ticket. The number that governs how much equity the business must carry is the own-funds requirement discussed below, and there is a separate guarantee to lodge on top of both. One exception is worth knowing — Article 14/A exempts a payment institution providing only the account information service from the registered-share, cash-subscription and minimum-capital requirements, so a pure data-aggregation play has a lighter entry path.

What does the Central Bank application actually involve?

Article 11 of the 2021 Regulation is the procedural spine, and it starts earlier than most founders expect. Before you register a trade name containing the words "payment institution" or "electronic money institution", you must file a notification and the prescribed forms with the Central Bank. That filing needs the draft articles of association and proof that the application fee of TRY 500,000 has been paid. That fee is not refunded if the application later fails at any stage.

Two deadlines cause most of the failures. Missing information not completed within six months of the Bank's written request renders the whole application invalid. And failing to move from preliminary to final approval within the 120-day window forfeits everything gained at the preliminary stage. Article 15(4) obliges the Central Bank to conclude a complete application within six months, with reasons if the answer is no.

The final-approval file is where timetables slip, because it is evidence-based rather than paper-based: an independent audit firm must inspect your premises and systems and report on whether internal control, risk, accounting, information-systems and reporting functions genuinely exist. The IT part is reserved to firms on the BDDK's approved list. Central Bank staff then attend in person.

What must the shareholders and directors prove?

Türkiye applies a banking-grade fit-and-proper test to fintech owners. Under Articles 14 and 18 of Law No. 6493, anyone holding ten percent or more of the capital, and anyone holding control, must satisfy the qualifications required of bank founders under Banking Law No. 5411. Shares must be issued against cash and must all be registered shares.

The preliminary-review bundle demands notarised declarations and evidence on each qualifying shareholder and controller:

• No bankruptcy or composition proceedings.
• No conviction for the offences listed in Article 8 of Banking Law No. 5411, evidenced by a criminal record extract including archive entries.
• No qualifying holding in a bank transferred to the Savings Deposit Insurance Fund, or in a financial institution whose license was withdrawn other than voluntarily.
• No overdue tax or social-security debt.
• An accountant's report on financial standing.
• An undertaking that the capital comes from the shareholder's own resources.

Neither Law No. 6493 nor the regulation imposes a ceiling on foreign shareholding, but a foreign qualifying shareholder is documented differently. Where a qualifying shareholder is a bank or financial institution established abroad, the regulation asks for its board resolution to operate in Türkiye, its latest consolidated audit report, and confirmation from its home supervisor that it is not prohibited or restricted from operating.

Because the same people will sit on the board of the Turkish company, read the license file alongside the ordinary exposure of directors of a Turkish company.

Are there routes in that do not require your own license?

Yes. There are two, and they suit different commercial ambitions.

The acquisition route is a share deal in a regulated target, so the usual transaction work applies on top of the Central Bank permission — see share deal versus asset deal in Turkey and due diligence on a Turkish company.

The Article 19 route is narrower than it first reads. A licensed Turkish institution may serve its Türkiye-resident customers together with a foreign legal entity, but only where at least one of the payer or payee is abroad; a purely domestic payment cannot be served this way. The foreign partner must be authorised at home and must obtain the Central Bank's permission first, supported by a business plan describing the office it will open in Türkiye, the staff it will keep there, and how local customers will raise complaints.

Crucially, the foreign entity may not present itself as the service: it cannot be the sole visible face to the customer, cannot use its brand in a way that suggests domestic authorisation, and cannot run a website aimed at Türkiye-resident customers. Responsibility stays with the licensed Turkish institution, and the transactions count towards its own-funds and guarantee calculations. If your plan is a consumer-facing Turkish brand, Article 19 will not carry it — you are back to your own license and to incorporating the Turkish company that will hold it. Groups approaching Türkiye from the United States often run this decision through our US Desk.

Which ongoing obligations bite hardest after the license?

Minimum capital is a one-off test. Own funds are a continuing one. Article 33 of the regulation requires own funds to be calculated at the end of June and December, and to stay above two things at once. The first is a fixed floor, which differs for bill-payment institutions, other payment institutions and electronic money institutions. The second is a figure scaled to payment volume through a banded percentage formula, doubled or tripled at higher volume tiers. The Central Bank may increase that volume-scaled figure by up to fifty percent on a risk assessment, without prejudice to the statutory paid-in capital minimum. The Central Bank re-assesses the fixed floors every January in line with published price indices and publishes the revised amounts separately, so work from the current figures rather than those printed in the original regulation.

The rules that most often surprise foreign entrants are the currency rules. Where both parties to a payment are resident in Türkiye and the providers used are located in Türkiye, the transaction may be executed only in Turkish lira, and as a rule the institution may not open foreign-currency payment accounts for Türkiye-resident customers. Foreign-exchange dealing is confined to payments with a leg abroad. A product built around multi-currency wallets for local users will need redesigning.

The rest is familiar to any regulated business:

• Professional indemnity insurance of at least TRY 1,000,000 — or a guarantee of the same value at the Central Bank — where the payment institution provides only the account information service, rising by TRY 500,000 for every hundred thousand customers after the first hundred thousand, and increasable by the Central Bank by up to half.
• Protection accounts at a bank for unpaid payment funds, which may not be pledged as collateral.
• Anti-money-laundering compliance under the MASAK regime.
• Independent financial audit, plus a separate information-systems audit under Article 21 of Law No. 6493.
• Central Bank inspection powers extending to your branches, agents and outsourced providers.
• Membership of the Turkish Payment and Electronic Money Institutions Association, applied for within one month of the license under Additional Article 1 of Law No. 6493.
• The data obligations covered in our guide to KVKK compliance for foreign companies.

You will also need day-one banking relationships — see opening a corporate bank account in Turkey.

What happens if you operate without a license?

Article 28 of Law No. 6493 makes unlicensed activity a criminal offence. Individuals who act as a payment institution or electronic money institution without permission — and the officers of legal entities that do so — face imprisonment of one to three years and a judicial fine of up to five thousand days. The same penalty applies to using words in a trade name, documents or advertising that create the impression of licensed status. Where the offence is committed within a business, the court may order it closed for two to six months, and permanently on repetition. The provision also catches an institution that keeps trading after its license is revoked.

That sits on top of the administrative fines the Central Bank applies to licensed institutions, which we set out in our guide to fintech sanctions and executive liability in Turkey. If your product touches crypto as well as payments, a separate licensing regime applies to crypto asset service providers under the Capital Markets Board — see the regulatory framework for crypto platforms — and holding one authorisation does not dispense with the other.

How should a foreign entrant sequence a Turkish fintech license application?

Applications fail on sequencing far more often than on merit.

1. Map the product against Article 12 first, and decide whether you need a license at all and which one. The answer sets capital, fees and timeline.
2. Test the shareholders early. An unresolved tax debt, a bankruptcy history or a criminal record entry will stop the application at the preliminary stage — establish this before you spend on incorporation.
3. Incorporate the Turkish joint-stock company with registered shares subscribed in cash, and file the pre-application notification before registering a trade name that uses the protected words.
4. Build the business plan and the systems in parallel. Final approval requires an audit firm to certify that internal control, risk, accounting, IT and reporting functions exist and are staffed — budget engineering time for it, not just drafting time.
5. Model own funds and the Article 36 guarantee, not just capital, against projected volume and the current January figures, keeping headroom for the Central Bank's discretionary uplift.
6. Diarise the deadlines: three months to cure pre-application deficiencies, six months to reach the preliminary stage, 120 days from preliminary to final approval, and ten days to notify the start of operations with the license fee.

If you are still deciding whether Türkiye justifies its own entity, our overview of establishing a business in Turkey and our note on banking and finance law for foreign businesses are the place to start. We are happy to scope the licensing question before you commit.

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