Crypto Asset Advertising and Promotion Rules in Turkey

Introduction

Crypto asset advertising has become one of the most sensitive areas of financial and digital advertising in Turkey. Crypto asset trading platforms, wallet services, custody providers, token projects, fintech companies, influencers, media publishers, comparison websites and foreign platforms may promote crypto-related services through websites, mobile applications, search engine ads, social media posts, sponsored articles, referral links, airdrop campaigns, promotional bonuses, push notifications and influencer videos.

The subject of crypto asset advertising and promotion rules in Turkey has become especially important after the entry into force of the Turkish crypto asset framework. Law No. 7518, which amended the Capital Markets Law No. 6362, was published in the Official Gazette on 2 July 2024. With this amendment, crypto asset service providers operating or intending to operate in Turkey were brought under the regulatory and supervisory authority of the Capital Markets Board of Türkiye, known as the SPK or CMB.

Crypto advertising is legally sensitive because crypto assets are volatile, technologically complex and often difficult for ordinary consumers to evaluate. A misleading advertisement may cause a person to open an account, transfer money, purchase a crypto asset, participate in a campaign, use a risky platform or believe that returns are guaranteed. For this reason, crypto promotions must be transparent, objective, verifiable and compliant with both capital markets rules and general consumer advertising law.

The core rule is clear: crypto asset service providers must not use false, misleading or exploitative advertising. They must not promise absolute returns or protection against loss except where legislation expressly allows it. They must not target consumers with claims suggesting that everyone will profit, that no loss is possible, or that crypto trading can provide easy additional income.

This article explains the key rules on crypto asset advertising and promotion in Turkey, including SPK authorization, crypto asset service provider advertising rules, promotional campaigns, prohibited return promises, foreign platforms, influencer marketing, sponsored content, comparative claims, risk disclosures, personal data, consumer complaints and administrative sanctions.

What Is a Crypto Asset Under Turkish Law?

The Capital Markets Law defines a crypto asset as an intangible asset that can be created and stored electronically by using distributed ledger technology or similar technology, distributed over digital networks, and capable of expressing value or rights. The law also defines crypto asset service providers as platforms, crypto asset custody service providers, and other institutions determined under the law to provide services related to crypto assets, including initial sale or distribution. A platform is defined as an institution where one or more activities such as crypto asset buying and selling, initial sale or distribution, exchange, transfer, custody required by these transactions, and other determined transactions are carried out.

These definitions matter for advertising. A business cannot avoid crypto advertising rules merely by calling itself a technology platform, wallet application, Web3 project, digital asset marketplace or community. If the commercial communication promotes crypto asset services, crypto asset transactions, custody, transfer, trading, listing or similar regulated activity, the advertising must be reviewed under the crypto asset regulatory framework.

The legal classification of the advertiser is also important. A crypto asset service provider is not an ordinary e-commerce business. Its advertising is subject to capital markets supervision, consumer protection principles and specific SPK rules on promotions, announcements and customer communications.

SPK Authorization and Regulatory Supervision

Under Article 35/B of the Capital Markets Law, crypto asset service providers must obtain permission from the SPK to be established and to begin activities. They may only perform activities determined by the SPK. The same provision authorizes the SPK to determine principles regarding establishment, commencement of operations, shareholders, managers, personnel, organization, capital, capital adequacy, obligations, information systems, technological infrastructure, share transfers, permitted activities and temporary or permanent suspension of activities.

This authorization framework affects advertising directly. A business should not advertise crypto asset services in Turkey unless it is legally entitled to provide those services. Advertising may become evidence of unauthorized activity if a company promotes crypto trading, custody, transfer or similar services without meeting the applicable regulatory requirements.

The SPK maintains a section for crypto asset service providers, including application processes, entities in operation and entities in liquidation. The existence of public lists is important for consumer trust, but businesses should be careful not to present being listed in a way that implies a government guarantee, investment safety or return assurance.

The 2025 Secondary Regulations

The SPK announced that two main communiqués on crypto asset service providers were published in the Official Gazette on 13 March 2025 and entered into force: the Communiqué on the Establishment and Operating Principles of Crypto Asset Service Providers No. III-35/B.1 and the Communiqué on Working Principles and Capital Adequacy of Crypto Asset Service Providers No. III-35/B.2. The SPK stated that these regulations cover establishment, commencement of operations, activities, suspension of activities, shareholders, managers, personnel, organization, internal audit, internal control, risk management, information systems, technological infrastructure, document and record systems, independent audit, proof-of-reserve audit, crypto asset trading environments, custody, transfers, listing and capital adequacy.

These regulations are central to crypto advertising compliance. They do not only regulate operational matters; they also impose rules on advertising, promotions, announcements, customer communications, records, complaint mechanisms and personal data.

Therefore, crypto advertising in Turkey should be reviewed not only by marketing teams but also by legal, compliance, risk management, data protection and internal control teams.

General Advertising Principles for Crypto Asset Service Providers

The SPK’s III-35/B.1 Communiqué contains a specific rule on advertising, announcements, publications, promotions and disclosures. It states that advertisements, announcements, publications, promotions and notices made through written press, internet, telephone, radio, television, cinema, outdoor media, printed materials and all written, visual and electronic communication tools must be objective. Crypto asset service providers may not make advertisements, announcements, publications, promotions or notices based on false, incorrect or misleading information, and they may not exploit customers’ lack of experience or knowledge.

This rule should be read broadly. It covers website banners, mobile app screens, push notifications, e-mails, SMS, call center scripts, social media posts, influencer briefs, sponsored content, press releases, referral pages, YouTube videos, search ads, billboards and in-app campaign screens.

A crypto advertisement should not be designed merely to increase trading volume. It should communicate accurately and fairly. It should not create a misleading impression about the safety, profitability, liquidity, price direction, regulatory status or user benefits of a crypto asset or platform.

Prohibition on Guaranteed Returns and No-Loss Claims

The most important rule in crypto advertising is the prohibition on return guarantees and no-loss promises. The III-35/B.1 Communiqué states that crypto asset service providers cannot include absolute return or guarantee commitments against loss in advertisements, announcements, publications, promotions and notices, except where legislation permits. It also prohibits statements suggesting that the customer will always make a profit or will never suffer a loss.

Risky claims include:

“Guaranteed profit.”

“No loss.”

“Risk-free crypto trading.”

“Earn every day.”

“Never lose with our platform.”

“Make passive income safely.”

“Double your money.”

“Secure income from crypto.”

“Crypto investment without risk.”

“Everyone can earn.”

Crypto assets may experience extreme price volatility. Even stablecoin-related products, staking-like arrangements, yield products or promotional reward systems may carry risks. Advertising should not hide these risks or create a false perception of certainty.

If a campaign offers a bonus, cashback, fee discount or promotional reward, the advertiser should clearly distinguish that campaign benefit from investment return. A trading bonus is not the same as a guaranteed profit from crypto assets.

Prohibited Income and Additional Earnings Claims

The SPK rules also prohibit certain income-oriented statements. Crypto asset service providers cannot use statements suggesting that particular occupational groups, university students, housewives or various segments of society will obtain additional income, earn profit or increase their existing income.

This rule is highly important for social media and influencer marketing. Many crypto promotions target young people, students, part-time workers or people seeking additional income. Phrases such as “students can earn easily,” “housewives can make extra income,” “salary is not enough, trade crypto,” “earn from home,” or “create passive income with crypto” are high-risk.

The purpose is to prevent advertisers from exploiting financial vulnerability or limited investment experience. Crypto advertising should not present trading as a simple solution to income problems.

Prohibition on Price Targets and Certain Misleading References

The III-35/B.1 Communiqué prohibits crypto asset service providers from including certain types of statements in advertisements and announcements, including statements about a specific price target, misleading references to persons or subjects, and expressions that create unfair competition by highlighting the provider without statistical or concrete data.

This means a platform should not advertise a crypto asset with phrases such as:

“Bitcoin will reach this price.”

“This token will rise.”

“Do not miss the next rally.”

“Target price is coming.”

“Analysts expect huge gains.”

“Join before the pump.”

Even if such wording is used indirectly, it may create investment pressure. Crypto asset service providers should avoid price predictions in advertising. Market commentary, analysis and general information should be separated from commercial promotion and must comply with applicable investment advice and general recommendation rules.

Comparative Claims and “Best Platform” Advertising

Crypto platforms often want to use superiority claims such as “Turkey’s leading crypto platform,” “best prices,” “lowest fees,” “most innovative exchange,” “fastest platform,” “most trusted crypto app,” or “highest liquidity.” These claims are legally risky unless they are objective, measurable and properly substantiated.

The III-35/B.1 Communiqué allows statements based on official or verifiable data, such as figures on financial position, total stored crypto asset size, customer number or transaction volume, only if the source that supports the statement is referenced.

Advertising Board enforcement confirms this approach. In its 12 March 2026 bulletin, the Board examined several crypto asset service provider advertisements. For example, it found that “Türkiye’nin En Yenilikçi ve Avantajlı Kripto Varlık Borsası” created a comparative advertising impression and required objective, measurable data supported by reports or documents from appropriate independent sources; because such support was not provided in the required manner, the advertising was found misleading and a suspension decision was issued.

The same bulletin also examined a sponsored content advertisement using the phrase “Türkiye’nin Lider Kripto Varlık Hizmet Sağlayıcısı” and decided that the advertisement violated advertising rules, resulting in a suspension decision.

The practical rule is clear: do not use leadership, superiority or “best” claims unless the claim is precisely defined, current, objective, measurable and supported by proper evidence.

Promotional Campaigns, Bonuses and Referral Offers

Crypto platforms frequently use promotional tools such as welcome bonuses, trading fee discounts, referral rewards, cashback campaigns, deposit bonuses, airdrops, token gifts and trading competitions. These campaigns can be lawful if transparent, but they can also become misleading.

A campaign advertisement should clearly disclose:

Eligibility conditions.

Campaign period.

Reward amount.

Maximum benefit.

Minimum deposit or trading volume.

Whether the reward is withdrawable.

Whether the reward is paid in Turkish lira, crypto asset or platform credit.

Whether there are exclusions.

Whether the campaign is limited to new users.

Whether KYC completion is required.

Whether trading risk exists.

In the Advertising Board’s March 2026 bulletin, a crypto platform’s “welcome” campaign was examined, and the Board decided that the relevant advertisements violated the consumer protection and advertising rules, issuing a suspension decision.

Promotional campaigns should not encourage excessive trading or direct users toward specific crypto assets. They should not give the impression that a promotional bonus eliminates trading risk.

Foreign Crypto Platforms and Reverse Solicitation

Foreign crypto asset service providers must be especially careful when targeting Turkey. Under Article 9 of the III-35/B.2 Communiqué, services obtained from foreign crypto asset service providers are outside the scope of the communiqué only if there is no advertising, promotion or marketing activity directed at persons resident in Turkey and the Turkish resident acts entirely on their own initiative.

The same article states that if a foreign organization opens a workplace in Turkey, creates a Turkish-language website, or directly or indirectly conducts promotion and marketing activities through persons or institutions resident in Turkey in relation to the offered investment services and activities, the activities are deemed directed at persons resident in Turkey and the relevant Turkish rules apply.

This is one of the most important crypto advertising rules in Turkey. A foreign platform may not rely on “we are offshore” if it uses Turkish language, Turkish influencers, Turkish social media campaigns, Turkish SEO, local payment channels, Turkish customer support or Turkey-focused referral promotions.

For foreign platforms, even a Turkish-language landing page, local affiliate campaign or influencer promotion may be evidence that the service is directed at Turkey.

Influencer Marketing and Crypto Assets

Crypto influencer marketing is high-risk. Influencers may promote platforms, tokens, trading campaigns, referral codes, educational content, market commentary or investment communities. If the influencer receives payment, commission, referral income, free tokens, trading benefits, event participation or another commercial benefit, the advertising nature must be clearly disclosed.

The Ministry of Trade’s influencer guide states that advertisements made through social media influencers must be expressed clearly and understandably and must be distinguishable as advertising.

For crypto assets, disclosure is only the first step. A disclosed influencer advertisement may still be unlawful if it promises returns, suggests no-loss trading, gives price targets, encourages vulnerable groups to trade, hides campaign conditions, promotes unauthorized services, or presents personal gains as typical.

Influencer agreements should therefore include strict compliance clauses. Influencers should be prohibited from using phrases such as “guaranteed profit,” “this coin will rise,” “use my code and earn,” “I made this much, you can too,” or “risk-free investment.” The platform should review and approve scripts before publication.

Sponsored Content and Native Advertising

Crypto platforms often publish sponsored articles on news websites or finance portals. These may appear as educational content, market analysis, security warnings or technology news. If the content promotes a crypto platform, service or campaign, it must be clearly identified as advertising or sponsored content.

The March 2026 Advertising Board bulletin is important because one crypto-related file involved sponsored content published on a news website with the phrase “sponsorlu içerik.” Even though the content was labeled sponsored, the Board still examined the substantive claim “Türkiye’nin Lider Kripto Varlık Hizmet Sağlayıcısı” and found it unlawful.

This shows that sponsorship disclosure alone is not enough. The content must also comply with substantive advertising rules. A sponsored crypto article should not use unsupported superiority claims, price predictions, return promises or misleading risk language.

Risk Disclosures in Crypto Advertising

Crypto advertising should include clear and understandable risk disclosures where appropriate. However, a disclaimer cannot cure a misleading headline. For example, an advertisement saying “guaranteed income” cannot be made lawful by adding a small “crypto assets are risky” note.

Risk disclosures should be visible, readable and close to the main claim. They should not be hidden at the bottom of the page, behind a link, in unreadable small text or in a long legal document. The consumer should understand before clicking, depositing or trading that crypto assets may lose value and that trading involves risk.

A good risk disclosure should be plain and direct. It should state that crypto assets are volatile, that past performance does not guarantee future results, that investors may lose part or all of their investment, and that platform promotions do not remove market risk.

Customer Communications and Recordkeeping

Crypto asset service providers must keep records of communications with investors, including advertisements, promotions, marketing activities and similar communications in verbal, written and electronic media.

This rule is very important in practice. Marketing materials should be archived with publication dates, screenshots, campaign conditions, approvals, influencer scripts, social media content, e-mail versions, push notifications, landing pages and call center scripts. If a complaint or regulatory inspection arises, the provider should be able to prove what was published and when.

A crypto platform should also preserve evidence supporting claims, such as transaction volume data, customer number data, liquidity data, awards, independent research reports, campaign rules, risk disclosures and approval records.

Personal Data and Targeted Crypto Advertising

Crypto platforms often use personal data for marketing. They may process identity data, contact information, device identifiers, trading behavior, wallet activity, abandoned registration, deposit history, app activity, marketing preferences and referral data.

The III-35/B.1 Communiqué states that where crypto asset service providers share collected customer information with other institutions, the provisions of Personal Data Protection Law No. 6698 must be observed.

This affects targeted advertising. If a platform segments users based on trading behavior, risk profile, inactive account status, deposit history or crypto interests, KVKK compliance must be reviewed. The platform should not assume that all customer data can be freely used for promotional targeting.

Marketing permissions, commercial electronic message consent, cookie and SDK consent, privacy notices and opt-out rights should be managed carefully.

Outsourcing Advertising and Marketing Activities

Crypto asset service providers may work with advertising agencies, media buyers, design teams, influencers, call centers and technology vendors. However, outsourcing does not eliminate responsibility.

The III-35/B.1 Communiqué states that activities requiring SPK permission and the marketing of those services and activities cannot be outsourced as part of the regulated service outsourcing framework. It also provides that external service use does not remove the crypto asset service provider’s legal responsibilities.

From a practical perspective, a platform may receive ordinary advertising, design or media support, but it must retain compliance control. The provider should not allow an agency or influencer to freely create claims about returns, platform leadership, fee advantages, customer numbers or crypto asset price expectations.

Advertising agencies should receive written compliance instructions. Final approval should remain with the crypto asset service provider’s authorized internal teams.

Insurance and Security Claims

Crypto platforms often want to advertise their custody structure, security technology, insurance, proof-of-reserve procedures, cold wallet systems or audit processes. Such claims may be lawful if accurate, but they must not create a false sense of complete protection.

The III-35/B.1 Communiqué expressly states that insurance obtained under the relevant provision cannot be made the subject of advertising and promotion in publications, announcements and notices of the crypto asset service provider.

This is significant. A platform should not use insurance language to make consumers believe that their crypto assets are fully protected against all risks. If security-related information is provided, it should be factual, limited and not promotional.

Claims such as “fully insured,” “100% safe,” “bank-level protection,” “your crypto is always protected,” or “no risk of loss” should be reviewed extremely carefully.

Consumer Reviews and Social Proof

Crypto platforms may use user testimonials, app store reviews, star ratings, community comments, social media posts or customer satisfaction claims. These forms of social proof are persuasive and therefore legally sensitive.

A platform should not publish fake reviews, selectively highlight only favorable comments, use employee testimonials, buy reviews, use AI-generated comments or present unverifiable customer experiences as genuine. If customer satisfaction claims are used, they should be supported by reliable methodology and current data.

The Advertising Board’s March 2026 bulletin shows that when a crypto platform used “Mükemmel Müşteri Deneyimi,” the Board examined whether the platform could support the claim with numerical data and whether there was evidence of misleading information. In that specific file, the Board concluded that the claim was not unlawful because the company had established relevant infrastructure and supported the statement with numerical data.

This decision is useful because it shows that evidence matters. A strong claim may be defensible if properly supported; an unsupported superiority claim may be unlawful.

Social Media Promotions

Crypto social media advertising should be reviewed carefully. Posts on Instagram, X, TikTok, YouTube, Telegram and Discord can all be treated as advertising if they promote a platform or campaign.

Risky social media practices include:

Memes suggesting guaranteed profit.

Influencer screenshots of gains.

Referral-code posts without disclosure.

Countdowns encouraging impulsive trading.

Token price predictions.

“Join before it rises” messages.

Claims targeting students or people seeking extra income.

Misleading comparisons with other platforms.

Social media content often spreads quickly and may be copied, reshared or screenshotted. This increases regulatory and reputational risk. A crypto platform should therefore maintain an approval workflow for social media content and preserve published versions.

Commercial Electronic Messages and Push Notifications

Crypto platforms frequently use SMS, e-mail, push notifications and in-app messages to promote campaigns, new listings, fee discounts, referral bonuses or price alerts.

Marketing messages should not be confused with transactional messages. A security alert, password reset message or withdrawal confirmation is different from a campaign message. Promotional messages should comply with commercial electronic message rules, marketing consent, opt-out rights and KVKK principles.

Push notifications are particularly risky because they appear directly on the user’s device. A message such as “This token is moving now,” “do not miss the opportunity,” or “deposit today and earn” may create investment pressure. Crypto platforms should avoid wording that triggers fear of missing out or suggests urgent profit.

New Listings and Token Promotions

Crypto platforms may announce new crypto asset listings. Listing announcements should be factual and should not present the listed asset as a recommended investment.

A lawful listing announcement may state that a crypto asset has been listed, when trading begins, what pairs are available and where users can read information. A risky listing announcement may say “the next big opportunity,” “early investors may win,” “this token will rise,” or “do not miss the launch.”

If a platform receives compensation, commercial benefit or issuer-related support in connection with a listing promotion, conflict-of-interest and disclosure issues may arise. Listing communications should be reviewed under platform listing procedures, advertising rules and market integrity principles.

Dark Patterns in Crypto Advertising

Dark patterns are manipulative interface designs that pressure consumers into decisions. In crypto advertising, dark patterns may appear in sign-up flows, campaign screens, trading interfaces, notification prompts and referral pages.

Examples include:

Large “buy now” buttons and hidden risk warnings.

Countdown timers that create false urgency.

Default opt-ins for marketing consent.

Promotional banners that hide conditions.

Confusing bonus withdrawal rules.

Making account closure difficult.

Using profit visuals without loss scenarios.

Highlighting rising assets while hiding volatility.

Because crypto markets are risky and fast-moving, interface design should not exploit impulsive behavior. Advertising should support informed choice, not emotional trading.

Administrative Sanctions and Enforcement

Unlawful crypto advertisements may trigger several layers of enforcement. Under the SPK framework, crypto asset service providers may face regulatory measures concerning authorization, activities, records, internal controls and compliance. Under consumer protection law, misleading advertisements and unfair commercial practices may be examined by the Advertising Board.

For 2026, the Ministry of Trade announced that administrative fines for misleading advertisements and unfair commercial practices may range from 99,339 TL to 39,916,524 TL, depending on factors such as the nature of the violation, benefit obtained, harm caused, fault, economic condition of the advertiser and advertising medium.

Advertising Board enforcement in 2026 confirms that crypto asset advertisements are actively reviewed. The Board examined claims concerning welcome campaigns, superiority statements, customer experience and leadership claims in the crypto sector, issuing suspension decisions where it found violations.

Therefore, crypto advertising should be treated as a regulatory risk area, not merely a marketing function.

Practical Compliance Checklist for Crypto Asset Advertising in Turkey

Crypto asset service providers and advertisers should apply the following checklist:

Confirm that the advertiser is authorized or legally entitled to provide the promoted service.

Use the correct trade name, registered business name or approved brand where required.

Do not promise guaranteed profit.

Do not state or imply that customers cannot lose money.

Do not target students, housewives or other social groups with easy income claims.

Do not use specific crypto asset price targets in advertisements.

Do not use unsupported “best,” “leading,” “most trusted,” “lowest fee” or similar superiority claims.

Support statistical claims with verifiable and current data.

Clearly disclose campaign conditions, exclusions and maximum benefits.

Separate promotional rewards from investment returns.

Do not promote insurance as a marketing advantage where prohibited.

Disclose influencer and affiliate relationships.

Prohibit influencers from making return promises or price predictions.

Clearly label sponsored content.

Keep risk warnings visible and understandable.

Do not direct Turkish residents to foreign platforms through Turkish-language or local marketing if the provider is not compliant with Turkish rules.

Preserve advertising records, screenshots, approvals and campaign evidence.

Review KVKK and commercial electronic message compliance.

Avoid dark patterns and false urgency.

Train marketing, compliance, legal, product and customer support teams together.

Best Practices for Crypto Platforms

A compliant crypto advertising strategy should be built around transparency and risk awareness. Marketing teams should not focus only on user acquisition, deposit growth or transaction volume. Every advertisement should be assessed from the perspective of an average consumer who may not fully understand crypto volatility, custody risk, cybersecurity risk or market manipulation risk.

The safest approach is to use factual, balanced and evidence-based language. A platform may explain its services, technology, fees, listing process, custody arrangements and customer support. It should not sell dreams of easy profit.

Before publishing any campaign, the platform should ask:

Does the advertisement imply profit?

Does it hide risk?

Does it encourage excessive trading?

Does it target vulnerable groups?

Is every claim provable?

Are campaign conditions clear?

Is sponsorship disclosed?

Is the communication archived?

Has legal and compliance approval been obtained?

If the answer to any of these questions creates concern, the advertisement should be revised before publication.

Conclusion

Crypto asset advertising and promotion rules in Turkey have become significantly stricter following the 2024 amendment to the Capital Markets Law and the 2025 SPK secondary regulations. Crypto asset service providers are now subject to SPK regulation and supervision, and they must comply with specific rules on advertisements, promotions, announcements, customer communications and records.

The central advertising principles are clear: crypto promotions must be objective, truthful, verifiable and not misleading. They must not exploit customers’ lack of experience or knowledge. They must not promise absolute returns, guarantee protection against loss, target vulnerable social groups with income claims, use price targets, or make unsupported superiority claims.

Foreign platforms must also be careful. If a foreign crypto asset service provider uses Turkish-language websites, local promotion, Turkish intermediaries, Turkish influencers or direct marketing aimed at persons resident in Turkey, its activities may be treated as directed at Turkey and become subject to Turkish rules.

Recent Advertising Board decisions show that crypto advertising is actively enforced. Claims such as “Türkiye’nin En Yenilikçi ve Avantajlı Kripto Varlık Borsası” and “Türkiye’nin Lider Kripto Varlık Hizmet Sağlayıcısı” were examined under misleading and comparative advertising rules, and suspension decisions were issued where the Board found the claims unsupported or unlawful.

For crypto platforms, fintech advertisers, influencers and foreign providers targeting Turkish users, the safest rule is simple: do not market crypto assets as easy, guaranteed or risk-free income. Advertise services factually. Disclose risks clearly. Prove every superiority claim. Avoid manipulative promotions. Keep records. Respect SPK, consumer protection and KVKK rules.

A lawful crypto advertising strategy protects investors, reduces enforcement risk and builds long-term trust. In Turkey’s regulated crypto asset market, sustainable growth depends not on hype, fear of missing out or unsupported promises, but on transparency, compliance and responsible communication.

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