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Licensing Advisory

TCMB Licensing Process for Payment and Electronic Money Institutions

Preparation of capital, own funds, financial statements and post-licence reporting for joint stock companies that will provide payment services or issue electronic money, in the operating licence process of the Central Bank of the Republic of Türkiye.

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Overview

In Türkiye, payment services may be provided only by banks, electronic money institutions, payment institutions and PTT A.Ş. (the Turkish postal company); no other persons may provide payment services. (Law No. 6493, Art. 13) Payment institutions and electronic money institutions operate with a licence from the Central Bank of the Republic of Türkiye (TCMB). (Law No. 6493, Art. 14, 18)

The payment services listed in the Law include operating a payment account, money transfers, issuing or acquiring payment instruments, money remittance, intermediation of bill payments, payment initiation and account information services. (Law No. 6493, Art. 12) Electronic money is monetary value issued against funds received, stored electronically and accepted as a means of payment by persons other than the issuer. (Law No. 6493, Art. 3)

The documents, stages, own funds and safeguarding rules for applications are set out in the TCMB Regulation on Payment Services and Electronic Money Issuance and Payment Service Providers. The Regulation was also amended in 2026: the amendment dated 19.03.2026 concerns the safeguarding of funds, and the amendment dated 04.09.2026 concerns remote identity verification. The current text is used as the basis before an application.

The licensing decision is made by the TCMB. KEYBIZ CPAs & Advisors carries out the review of the applicant company’s capital and shareholding structure against the requirements of the Law, the preparation of the financial statements, the own funds calculations and the financial part of the business programme, and the post-licence accounting and reporting arrangements. Independent audit reports are prepared by audit firms authorised by the Public Oversight Authority (KGK), and legal assessments by the company’s lawyer.

Comparison of Payment Institution and Electronic Money Institution

Payment InstitutionElectronic Money Institution
ActivityPayment services listed in Article 12 of the Law (Law No. 6493, Art. 14)Issuance of electronic money and payment services (Law No. 6493, Art. 18)
Company Type and SharesJoint stock company (anonim şirket); shares are issued against cash and are all registered shares (Art. 14)Joint stock company (anonim şirket); shares are issued against cash and are all registered shares (Art. 18)
Minimum Paid-in CapitalAt least TRY 1 million for intermediation of bill payments, at least TRY 2 million for other payment services; paid in cash and free from any collusive arrangement (muvazaa) (Art. 14)At least TRY 5 million; paid in cash and free from any collusive arrangement (muvazaa) (Art. 18)
Minimum Own Funds (from 30.06.2026)TRY 20 million for those intermediating bill payments; TRY 40 million for other payment institutions, except those providing only account information services (TCMB Communiqué, Official Gazette 31.01.2026)TRY 105 million; plus own funds equal to two per cent of the average outstanding electronic money (TCMB Communiqué, Official Gazette 31.01.2026; Regulation, Art. 33)
Initial CollateralTRY 2 million for intermediation of bill payments, TRY 3 million for other payment institutions; increases up to four times this amount according to the number of clients, TRY 500,000 is added for every thousand agents, and the amount is set by the Bank each year in January (Regulation, Art. 36)TRY 5 million; increases on the same basis according to the number of clients and agents, and the amount is set by the Bank each year in January (Regulation, Art. 36)
User FundsPayment funds are tracked separately, used only for the payment transaction and transferred to a safeguarding account; they are not deemed deposits or participation funds (Art. 14; Regulation, Art. 34)Electronic money is issued in the amount of the funds received; the funds are safeguarded in separate accounts at banks and are not deemed deposits (Art. 20; Regulation, Art. 35)
ProhibitionsNo loans may be granted (Art. 14)No loans may be granted; no interest may be paid and no benefit provided to the electronic money holder (Art. 20)

Current texts of Law No. 6493 and the TCMB Regulation on mevzuat.gov.tr, and the TCMB Communiqué published in Official Gazette No. 33154 dated 31.01.2026 (November 2026).

Crypto Asset Service Providers

Operating Licence Process

  1. Scope of Services and Shareholding Structure

    The payment services to be provided are determined; if issuing electronic money is planned, an electronic money institution licence is required. Shareholders holding ten per cent or more of the capital and controlling persons must have the qualifications required of bank founders under banking legislation. The shareholding and organisational structure must be transparent so as not to prevent supervision by the TCMB. (Law No. 6493, Art. 14, 18)

    • The board of directors consists of at least three members, including the general manager (Regulation, Art. 23)
    • The general manager must have at least a bachelor’s degree and at least seven years of experience in business administration or finance (Regulation, Art. 24)
    • The trade name contains the phrase “ödeme kuruluşu” (payment institution) or “elektronik para kuruluşu” (electronic money institution) (Regulation, Art. 11)

    For the formation of the joint stock company and payment of capital, see our Company Formation page.

  2. Initial Application

    Before its trade name is registered with the trade registry, the company applies to the TCMB with the forms in Annexes 11-A to 11-D to the Regulation and a receipt showing payment of the TRY 500,000 application fee. The application fee is not refunded even if the outcome is negative. Applications are delivered by hand to the TCMB Head Office. (Regulation, Art. 11)

  3. Intelligence Review

    Within six months of notification of the document issued by the TCMB confirming that the application has been made, an application is made for the intelligence review stage with the documents listed in Annex 15; otherwise the document loses its validity. At this stage, the business programme, declarations on the shareholders, undertakings, criminal records and financial statements are submitted. (Regulation, Art. 11)

  4. Final Approval

    The application for final approval is made with the documents listed in Annex 16 within 120 days at the latest of the written notification of the intelligence review approval. The TCMB may extend this period by up to 60 days if a reasonable justification is provided. (Regulation, Art. 11)

    • Documents showing that the capital has been paid and the minimum own funds requirement is met
    • Report prepared by independent audit firms following an on-site review
    • Documents on collateral and, where required, professional liability insurance

    Under the Law, the application is concluded within six months of the submission of complete documents. The operating licence takes effect from the date of its publication in the Official Gazette (Resmî Gazete). (Law No. 6493, Art. 15; Regulation, Art. 11)

  5. Starting Operations

    The start of operations is notified to the TCMB within 10 days of the start date; the notification is accompanied by a receipt showing payment of the TRY 1 million licence fee. (Law No. 6493, Art. 15; Regulation, Art. 11) If operations do not start within one year of the date the licence is granted, the TCMB may cancel the licence. (Law No. 6493, Art. 16)

Post-Licence Accounting, Audit and Reporting

Accounting and independent audit: Accounting is carried out in accordance with the procedures and principles set by the KGK. The year-end financial statements are audited by independent audit firms authorised by the KGK, and the audit report is submitted to the TCMB by 15 May of the following year. (Regulation, Art. 28) Information systems are also subject to independent audit. (Law No. 6493, Art. 21)

Own funds: Own funds are calculated as at the end of June and December. The minimum amounts are reassessed by the TCMB each year in January. (Regulation, Art. 33)

Internal systems: Internal control and risk management systems are set up; their results are reported to the board of directors twice a year, as at the end of June and December. (Regulation, Art. 26, 27)

Share acquisitions and transfers: Acquisitions of shares representing, directly or indirectly, ten per cent or more of the capital, and a shareholder’s holding rising above or falling below the thresholds of ten, twenty, thirty-three or fifty per cent, are subject to TCMB permission; transfers made without permission are not entered in the share register. (Law No. 6493, Art. 25)

Records: Records are kept for at least ten years and in Türkiye. (Law No. 6493, Art. 23)

During this period, KEYBIZ CPAs & Advisors prepares the statutory books, the periodic financial statements and the own funds calculations, and handles reconciliation with the independent auditor. For details, see our Financial Reporting page.

Frequently Asked Questions

What Is the Sanction for Providing Payment Services without a Licence?

For natural persons, and the officers of legal entities, who operate as a payment institution or electronic money institution without a licence, the Law provides for imprisonment of one to three years and a judicial fine of up to five thousand days. Using a trade name, advertisement or statement that creates such an impression without a licence is subject to the same sanction. (Law No. 6493, Art. 28)

Can a Payment Institution Grant Loans?

No. Payment institutions and electronic money institutions may not grant loans. Funds received for payment services or electronic money are not deemed deposits or participation funds. (Law No. 6493, Art. 14, 20)

Are Minimum Capital and Minimum Own Funds the Same?

No. The minimum paid-in capital is set in the Law as fixed amounts. Minimum own funds, by contrast, are governed by the Regulation and reassessed by the TCMB each year; the amounts applicable from 30.06.2026 were set by the Communiqué dated 31.01.2026. (Law No. 6493, Art. 14, 18; Regulation, Art. 33)

Is the Application Fee Refunded?

No. The application fee of TRY 500,000 is not refunded even if the application is rejected at any stage. (Regulation, Art. 11)

Is a Separate Licence Required for a Digital Wallet Service?

Digital wallet services may be provided by payment service providers. An institution that will provide this service must be authorised at least for the issuance of payment instruments. (Regulation, Art. 4/A) The licence scope required for the planned business model is determined before the application.

Is Permission Required for Changes in the Shareholding Structure?

Yes. Acquisitions of ten per cent or more of the shares, rising above or falling below certain thresholds, and transfers of shares carrying the privilege to nominate board members are subject to TCMB permission. Those acquiring the shares must have the qualifications required of bank founders. (Law No. 6493, Art. 25)

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